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ROHS and WEEE Directives After the Deadline September 2006 Berri Remenick Washington Laboratories, L


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Title: ROHS and WEEE Directives After the Deadline September 2006 Berri Remenick Washington Laboratories, L

ROHS and WEEE Directives -After the Deadline-
September 2006
Berri RemenickWashington Laboratories, Ltd.
  • Worldwide Product Based Environmental
  • ROHS Requirements and Issues
  • WEEE Requirements and Issues
  • FAQ

  • As electronics have become more common throughout
    the world, concerns have developed as to what the
    effect is of filling landfills with electronics
  • Many of these electronic products contain
    hazardous substances.
  • Therefore, product based environmental
    regulations are becoming more common worldwide.

  • Americans discard over 100 million computers,
    cell phones, and other electronic devices each
  • An estimated 60 million PCs
  • have already been buried in
  • US landfills.
  • Between 2004 and 2009,
  • 250 million computers will
  • become obsolete or
  • 136,000 computers a day!!!
  • Electronic waste is accumulating almost 3 times
    faster than ordinary household trash.
  • E-Gad, Elizabeth Royte, Conformity Magazine,
    November 2005

  • RoHS DIRECTIVE (2002/95/EC) Restriction of
    Hazardous Substances
  • Limits use of Lead, Cadmium, Mercury, Hexavalent
    Chromium, PBB and PBDE in electronic products
    effective July 1, 2006.
  • WEEE DIRECTIVE (2002/96/EC) Waste Electrical
    Electronic Equipment
  • Requires producers to manage post-consumer
    recycling and disposal of electronic products
    effective August 13, 2005.
  • EuP DIRECTIVE (2005/32/EC) Energy Using
  • Requires producers to design products to meet
    specific eco-design criteria over entire life
    cycle effective 2007 for certain specific
    products. Regulates products that have sales of
    over 200,000 units per year in the EU, have a
    significant environmental impact over their
    entire life cycle, and have a wide range of
    environmental performance between different units
    with equivalent functionality.
  • REACH DIRECTIVE Registration, Evaluation and
    Authorization of Chemicals
  • Requires registration and risk assessment of
    chemical substances effective 2007.

  • Nearly all states either already have some
    regulations for restricting substances or for
    electronics recycling requirements or they have
    some pending legislation.
  • A national system for electronics recycling has
    been proposed but is not near approval yet.
  • Website with a detailed list of requirements for
    each state
  • http//

  • California The current California ROHS covers
    displays greater than 4 inches and is effective
    1/1/07. Pending Legislation for AB2202 is one
    step closer to the EU RoHS directive. AB2202,
    passed the California Assembly on May 31, 2006.
    Recently updated, the bill would expand the
    current restricted substance requirements to
    cover all products listed in Annex 1A of the WEEE
    directive. The scope of products covered was
    further clarified to harmonize with the EU RoHS
    Directive's Article 2. The enforcement deadline
    has been moved out to January 1, 2010 to provide
    manufacturers with a realistic amount of time to
  • Washington State Has enacted legislation that
    will establish an electronics recycling program
    requiring electronics manufacturers to pay for
    the collection, transportation and recycling of
    computers, monitors and televisions from
    consumers, small businesses, schools, small
    governments and charities.  Manufacturers
    required to register with the state by January 1,
    2007, and the recycling program comes into effect
    as of January 1, 2009.
  • Rhode Island Proposed legislation that would
    prohibit the manufacture and sale of products
    containing more than one-tenth of one percent of
    pentaBDE or octaBDE, and more than one percent of
    "deca" mixtures.

  • - Effective 3/1/07
  • - Has requirements similar to RoHS and WEEE.
  • - Has new energy efficiency standards for
    certain products.
  • - Packaging must be non-toxic, biodegradable and
  • Recyclable. Packaging must be marked with
    material content.
  • - RoHS materials (Cd, Cr, Hg, Pb, PBB, PBDE) are
    banned from
  • January, 2006.
  • - Products must be labeled with
  • names, content levels, and recyclability of
    harmful materials recyclability (fully,
    partially and non-recyclable)
  • product safety periods (date range product is
    safe to use).
  • - Producers must contract with local recyclers
    to recover products after
  • safety period.
  • - Producers must finance recycling.

