With electronics equipment made using complex electronic components such as highly integrated semiconductor ICs attained pervasive nature, the use of harmful substances in components is affecting the environment and health of living things on earth. Responsible regions around the world are imposing ban on substances causing hazard to life and to environment. Regulations such as RoHS are well implemented in Europe. Lot more new regulations are in the pipeline in many regions of world.
New environment regulations and the challenges to meet them are adding continuous pressure to the suppliers and manufacturers. The design and manufacturing supply chain has been pushed into a new uncertain territory due to the growing number of regulations coming into effect. The number of regulations and the list of hazardous substances also grow thereby adding more burdens on the company in their designing and redesigning efforts. Scrapped parts, customer complaints and legal issues, downfall in sales and shipments, and business blockages are few risks to face due to non-compliance which could potentially lead to heavy revenue losses. Hence adopting a successful environmental compliance management solution in a company is one of the core competencies required for developing compliant products and a successful environmental friendly venture. The business cost of compliance products is lower than the cost of non-compliance products because of better market share, no legal or regulatory penalties and strategic competitive advantage. Above all, it's about caring the environment by producing environmental friendly products.
The critical tasks in managing environment-compliance are to understand the requirement of applicable regulations, to collect the required information (data) on the hazardous substances used in each material or component and to evaluate the data for non-conformances and risks. Collecting and managing the compliance data thus becomes extremely difficult for the company and extra costs are involved. As mentioned in the introductory module, the required-right-recent-reliable compliance information provides the essential metrics and guidance to the company to demonstrate the product's compliance. Awareness on the ready solutions available in the market and their affordability can also help companies to quickly implement compliance programs company-wide. Company's status at the corporate level can be determined with the help of a common solution implemented company-wide (even with the help of 3rd party ready solutions) irrespective of the number of factory locations and data sources.
Brief history:
The presence of innumerable substances and materials in variety of electrical and electronic equipments in one or the other form is quite evident. In the studies conducted over years, it was identified that there were so many toxic and hazardous substances present in the products. Adding to the presence of the toxic substances, there were no recycling plans, efforts and methods to dispose these products that has created severe threats and damages to humans, bio-life and environment. Harmful effects to humans include nervous system failures, fall in children's IQ level, brain and kidney damages, anaemia, lead poisoning, etc.,
Since more than a decade, regulations such as the European Union's RoHS Directive 2002/95/EC, the China's Administrative Measure on the Control of Pollution Caused by Electronic Information Products, the Korea's Act for Resource Recycling of Electrical and Electronic Equipment and Vehicles, the State of California's Electronic Waste Recycling Act of 2003, etc., have been working on legislations in bits and pieces. To create a hazard-free environment and to save the next-generation, these directives guide the producers and consumers to effectively and efficiently produce and use environmental products respectively.
Directive on Batteries and Accumulators - The battery directive comes in to effect from 18th March 1991 that targets batteries and accumulators containing certain dangerous substances. The directive requires batteries to be removed from separately collected WEEE (Waste Electrical and Electronic Equipment) and the current disposition within European Union may introduce new requirements. The directive with 26th September 2008 as the effective date of compliance seeks to improve the environmental performance of batteries and accumulators and all activities of producers, distributors, end-users, etc., who are involved in the entire life cycle. All the products containing rechargeable and non rechargeable batteries are covered under this regulation irrespective of the type, shape, volume, weight, material composition or use of the batteries and accumulators. Harmonizing heavy metal content and labelling through the EU and promoting high level of recycling and collection is also required.
Packaging Directive - The scope of the EU Packaging directive includes all packaging and packaging waste placed in the EU market, whether it is used or disposed of in an industrial, office, commercial, service, household, shop or any other setting, regardless of the material used. The directive lays down measures aimed at preventing the production of packaging waste by reusing or recycling it thereby promoting the usage of non toxic and bio-degradable packaging materials. The effective date of packaging compliance was effect from 30th June 1996. The producers are required to take all necessary measures to minimize the environmental impact without compromising the essential functions of packaging and are required to provide the competent authorities with reliable data on the type and amount of packaging materials used; including the toxicity information or danger of packaging materials and components used for their manufacture.
