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. In addition to disposal payments, use of non-lead solder, and the redesign of injection molds to match flow characteristics of plastics without banned substances, those involved are defining and refining some vagu...
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.
In addition to disposal payments, use of non-lead solder, and the redesign of injection molds to match flow characteristics of plastics without banned substances, those involved are defining and refining some vaguely written regulations.
This means you
For disposal, the following players could be held as responsible as the equipment manufacturers themselves:
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.
Remove hazardous substances
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.
Plan ahead to save money
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."
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Regulations are among primary products created by the European Union (EU), which expands from 15 member states and 375 million people to 25 member states and about 450 million people in 2004. Counting like-minded countries, the population of the region could top 500 million people this year, according to Iain Lindsay, Global Standards & Trade (Europe) for Rockwell Automation.
And while he suggests that directives aim to do good things, because they're part of a political process, how they're formed is not always exact or predictable. The process involves the European Commission, each of the EU countries, and the European Parliament. Lindsay says, "When legislation is proposed, sometimes it's a problem to figure out with whom to talk. Securing changes in directives can be very difficult."
The Technical Adaptation Committee—chaired by the European Commission and comprised of Member State representatives—gets proposals from associations and industry on how to solve outstanding issues, then will decide, explains Dr. Ferdinand Quella, Siemens head of product-related environmental protection. To track regulations and advocate solutions, most major manufacturers seem to have multiple persons tracking development and impacts, and seeking to work with all parties for the most cost-effective compliance. Manufacturers such as Siemens, says Quella, also have been working within their supply chains to educate distributors and system integrators and customers, so there are no surprises. Some requirements were already met: "We've removed cadmium from products for 10 years in Europe." (Also, Siemens Gammasonics banned cadmium plating of metal parts in the mid-1980s.)
Lindsay says Rockwell Automation started RoHS plans in 2002 and expects to comply with most products before or during 2005. Lead circuit boards are a problem still under investigation, while eliminating cadmium plating and pigments was completed in 1992. Lindsay covered the topics during "Market Access Requirements for Europe: The Implications of New Environmental Legislation," at Automation Fair, Milwaukee, WI, Nov. 20, 2003, and in comments to Control Engineering .
Other directives restrict hazardous substances, one for dangerous substances and preparations, another for batteries, and another for packaging. Some actions capture headlines, such as the November 2003 action from Dutch officials, who halted shipment of 1.3-million Sony PlayStation game consoles because the cables reportedly contained too much cadmium. High-profile examples underscore the need for companies to continue to educate their partners; track directives, regulations, and standards; as well as participate in European trade associations and meet with EU officials and with representatives of national governments.
Those involved in the transition roadmaps know where things stand on the journey to compliance. For instance, areas of study within Phoenix Contact, include:
Semi-finished products and surface coatings on metal body parts of connection/termination products;
Plastic material including material used in terminal block housings, electronic enclosures and plastic accessories;
Electronic components and printed circuit boards (PCBs); and
Lead-free soldering in the reflow furnace, wave-soldering bath, and with selective soldering systems. "Many electronic components are not available as lead-free products, so we will only change once they are commercially available," says says Arnold Offner, who heads up the Phoenix Contact Inc.
USA International Committee Area, and is a product manager for Varioface wiring interfaces.
Plastics used by Phoenix Contact do not contain any cadmium, PBB, and PBDE (polybrominated biphenyl flame-retardants). Conversion to lead-free soldering and surface systems without hexavalent chromium are in process. Offner says, "Our first product that fulfilled many of the above requirements was our PLC-Relay launched in 1997 that did not use the usual silver cadmium oxide power contacts, and now uses AgSnO (silver-tin-oxide)." Existing products that fulfill requirements of the directives include ST family of spring cage terminal blocks; feed-through and installation modular terminal blocks in screw version; PCB/Combicon family; and printed circuit board terminal blocks.
Rich Widdowson, director of safety, real estate, and environment for North American Division of Schneider Electric says his company already has largely eliminated cadmium except for some products manufactured in other global regions and sold in Europe. Schneider Electric also took steps several years ago to eliminate mercury and polybrominated biphenyl substances, he says.
Key Dates for WEEE and RoHS
Feb. 13, 2003
European Commission (of the European Union) publishes Directive on Waste Electrical and Electronic Equipment (WEEE) and EC Directive on the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment (RoHS).
Aug. 13, 2005
Producer responsibility for financing commences alongside retailer take-back.
July 1, 2006
RoHS substance ban commences.
Dec. 31, 2006
Collection and recycling targets to be achieved.
Source: Control Engineering with information from U.K.
More information, links
The January 2004 Control Engineering “Lifecycle Environmentalism” article summarizes what the Waste Electrical and Electronic Equipment (WEEE) directive covers; the 10 categories for electrical and electronic equipment follow. As sources suggest, more specific definitions are needed.
1. Large household appliances;
2. Small household appliances;
3. IT and telecommunications equipment;
4. Consumer equipment;
5. Lighting equipment;
6. Electrical and electronic tools (with the exception of large-scale stationary industrial tools);
7. Toys, leisure, and sports equipment;
8. Medical devices (with the exception of all implanted and infected products);
9. Monitoring and control instruments; and
10. Automatic dispensers.
In addition to vendors’ Web sites, the following links provide additional information.
—Mark T. Hoske, Control Engineering , editor in chief
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