  • The South Korean government is reportedly moving
    to adopt RoHS/WEEE-like legislation that will
    take effect July 1, 2007.
  • The proposed Act for Resource Recycling of
    Electrical/Electronic Products and Automobiles
    includes virtually anything electrical or
    electronic within the scope of its requirements.
    While specifics on restricted materials are not
    yet available, the Korea Ministry of Environment
    has indicated that consistency with the
    provisions of the European Unions RoHS Directive
    can be expected.
  • The proposed legislation does spell out penalties
    for non-compliance. For example, failure to
    provide data requested by government officials
    regarding material composition can result in a
    fine of up to 50,000 and a year in jail.

RoHS Directive
  • Scope
  • The directive covers all equipment dependent on
    electrical currents or electromagnetic fields in
    8 categories
  • - IT / Telecommunications
  • - Electrical and Electronic Tools
  • - Consumer Equipment
  • - Large Household Appliances
  • - Small Household Appliances
  • - Lighting Equipment
  • - Toys, Leisure and Sport
  • - Automatic Dispenser

RoHS Directive
  • Is a 95/EC Directive Requirements are the same
    for all member states in the European Union (not
    the case for WEEE).
  • No product marking requirements.
  • Allows for Self Certification.
  • No harmonized standards or test methods currently
    (some in progress).
  • No specified compliance method (each manufacturer
    must decide on their own method).
  • Download RoHS Directive at http//

RoHS Limits
  • Homogenous material can contain a maximum of
  • 0.1 lead by weight.
  • 0.1 mercury by weight.
  • 0.01 cadmium by weight.
  • 0.1 hexavalent chromium by weight.
  • 0.1 polybrominated biphenyls by weight.
  • 0.1 polybrominated diphenyl ethers by weight.
  • Homogeneous material materials of uniform
    composition which cannot be mechanically
    disjointed into different materials. For
    example, an IC has silicon chip, wires, solder,
    pins, casing.

RoHS Directive
  • Compliance Methods
  • Destructive vs non-destructive testing
  • Materials testing using X-Ray Flourescent
    screening (EDXF or XRF)
  • Detailed Materials testing using Gas
    Chromatography or Mass Spectroscopy
  • Rely on Suppliers Declaration of Conformity

RoHS Directive
  • Suppliers Declaration of Conformity (SDoC)
  • Many different formats out there
  • Without a standard format, there is confusion and
    extra work figuring out each of the multiple
    formats a supplier gets.
  • IPC1751/1752 Material and substance declaration
    form available.
  • If you can show you have taken all reasonable
    steps and exercised all due diligence you stand a
    better chance.
  • You need an extensive paper trail of information
    demanded from the supplier, steps taken to verify
    the information, and if there are any indications
    that the information should be disbelieved.

RoHS Directive
  • Who is responsible?
  • The Producer
  • Producer any person who
  • 1. manufactures and sells electrical and
    electronic equipment under his own brand
  • 2. resells under his own brand equipment
    produced by other suppliers or
  • 3. imports or exports electrical and electronic
    equipment on a professional basis into a member

RoHS - Exemptions
  • Mercury in lamps
  • Lead in the glass of cathode ray tubes (CRT's),
    electronic components, and fluorescent tubes
  • Lead in certain steel, aluminum, and copper
  • Lead in high melting-temperature solders
    containing over 85 lead by weight
  • Lead in solders used for servers, storage, and
    storage array systems
  • Lead in solders used for network infrastructure
  • Lead in electronic ceramic parts
  • Cadmium and cadmium compounds in electrical
    contacts and cadmium plating that isn't banned by
    Directive 76/769/EEC
  • Hexavalent chromium as an anti-corrosion agent in
    absorption refrigerators
  • Lead in compliant pin connector systems
  • Lead as a coating for the thermal conduction
    module c-ring
  • Lead and cadmium in optical and filter glass

