Just when you thought you were beginning to
understand Europe’s environmental regulations, the
European Union turns the tables and will change
them again. In the process, these requirements
will become much more complicated, more costly,
and—for product designers—more challenging.
Adding to this growing complexity is the emergence
of environmental restrictions that target the
electronics industry from China, Korea, and India
(Fig. 1). Also, California’s RoHS-like laws covering
the chemical content of electronic products,
electronic waste, and energy efficiency are expected
to impact the industry inside and outside the state.
The EU’s Restrictions on Hazardous Substances (RoHS) originally
limited the use of six hazardous substances in electronic
products. Another EU directive, Waste from Electrical and Electronic
Equipment (WEEE), focuses on recycling e-waste.
RoHS requires manufacturers to demonstrate that their products
don’t contain more than the maximum permitted levels of
lead, mercury, cadmium, hexavalent chromium, polybrominated
biphenyls, and polybrominated diphenyl ethers. RoHS has already
come at a big cost to the industry, even to companies that have had
formal environmental programs in place for years
(Fig. 2).
A study conducted for the Consumer Electronics Association
by Technology Forecasters Inc. estimates that the RoHS directive
cost the global electronics industry more than $32 billion for initial
compliance and about $3 billion annually to maintain compliance.
The study also found that companies spent on average about
$2.6 million to achieve initial RoHS compliance and another
$482,000 for annual maintenance.
But according to the European Commission (EC), which oversees
RoHS and WEEE, more than four years after these directives
went into effect, only about a third of electronic waste is reported
to be treated in line with these laws. The other two-thirds is going
to landfill and potentially to substandard treatment sites in or
outside the EU.
THE PCB CONTROVERSY
Meanwhile, the EC was considering adding substances to the
RoHS list. One of these was tetrabromobisphenol A (TBBPA), a
reactive flame retardant used in most printed-circuit-board (PCB)
laminates. TBBPA was one of the more controversial additions
to the draft list of the European Commission’s Environmental
Directive-General.
The IPC, a global trade association that comprises 2700 members,
has been anything but supportive of adding TBBPA to RoHS.
The group says that many PCB manufacturers and end users of
circuit boards would not be able to afford the more costly halogenfree
laminates.
The group also pointed out that some of the electrical and
dielectric properties of halogen-free materials are different compared
to those based on TBBPA, requiring the redesign of many
PCBs. The IPC won its case when the EC recently announced that
it does not intend to add TBBPA as an additional substance to be
monitored or restricted under RoHS.
“TBBPA was found to be safe for humans and the environment
by a comprehensive risk assessment conducted by the European
Union and therefore is not expected to be restricted under the
EU’s Restriction, Evaluation, and Authorization of Chemicals
(REACH) regulation,” says Lee Wilmot, director of EHS at TTM
Technologies Inc. and chair of the IPC EHS Steering Committee.
Several groups are involved in revising RoHS, now known as
RoHS2. U.K.-based ERA Technology was contracted to look at
the viability of adding categories, such as medical equipment and
monitoring and control instruments, to the scope of RoHS, mainly
because they represent different markets than consumer electronic
products.
Also, the EC assigned the German-based Oko Institute to consider
adding new restricted substances within the scope of the
directive. Oko was further asked to conduct a separate study considering
the validity of all current exemptions to RoHS.
At last count, a list of 46 potential restricted substances was
reduced to eight under RoHS2. But in a letter to its member companies
in May 2008, IPC called the institute’s draft report on adding
substance restrictions “biased” with “flawed methodologies.”
MORE CHANGES
Other proposed changes by the EC’s Directorate General Environment
to both RoHS and WEEE directives showed up in a new
round of proposals published in December, aimed at clarifying
the scope and definitions in the directives. Details of the proposed
changes can be found on the EC Web site at ec.europa.eu/environment/waste/weee/index_en.htm.
One change covers new procedures for exemptions, including
introducing additional socio-economic criteria for granting
exemptions and a requirement for applicants to evaluate substitutes
before submitting requests. Another calls for adding medical
devices and control and monitoring instruments to the scope of
RoHS. There’s also language for establishing a clear mechanism
for identifying and, “if necessary,” restricting the use of additional
hazardous substances.
The EC says it recognizes that revisions to the RoHS directive
covering medical devices and control and monitoring instruments
may add manufacturing costs, particularly for products produced
in smaller numbers. However, the commission also said that rolling
out exemptions of these products over a period of time would
allow the proposed exemptions to occur in normal product development
cycles.
One of the big changes under consideration for WEEE is to
harmonize the registration and reporting obligations for producers, along with harmonizing their financing
across the EU. (Some member states
already make producers fully financially
responsible for WEEE.) The EC also wants
to clarify what products are excluded from
the scope of the directive.
Continue to page 2