ELV - The directive on End-of-Life Vehicles poses general ban on lead with effect from 1st July 2003 as well as ban on mercury, cadmium, and hexavalent chromium. The directive offers electronic solder as an exemption and can use Pb; Non-electronic solder is not exempted and cannot use Pb; Component coatings are not exempted unless they become part of the solder joint during processing, etc.,
Directive on BDEs - The prohibition of marketing and usage of dangerous penta-BDE and oct-BDE (bromodiphenyl) in a substance or article of levels above 0.1 wt% is the prime requirement of this directive formed on 6th February 2003. These two BDEs should no longer be used in plastic housings.
WEEE - The main objective of this directive Waste Electrical and Electronic Equipment is to prevent and reuse, recycle and recover WEEE to reduce the disposal of waste and to improve the environmental performance of all operators involved in life cycle of electrical and electronic equipment. The directive places minimum recycling requirements and additional stringent guidelines can be imposed by the EU member states. The member states' requirements may be tougher and with a different financing basis. The document and subsequent revisions state that producers must register their products by 13th August 2005 and plan for recycling for compliance with recycling laws with individual member states. Producers will be responsible for taking back and recycling their products.
WEEE is applicable for the following product categories:
1. Large household appliances
2. Small household appliances
3. IT and Telecommunication equipment
4. Consumer equipment
5. Lighting equipment- Light bulbs and luminaries
6. Electrical and electronic tools (with the exception of large scale stationary industrial tools)
7. Toys, leisure & sports
8. Medical equipment systems (with the exception of all implanted and infected products)
9. Monitoring and control instruments
10. Automatic dispensers
RoHS (Restriction on the use of certain Hazardous Substances)-has come in to effect to assist the recycling efforts set forth by WEEE. The new electrical and electronic equipment put on the market from 1st July 2006 must not contain restricted substances. The directive restricts the usage of hazardous substances which have adverse effects on human health and the environment. The maximum allowable concentration values in weight percent per homogeneous material is given below.
1. 0.1% for Lead, Mercury and Hexavalent Chromium
2. 0.01% for Cadmium
3. 0.1% for PBB and PBDE flame retardants
There are exemptions permitted by the directive and these exemptions are reviewed at least every 4 years.
China RoHS - China RoHS applies to the products manufactured after 1st March 2007 and the regulation is intended to prevent accumulation of toxic substances to health elements and substances in the environment. China RoHS is similar to EU RoHS but with few major differences. The China RoHS covers the same six restricted substances as of the EU RoHS. The additional requirements are classified in to 2 phases, Information Disclosure and Material Restrictions. The 1st phase includes labelling (green and orange) and packaging recycling remarks. The 2nd phase includes Electronic Information Products (EIP) listed in the "living" catalog must comply with the hazardous substances ban and are subjected to China's Compulsory Certification (CCC) and labelling requirements. Additionally, requires testing using government approved Chinese labs.
EuP - The Energy using Products directive requires producers to design products to meet specific eco-design criteria over entire life cycle effective 11th August 2007 for certain specific products. The directive regulates the products that have sales of over 200,000 units per year in the EU, have a significant environment impact over their entire life cycle, and present significant potential for improvement. Also, the implementing measures must not have a "significant negative impact" on product's price or performance or on the competitiveness of EU industry.
Korea RoHS - The South Korea's RoHS/WEEE legislation was effected from 1st July 2007 and is termed as "the Act for Resource Recycling of Electrical/Electronic Products and Automobiles".
Norwegian PoHS - Norway has proposed to restrict 18 substances in anything intended for consumers or products that can reasonably be expected to be used by them. The products include clothing, bags, toys, food packaging, medical equipments, fertilizers, tobacco, means of transport, and does not apply to food products. The legislation "PoHS" refers to "Prohibition on certain Hazardous Substances" in consumer products.
