Comedian George Carlin seems to have unwittingly captured the attitude of much of the electronics industry in the daily musings of his 2005 calendar. On August 12, he looked at the American Businessman's 10 Steps to Product Development. Question 5, "Will it harm the environment?" was halfway between "Can I cut corners in design?" and "Will it force smaller competitors out of business?"
Could Carlin have heard about the European Union's (EU's) Restrictions on Hazardous Substances (RoHS) and Waste Electrical and Electronic Equipment (WEEE) directives? If so, how would he respond? Hopefully, he would respond better than many industry companies that, even at this late date, may not meet the deadline for compliance with either RoHS or WEEE.
Only 54.9% of Electronic Design readers responding to the online survey said they are "very confident" or "confident" that their companies will fully comply with RoHS by the July 1, 2006 deadline. Barely more than half (51.7%) indicated they were "very confident" or "confident" their original design manufacturer (ODM) or electronic manufacturing service (EMS) company would fully comply with RoHS by the directive's deadline.
Some respondents took a dim view of the entire process. "This is just an attempt by people to close markets to foreign competition and sell new expensive products to manufacturers," says Paul Dickerson, technical process engineer at Matric, a contract manufacturer and designer. Dickerson also suggests that lead-free products will require more energy to process. "Is this not going to be bad for the environment?" he asks.
David Figueroa, a senior systems engineer with Constellation Technology Corp., says his company's products will suffer due to the lack of fundamental component availability, such as junction FET devices used in video amplifiers and high-impedance amplifier front ends. "The choices are becoming limited," he says. "Most of our products require special handling to address hazardous materials used in their manufacture."
Staff development engineer Wyn Robertson of Coherent Inc., maker of lasers and laser-measurement tools, says his biggest concern about meeting RoHS requirements is "getting it all done in time." He also worries about ending up with obsolete products when the RoHS deadline kicks in next year. "Some products were teetering on the brink anyway," he says. "RoHS will push them over the edge."
RoHS has received most of the industry's attention. Yet some industry executives and engineers believe another EU directive may be even more daunting.
Blowing the deadline
The Waste Electrical and Electronic Equipment (WEEE) directive requires electronics manufacturers and "producers" to provide takeback programs for the collection, treatment, recovery, and recycling of end products sold in EU member states, as well as Norway and Switzerland. In its simplest terms, WEEE rules include any electronic product with a battery and an electric cord.
Under WEEE, a company that sells equipment using its own brand name on equipment made by another manufacturer is defined as a producer. Collection can be from municipal waste sites or local collection sites, but not from consumers.
WEEE also lets producers comply either individually or collectively by joining what the EU calls a "compliance solution organization." These membership-based groups would be equipped to comply with the directive. Professional recyclers are likely to collect the majority of WEEE-related products from local authority waste sites.
WEEE became "law" on August 13. But with the exception of most major OEMs, only a small percentage of industry companies seems to have taken WEEE seriously enough to make the deadline, which they must do because they can register with any EU member country.
"Many manufacturers are unaware, poorly informed, or confused about the requirements and implications regarding preparation for WEEE compliance," says Leonie Tipton, vice president of Global Supply Chain Programs at Arrow Electronics.
"The August 13 deadline is not really a date of compliance, but simply a date at which producers must register within each EU member state they sell into," says Paul Chinery, managing director of Dionics Plc, a U.K.-based distributor. Moreover, he says, some countries (Austria, Finland, Germany, and others) do not require registration unless the producer has a registered address or legal entity in that country. In these situations, either the distributor or agent in that country inherits producer responsibility if one exists, or the end user (for direct sales) is responsible for disposal or recycling.
"I have heard nothing of penalties being issued for non-registration," said Chinery. "One must assume that due to the complexity and diverse implementation of the legislation, governments are offering a degree of flexibility. Obviously the directive must also accommodate newcomers to the market selling products into a member state."
To help smooth the way, especially with the looming deadline, Arrow Electronics produced a guide to WEEE, with expected implementation dates, regulatory body details, and compliance status on a country-by-country basis (www.arrow.com/green). Arrow produced the material with ERA Technology, a U.K.-based technology consultant. Further complicating WEEE compliance, several EU member countries have yet to formulate their own WEEE legislation, as required by the EU. (China, although obviously not an EU member, stated through its State Environmental Protection Administration that it would meet the August 13 deadline.)
The U.K. says it won't be ready to register WEEE-compliant companies until next June. The U.K.'s Department of Trade and Industry (DTI) extended the date for collecting and recycling electronic waste in the U.K. to June 2006. This allows more time to establish a working network of facilities for separate collection of e-waste for homeowners.
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