RoHS - Exemptions
  • RoHS does not apply to batteries (see Directives
    91/157/EEC and 98/101/EC). The Battery Directive
    permits lead-acid and nickel-cadmium batteries to
    be used in electrical and electronic equipment as
    long as they contain less than 0.0005 by weight
    of mercury. Button cells and batteries made from
    button cells are permitted to contain up to 2
    mercury by weight.
  • RoHS does not apply to electrical and electronic
    equipment "intended specifically to protect
    national security and/or for military purposes
  • RoHS does not currently apply to medical
    equipment or laboratory equipment - being
    reviewed this will be changed soon!
  • Process exists for applying for an exemption,
    several applications for exemption are currently
    under consideration.
  • Items would be given exemptions where substitute
    materials have not been discovered or adequately
  • Exemptions are reviewed every 4 years. If no
    action is taken, the exemptions will stay in

  • Applying for an exemption
  • - Submit request to the European Commission.
  • - Must be precise and refer to a specific
    application of the substances restricted.
  • - Must provide all technical evidence supporting
    the request.
  • - Article 5(1)(b) of the RoHS Directive is the
    only criteria to be followed for an argument.
  • - Once a number of requests deemed worthy are
    collected, the Commission summits the requests to
    a public stakeholder consultation for minimum of
    8 weeks.
  • - The request is then assessed by an independent
    consultant. Report issued in about 3 months.
  • - If still considered possible, it is then
    presented to the Technical Adaptation Committee
    (TAC) for vote.
  • - If it passes, it comes legally into force on
    publication in the OJ.

RoHS - Enforcement
  • EC has published an enforcement guidance document
  • Enforcement authorities have been appointed.
  • Investigations based on- Market intelligence
  • - Random selection
  • - Products known to contain materials of
    high concern
  • - High volume products
  • - Short life products
  • - Consumer products unlikely to be recycled
  • - Tips from external parties
  • - Tips from other member states.
  • Show due diligence!

ROHS - Enforcement
  • Penalties for non-compliance vary by country.
  • Examples
  • UK Max of 9500
  • France Max of 1900
  • Ireland Max of 19.2 Million

Solder Issues
  • Tin whiskers
  • are electrically conductive, hair-like strands of
    single tin crystals that sometimes grow from
    surfaces where tin is used as a final finish. Tin
    is only one of several metals that are known to
    be capable of growing whiskers. Other examples
    include zinc, cadmium, indium and antimony.
    Whisker sizes vary, and some have grown to
    lengths of several millimeters (mm) and in a few
    cases up to 10 mm. Two of the more common
    finishes that are being considered are
    nickel/palladium/gold (NiPdAu) and some
    composition involving tin (Sn). Of these two
    materials, NiPdAu does not grow tin whiskers,
    while tin in both its pure and composition forms
    have shown tin whisker growth.

Solder Issues
  • Solder temperatures
  • - For lead free solder temperatures are higher
    than traditional solder.
  • - It is not completely clear what the effect is
    going to be in the long term using lead-free
    solder, the effect certainly should be considered
    in the product design.
  • - In transitioning to lead-free wave soldering,
    alloy selection will be the primary choice that
    will impact solder joint quality, reliability and
    production yields.
  • - Most assemblers are choosing tin-silver-copper
    alloys (SAC) for leaded solder replacement. On a
    global basis Sn96.5 Ag3.0 Cu0.5 has been the
    favored solder recipe. This alloy also known as
    SAC305 has melting range of 217-220 C the
    traditional alloy 63/37 has a melting point of
    183 C. These alloys have higher melting
    temperatures but also have higher surface

