Introduction What are RoHS and WEEE All About?
The full names of these important EU Directives are:
RoHS: Directive 2002/95/EC of the European Parliament and of the Council of 27 January 2003 on the Restriction of the use of certain Hazardous Substances in electrical and electronic equipment This Directive restricts the use of hazardous substances (lead, mercury, cadmium, hexavalent chromium, PBB and PBDE) in electrical and electronic equipment at the design and manufacturing stage. The RoHS Directive means that products containing restricted substances will have to be redesigned or withdrawn by July 2006.
| WEEE: Directive 2002/96/EC of the European Parliament and of the Council of 27 January 2003 on Waste Electrical and Electronic Equipment This Directive covers the treatment and recycling of WEEE. It is designed to encourage the reuse and recycling of WEEE and to reduce the amount of WEEE being discarded. The WEEE Directive will require producers to pay for at least the collection of their products at end-of-life from central points, and meet targets for re-use, recycling and recovery. Waste electrical and electronic equipment is the fastest growing municipal waste source in Europe. The two Directives initially started out as a single combined Directive aimed at reducing the environmental impact of WEEE. It was then realized that there was a need to address both the start and the finish of the product life cycle to adequately deal with the concern. This is best illustrated using the waste hierarchy shown at right. |  |
Reducing the environmental impact of a product begins at the design and manufacture stage where eliminating or reducing the use of hazardous substances is most effective if hazardous substances are removed at source and are not present, then there is no need to specially treat the waste. RoHS deals with the elimination and reduction aspects of the waste hierarchy.
If hazardous substances have been used, then it is best to reuse or recycle the waste to reduce the environmental impact. Only when these have been fully carried out is it acceptable to properly dispose of the waste. WEEE deals with the reuse, recycling and disposal aspects of the waste hierarchy.
Much of the effort and publicity surrounding RoHS and WEEE to date has concentrated on the heavy metals present in circuitry and the issues facing the electronics industry, but if the product is not exempt, then the Directives cover all the materials in WEEE including any plastic materials. Some of the substances included in the RoHS list were, or are, used extensively in plastics (e.g. lead-based stabilizers were once the predominant method of stabilization in PVC, cadmium based colorants have been extensively used in producing red pigments for many types of plastics, and PBB and PBDE are used as flame-retardants). Plastics producers cannot ignore RoHS and WEEE and think that these will go away, particularly since the high volumes of plastics used in many WEEE products means that the plastics must also be recycled to comply with the Directive.
Definitions and Scope
RoHS and WEEE share many common definitions and these are important in deciding if the Directives cover suppliers and products. The relevant definitions are:
1. Electrical and electronic equipment means equipment which is dependent on electric currents or electromagnetic fields in order to work properly, equipment for the generation, transfer and measurement of such currents and fields and equipment designed for use with a voltage rating not exceeding 1000 volts for alternating current and 1500 volts for direct current.
2. Producer means any person who, regardless of the selling technique used:
(i) Manufactures and sells own brand electrical and electronic equipment.
(ii) Resells equipment produced by other suppliers under his own brand.
(iii) Imports or exports electrical and electronic equipment into a Member State.
3. Distributor means any person who provides electrical or electronic equipment on a commercial basis to the party who is going to use it.
4. The product areas covered by RoHS and WEEE are largely the same and are listed in the table below:
Table scrolls horizontally
| Product Category | RoHS | WEEE |
| Large household appliances | YES | YES |
| Small household appliances | YES | YES |
| IT and telecommunications equipment | YES | YES |
| Consumer equipment | YES | YES |
| Lighting equipment | YES | YES |
| Electrical and electronic tools (except for large-scale stationary industrial tools) | YES | YES |
| Toys, leisure and sports equipment | YES | YES |
| Medical devices (with the exception of all implanted and infected products) | NO | YES |
| Monitoring and control instruments | NO | YES |
| Automatic dispensers | YES | YES |
| Electric light bulbs | YES | NO |
| Luminaires in households | YES | NO |
This list should be considered as provisional only, see section The exemptions (below). For further details of example products included in each product category see Annex II of the WEEE Directive.
RoHS in Detail
The affected substances
To comply with RoHS, beginning in July 2006 manufacturers will need to demonstrate that their products do not contain more than the maximum permitted levels of:
1. Lead (Pb)
2. Mercury (Hg)
3. Cadmium (Cd)
4. Hexavalent Chromium (Cr VI)
5. Polybrominated Biphenyls (PBB)
6. Polybrominated Diphenyl Ethers (PBDE)
The maximum permitted levels are proposed to be 0.01% by weight for cadmium in any individual homogeneous material and 0.1% for the other substances. Initially there was some debate as to what a homogeneous material was and whether this referred to a component or assembly. This has now been clarified and a homogeneous material is now known to be a single substance such as a plastic, e.g. the plastic used in the insulation of a wire is considered to be a single substance. The assembly of wire + insulation is not considered to be a single substance but a component. A component may contain several different materials that must all be considered separately.
The Exemptions
There are some significant product and application exemptions listed in the RoHS Directive, but these mainly relate to the use of materials in non-plastic applications and are not considered in this Newsletter. A full list of the current exemptions is given in the Annex to the RoHS Directive.
Further product and application exemptions have been applied for, e.g. for light bulbs, and are currently being considered by the EU. It is unlikely that all the exemptions applied for will be granted, but most of them do not affect the application of plastics in WEEE.
Where are the Affected Substances Likely to be Used in Plastics?
In most cases the affected materials have already been phased out for plastics processing due to rising environmental pressures. Examples of previous uses are:
Lead Lead based stabilizers have been used in PVC for a variety of uses in the past but this has largely been superseded by the use of other stabilizer systems, e.g. Ba/Ca/Sn systems.
Cadmium Cadmium has been used as a red colorant in many plastics in the past but has been replaced by alternative colorant systems.
Hexavalent Chromium This is used in metallizing of plastics and is being phased out rapidly by alternative processes that are less environmentally damaging.
PBB and PBDE These have been used as flame retardants in a range of plastics but substitution with other flame retardants has already largely taken place.
Despite the progress, users of plastics in products that are covered by the RoHS or WEEE Directives are still advised to seek confirmation from plastics raw materials suppliers that the affected substances are either not used or are used in less than the maximum permitted levels.
Proving Compliance and Policing
