European Union regulations have the world hopping to comply at the beginning and end of the product lifecycle, to design without banned substances and meet new disposal requirements.

• System integrators may become responsible for systems they assemble;
• Distributors, who represent manufacturers, import, and serve as point of sale;
• End-users who may receive higher fees for purchase of equipment to recoup higher costs of manufacturing and end-of-lifecycle disposal, and those who assemble their own systems.
  Several existing regulations restrict use of certain materials, but a number of undefined terms have manufacturers conferring among themselves, with industry groups, and with regulators about two in particular.
• Restriction of Hazardous Substances (RoHS) covers design of electrical and electronic equipment containing lead, mercury, cadmium, hexavalent chromium, and the polybrominated biphenyl flame-retardants PBB and PBDE; and
• Waste Electrical and Electronic Equipment (WEEE) aims to prevent waste of electrical and electronic equipment and encourage reuse and recycling and other forms of recovery of such wastes to reduce disposal requirements.

RoHS has the goal to reduce hazardous substances from leaching out of landfills into waterways or groundwater and prevent incinerated items from releasing toxic chemicals into the air. Details regarding minimums haven't been set for each substance covered, although some expect the need not to exceed 0.1% by weight for lead, mercury, hexavalent chromium, PBB and PBDE and 0.01% for cadmium. Here, too, some exceptions are offered, like some servers, which can contain lead until 2010. Monitoring and control instruments may be extended from 2006 compliance until perhaps 2010, suggests Iain Lindsay, Global Standards & Trade (Europe) for Rockwell Automation. How percentages apply is under discussion, but the most likely outcome is thought to be at the homogeneous material level (rather than for components), he says.

WEEE Directive's 10 categories include IT and telecommunication equipment, electrical and electronic tools, and monitoring and control instruments. Member states each will publish disposal requirements for the February 2003 directive, which will be made into national legislation in August 2004; producer responsibility begins in August 2005. Among requirements will be a wheeled-bin trashcan symbol with a line through it, showing that, within EU, special disposal requirements apply.

Products will need to carry a mark to identify specific manufacturers, Lindsay says. One method under discussion is simple weighing of the disposed equipment, with a charge back to the original manufacturer. Clarifications are required; for instance, large-scale, stationary industrial tools are exempt, but not defined. With assembled components, however, the end-user or system integrator could be responsible, but there's a question of how far something should be taken apart and who'd be responsible for each piece. Local distributors, or importers also could be on the line for disposal fees, Lindsay suggests.

Under a proposed amendment, for items in place prior to Aug.13, 2005, the manufacturer winning the next contract would be responsible for disposing of what was there before, even if from a different manufacturer, says Lindsay. After the 2005 date, the producer (or integrator) would be responsible. "Alternatively, producers and users can agree contractually who is responsible," he says. If the manufacturer doesn't have staff in a particular member country, distributors would be responsible. Producers may need to register or provide financial guarantees in a particular member state. In addition, information may need to be given to recycling facilities about how to disassemble components within one year from when the product is put on the market.

Depending on the application, a particular device or technology might fall into different WEEE categories. Also, if a display is resold, it's unclear if disposal responsibility remains with the manufacturer or transfers to the reseller. Non-compliant inventory is another point yet to be resolved, suggests Dr. Ferdinand Quella, Siemens head of product-related environmental protection.

Incorporating current and upcoming regulatory requirements into normally scheduled product redesign remains the most cost-effective means of compliance. Quella says Siemens has been reworking "a lot of products" using lead-free solder because of the RoHS directive.

"Lead-free solder is not such a problem as we thought at first." Because a higher melting temperature is required to optimize solder conditions, board designers had to check if components would be stable at higher temperatures. Some exceptions, such as for sandwich components, which could remelt, have been helpful. "Every three months or so, we come up with another problem. The commission has been open-minded," Quella says, when technical limits are explained.

Siemens, like other manufacturers, has made roadmaps for transitioning product lines to comply. "We expect to finish six to 12 months ahead," Quella says. Cost for transition has not been calculated, he says, because it's integrated into ongoing product redesign and recertification.

The National Electrical Manufacturers Association (NEMA) helps express the collective views of manufacturers, says Omron Electronics' Pete Walthers, standards and safety manager. As Omron liaison for the NEMA Industrial Automation components section, he leans toward diplomacy, saying, "while regulators have good ideas, manufacturers can help on details and implementation" to comply in the most practical means possible. When designs change solely to comply with regulations, costs obviously are higher, he says, and may get transferred to customers.

Schneider Electric's roadmap seeks RoHS compliance by July 1, 2005, a year ahead of time, in part to ensure its supply chain moves existing inventory ahead of the deadline, says Rich Widdowson, director of safety, real estate, and environment for North American Division of Schneider Electric. Hexavalent chrome principally is found in plated steel products, such as screw fasteners—and that involves working with suppliers he says.To integrate environmental thinking, Widdowson helps train engineering teams to look at designs and processes as product designs evolve. One example is making the switch to cathodic paint booths to avoid use of hexavalent chromium.

Internal company working groups often address how directives relate to "products, components, and production stages," says Arnold Offner, who heads up the Phoenix Contact Inc.—USA International Committee Area, and is a product manager for Varioface wiring interfaces. Offner says some global players (including Japanese companies) in the electronics market are looking at making the directives "a global standard, just like the CE Mark. As the July 1, 2006, deadline approaches, he expects North American electronic component suppliers and distributors to be "inundated with inquiries from customers and manufacturers."