Solder Issues
  • Lead Solder Replacements
  • - Some manufacturers are choosing Sn/Cu alloys
    such as 99.3 tin/ 0.7 lead, some with small
    additions of nickel, silver, bismuth, germanium,
    and other elements.
  • - Due to the lack of silver in these alloys,
    costs are substantially less than processes using
    SAC alloys.
  • - Sn/Cu alloys melt at 227 C but may require
    longer contact times at the wave solder to
    achieve hole-fill. The melting temperature being
    higher will also require slightly hotter pot
  • SAC alloys can be run at 255- 260 C
  • Sn/Cu will require 260-270 C.
  • - In some cases some assemblers are using as high
    as 275 C for Tin-Copper based solders. These
    higher temperatures may put a strain on both
    board and bottom-side component reliability.

Solder Issues
  • Lead-free Wave Soldering
  • - Has been done in a large scale in Asia for
    some time
  • - Equipment upgrade may be required because the
    tin may cause the leaching of iron and could
    required replacement of the solder pot, impeller,
    and ducts.
  • - Alloy selection will impact quality and
  • - Flux selection critical. Fluxes used for
    leaded solder will not give adequate hole-fill
    without increasing flux volumes or longer contact
  • - Fluxes with higher activity and higher solid
    content perform better with lead-free solders.
  • - The use of VOC-free fluxes in conjunction with
    lead-free solders offer a green wave solder
  • - Board and component finish also impacts
    reliability. Matte tin finish gives the best
    soldering results. Gold over nickel finishes and
    immersion silver also solder well.
  • - Bare copper boards are difficult to solder
    with lead-free solder.

Solder Issues
  • Summary of possible issues
  • - Tin whiskers
  • - Thermal fatigue of solder joints
  • - Delamination of multi-layer boards
  • - Damage to plated through holes
  • - PCB warping
  • - Damaging heat sensitive components
  • - More difficult repair or rework

WEEE Directive
  • Scope
  • The directive covers all equipment dependent on
    electrical currents or electromagnetic fields in
    10 categories
  • - IT / Telecommunications
  • - Electrical and Electronic Tools
  • - Consumer Equipment
  • - Large Household Appliances
  • - Small Household Appliances
  • - Lighting Equipment
  • - Toys, Leisure and Sport
  • - Automatic Dispenser
  • - Medical Devices
  • - Monitoring and Control Equipment

WEEE Directive
  • Requires the producer, within one year of putting
    any electrical/ electronic equipment on the
    European market, to provide reuse centers,
    treatment facilities, and recycling facilities
  • Lists of components and materials it contains.
  • Locations of dangerous substances.
  • Encourages producers to design electrical and
    electronic equipment
  • For repair.
  • For possible upgrading.
  • For reuse.
  • For disassembly.
  • For recycling.
  • To integrate recycled material into new
  • Download WEEE Directive at http//

WEEE Directive
  • Is not a single market directive (not a new
    approach directive).
  • Member states set their own requirements for
    registration and compliance.
  • Requirements are different for each member state
    in the European Union!
  • Each member state has its own agency for
    registration and collection.
  • The Producer is responsible.

WEEE Directive
  • Requires each country in the European Union to
    set up facilities for the separate collection of
    waste electrical and electronic equipment.
  • Came into effect August 13, 2005 (implementation
    is behind schedule)
  • December 31, 2006 is date to meet recovery and
    recycling targets.
  • The actual processing may be done by the company
    itself, or by participating in a producers'
    compliance scheme.
  • The producer must provide financial guarantees
    that they will pay for the handling of their
    waste equipment, by participating in a collective
    group for this financing, recycling insurance, or
    a blocked bank account.

WEEE Marking
  • Wheelie Bin Symbol required to be marked on
    product (or the instructions and warranty or the
    packaging) per EN504192005
  • Date of shipment to Europe or the black line
  • Manufacturers name or trademark required on

WEEE Directive
  • Household WEEE
  • Producers pay according the their market share.
  • Non-household WEEE
  • Producers must collect, treat, and recycle one
    equivalent item when they supply a new product.
    Any additional WEEE is the responsibility of the
    last user.