REACH - The European REACH regulation (Registration, Evaluation, and Authorisation of Chemicals came in to effect on 1st June 2007 and is applicable to manufacturers, importers and users of chemical substances on their own or contained in preparations, or in products. REACH requires compulsory registration of all chemicals sold, imported, manufactured, or used in articles that are manufactured or imported into the EU. REACH replaces about 40 existing legislations by improving the knowledge on the risks posed by chemicals, with the aim of using them in a safe way. In addition, the regulation authorises the use of or set restrictions on the manufacture, placing on the EU market and use of toxic substances, preparations and articles.
The scope of the regulation is broad and applies to substances (elements and compounds) on their own, in preparations (mixtures), or in articles (products). Waste and radioactive substances are exempt while REACH's provisions do not apply to substances addressed in other legislations (including food, medicine, and medical products for humans, animals and cosmetics), or listed substances with known risks (water, CO2) or found in nature (minerals, coal).
DfE - Design for Environment offers a structure to define, configure, measure and reduce the environmental impact of the products and product packaging. Key measurements covered by the DfE are Energy use, greenhouse gases, raw material input, bad actor chemicals, recyclability and carbon footprint.
RoHS Recast - There have been changes to the exemptions listed in the RoHS directive and in 2010, the European Union had agreed to a range of these changes to the directive. The new version known as "Recast" will take effect during the following seven years. All exemptions are temporary and they will be reviewed at least every four years. The exemptions of the recast RoHS directive will expire on 21 July 2016 unless an earlier date is mentioned against each of the exemption. RoHS will become a CE marking directive applying to the finished goods where manufacturers, importers and distributors are responsible for some or all of the compliance activities. So, compliance information maintenance (record keeping) is very much essential as most of the obligations are to produce documentation that can be assessed by the enforcement bodies.
India WEEE and India RoHS - The "e-waste (Management and Handling) Rules 2011" has been published which comes into effect from 1st May 2012. The regulation is considerably similar to EU WEEE and RoHS in terms of scope, exclusions, etc. and is a joint legislation (not separate for WEEE and RoHS). The regulation does not apply to micro and small enterprises. Batteries and radio-active waste are out of scope.
India WEEE defines the responsibilities of the various entities, producers, consumers, collection centres, dismantlers and recyclers with the procedures for obtaining registration and authorisation from the pollution control entities including sample forms. The storage of e-waste is permitted only for a period of 180 days and the labelling is similar to that used in the EU, except the black bar under the crossed out wheelie bin is not required.
India RoHS restricts the same six substances including their maximum concentrations as that of the EU RoHS but the scope of products is different. The RoHS requirements enter in to force from May 2014.
The equipment manufacturers or the producers need to declare their products that they are compliant with the applicable regulations. Declarations of compliance for materials, components and other parts are obtained from the original suppliers by the producers and they should be maintained for a minimum of 4 years. The declarations, in the past, were in the form of lab test reports/certificates, CoCs (certificate of compliance), IPC-1752 declarations, custom reports (includes JIG data), etc., Of late, newer regulations coming to picture, the suppliers are preferring and declaring full material disclosures in industry-standard format (say, IPC-1752) so that the costs and efforts of re-testing and re-qualifying for the changing regulations can be minimized. The material composition information can help manufacturers to satisfy legal and regulatory requirements, improve product designs, and respond to inquiries from customers and stakeholders.
Sustainable Manufacturing - Sustainable manufacturing approach promotes the concept of "reduce, reuse and recycle" to preserve the environment and the natural resources. There is a need for the companies to adopt clean and lean practices in developing green products that serves the present need as well as the future generation does not have any adverse effects by these products. The smarter approach in managing environmental compliance is by avoiding the usage of hazardous substances or usage within the allowable limits; recycling the e-waste under controlled environment; reusing the applicable scrap materials after proper treatment; disposing the harmful substances and materials as per the regulations; finally using the green materials and products alone in the entire supply chain. The future point where all the environmental regulations directed are "the manufacturing for sustainability and the sustainable manufacturing".
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