WEEE Directive
  • Actions required
  • Register with the appropriate agency in each
    member state (where possible) pay the required
  • Provide sales data by weight to authorities.
  • Provide information required by recyclers
  • Provide financial guarantees for products that
    will be household WEEE.

WEEE Directive
  • Exclusions
  • - Equipment part of a larger product (i.e.
    electronics installed in a train)
  • - Military Equipment
  • - Equipment used a integral parts of large-scale
    stationary industrial tools

WEEE - Latest status
  • WEEE registration authorities have been setup in
    most Countries.
  • New WEEE legislation in the works due to
    difficulty implementing programs and since 3
    countries still have not adopted any laws
    regarding WEEE.
  • Compliance schemes available companies that
    will handle all the registrations and reporting
    for you.

FAQ on RoHS and WEEE
  • Q What is the difference between exemption and
  • A The WEEE has no exemptions only exclusions.
    This means that certain types of equipment are
    out of the scope of WEEE entirely. The RoHS takes
    its scope from the WEEE except for Categories 8
    9. These are "excluded" from the scope of RoHS.
    So if your equipment is covered by WEEE, it is
    covered by RoHS, unless it is a medical device or
    a monitoring and control instrument. The
    "exemptions" are a series of applications of
    banned substances that are exempted from some of
    the RoHS requirements. The legislation allows the
    EU to add or remove exemptions based on
    technological progress.

FAQ on RoHS and WEEE
  • Q What are my chances of getting a RoHS
  • A A good proportion of industry exemption
    requests get thrown out.
  • - Understand the two criteria that the EU is
    allowed to take into account Technical
    feasibility (Substitution is not possible, or is
    possible under such conditions as to be
    unfeasible in practice) and Environmental impact
    (The negative environmental impact of not
    allowing the exemption would outweigh the
    positive environmental impact of the ban. This
    might be because of increased waste resulting
    from predictably higher failures, or because the
    substitutes are as toxic as the banned
    substances, etc).
  • - Cost or cost/benefit is not a vaild argument.
    The EU legislation does not permit cost to be
    taken into account in making a decision on
    exemptions. This does not mean that you cannot
    refer to the costs indeed many EU regulators
    will be interested. Its just not a valid legal
    reason for exempting.
  • - Need more time is not a valid argument. Unless
    you can relate it to industry-wide problems, EU
    authorities are likely to take a dim view of this
    line of argument, since the legislation was being
    discussed as long as ten years ago and was
    adopted in 2002.
  • - Supply chain would need to be changed is not a
    valid argument. This is ground-breaking EU
    environmental legislation that aims to change the
    world. They are very proud of that, and expect it
    to cause pain.
  • - Refer to existing exemptions that follow
    similar logic or have similar characteristics.

FAQ on RoHS and WEEE
  • Q Can my distributors continue to sell non-RoHS
    compliant products I shipped to Europe before
    July 1, 2006?
  • A Technically yes. If they are on the European
    market prior to July 1 they can be freely sold in
    Europe. However, many member states will not
    allow the products into their states if not RoHS
    compliant (from one member state to another).
    Some distributors are refusing to sell non-RoHS
    products even if they were there prior to July 1.

FAQ on RoHS and WEEE
  • Q I sell systems not discrete products Am I
    affected by WEEE?
  • A Yes. WEEE applies to any product in the ten
    categories. It makes little distinction between
    products put on a retail shelf and products
    custom made for an end customer. Many systems
    fall under the IT category.

FAQ on RoHS and WEEE
  • Q Do I have to register for WEEE if I have no
    legal presence in Europe?
  • A Your legal obligations are not defined by
    reference to whether you have a legal presence in
    the EU or in any particular EU country, but by
    whether you are the producer of equipment put
    on the EU market. However in practice, in many EU
    countries the WEEE registration systems are new
    and have not been set up in such a way as to
    allow foreign companies to register. There are
    some notable exceptions, including Germany and

FAQ on RoHS and WEEE
  • Q What if I sell via distributors or direct to
    businesses or direct to consumers?
  • A Generally the manufacturer is the producer
    and must register. In countries where US
    businesses are not allowed to register, then the
    distributor can register. If you sell direct to
    business customers, they can register for you.
  • The WEEE applies to products put on the market in
    Europe. If you sell directly to consumers via a
    US website or mail order the directive most
    likely does not apply.

FAQ on RoHS and WEEE
  • Q How do I register for WEEE?
  • A Use a compliance scheme company or contact
    the registration authorities in each country.
    Contact info can be found at http//www.buyusa.go
  • Q My product is bolted down in use, is it a
    fixed installation?
  • A No. The intention for the fixed installation
    exclusion is that the product becomes part of the
    building and likely to be left in place. Lights,
    electric doors, gates are fixed installations.
    Kitchen appliances, large fixed equipment, cctv
    camera systems are not.
  • Q Are servers and network infrastructure exempt
    from RoHS?
  • A No. The exemptions for servers and network
    equipment are only for lead in the solder, the
    rest of the product still must comply with RoHS.

FAQ on RoHS and WEEE
  • Q Are RFID chips and tags required to meet
  • RoHS.
  • A Yes. These are considered products in
  • Q Can I import for my own company use.
  • A No. That is still placing on the market.
  • Q Should the wheelie bin symbol be placed on a
  • A No. PCBs are considered components and
    there is no legal requirement to label

FAQ on RoHS and WEEE
  • Q Are cables included in the RoHS scope.
  • A Yes. The present view is that cables both
    included with equipment and sold separately fall
    with RoHS.
  • Q Does packaging need to comply with RoHS?
  • A Packaging discarded is not. Packaging or
    cases that may remain with the product and may be
    disposed of with the product may have to comply.
  • Q Are GPS units required to meet RoHS?
  • A They would most likely be considered part of
    a radio network system under the IT category and
    therefore must comply.

FAQ on RoHS and WEEE
  • Q I manufacture a device that is built into
    equipment and has someone elses logo, who is
    responsible for the recycling?
  • A The brand owner.
  • Q Who takes the producer liability when a piece
    of equipment is refurbished?
  • A It is refurbished but otherwise unchanged,
    the original producer remains responsible for
    recycling at the end of life.
  • Q Are the different RoHS type legislations
    (Europe, China, Korea, California, etc) all the
  • A The limitation requirements are similar. The
    main differences are in product categories,
    reporting and proof of compliance.

FAQ on RoHS and WEEE
  • Q What about spare parts?
  • A You can place spare parts that dont comply
    with RoHS on the market if they are for equipment
    placed on the market prior to July 1, 2006.
    Spare parts for equipment placed on the market
    after July 1, 2006 must comply.
  • Q What is the difference between lead-free and
    RoHS compliant? A. While lead (Pb) is the most
    widely used toxic substance in electrical and
    electronic equipment (EEE), the term "lead-free"
    is often wrongly adopted to refer to all of the
    substances specified in the RoHS Directive.
    However, RoHS restricts a total of six
    substances. To be truly compliant with this
    legislation, the presence of each of these
    substances must be reduced below their proposed
    maximum concentration values (MCV).

Washington Laboratories, Ltd.
  • ROHS\WEEE Compliance Assessment Program (R\W CAP)
  • Performed on-site at your facility
  • Includes
  • Orientation training for RoHS and WEEE Directives
  • Assisting you in determining the applicability of
  • the RoHS/WEEE requirements
  • Assisting you in reviewing products for
  • compliance
  • Assisting you in registering with EU member
  • countries for WEEE
  • Assisting you in developing a ROHS compliance

Washington Laboratories, Ltd.
  • Give us a call or send us info about your product
    - were here to help!
  • Berri Remenick, N.C.E.
  • Product Safety Manager
  • Phone 301-473-1255
  • Fax 301-473-1257
  • E-mail
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