RoHS and WEEE Regulations
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IN THIS ISSUE |
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WELCOME |
Nowadays we are all keen on displaying our “green” credentials and that includes the EU and the UK government, which is why there are two new sets of Regulations that you need to know about.
They are both aimed at how we dispose of electrical and electronic items when we no longer want them. Simply “dumping” them is not an option. We need to recognise our responsibility to be more accountable in how we produce them, sell them, use them and eventually discard them.
These regulations impact some businesses more than on others, though there are few who are not affected in some way.
| Read the article and then, if you are unsure how they affect you, call in one of our consultants who can assess your circumstances and advise you accordingly. You will find contact details at the end of this newsletter. |
David Skews, (CEO)
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ROHS AND WEEE REGULATIONS |
If you are in the electrical or electronic equipment business – be it manufacturing, importing, distributing, selling or using, then you will be affected by two new sets of Regulations that are designed to safeguard our environment, namely:
- Waste Electrical and Electronic Equipment Regulations (WEEE)
- Restriction of Hazardous Substances Regulations (RoHS)
These regulations are in response to the increasing mountain of defunct equipment; most of which ends up in landfill. As an example, estimates for household waste alone are as high as 93,000,000 items per year, amounting to a staggering 1,000,000 tonnes. The particular concern about this kind of waste is that it contains various substances that can damage the environment and possibly affect human health.
As well as being a waste disposal problem those items are a waste in a different sense, in that they contain materials and substances that could be easily recycled and used for other purposes.
To assess the potential for reducing your waste, ring EDP today for expert advice.
New Regulations
The WEEE Regulations are concerned with collecting, treating, recycling and recovering waste electrical and electronic equipment. This is affected by everything that happens to a piece of equipment, throughout its life. It follows, therefore, that the WEEE Regulations affect everyone from designers, manufacturers, wholesalers and retailers, all the way through to recycling companies.
The RoHS Regulations are a little more restricted in who they affect, being mainly directed at designers, manufacturers and importers. These regulations place restrictions on the use of certain hazardous substances in electrical and electronic equipment.
Looking at these two sets of Regulations in a little more detail:
WEEE Regulations
The WEEE Regulations affect the widest range of people in a variety of ways, for example:
- Designers and manufacturers should take more account of the need to repair and upgrade products during their useful lives, along with efficient recycling when they are thrown away.
- Retailers must provide a free “take-back” service for disposing of equipment that is being replaced.
- Householders are encouraged to separate electrical and electronic equipment from other household rubbish.
So what exactly is covered by the WEEE regulations? Actually it includes all kinds of products:
- Large household appliances - such as cookers and refrigerators
- Small household appliances - such as kettles and toasters
- IT and telecommunications - such as computers and telephones
- Consumer equipment - like televisions and radios
- Tools - such as electric drills and sewing machines
- Automatic machines - such as cash and drinks dispensers
- Monitoring instruments - such as alarms and smoke detectors
- Medical and laboratory equipment
- Even toys and leisure equipment
There are exceptions, though some may not be all that clear.
By way of illustration, components are not included if they are to be part of larger items that are not themselves covered. This might include, for example, automotive components that are built into cars, or other forms of transport.
Another exclusion is where an item uses electrical/electronic components that are not considered essential for the item’s “primary” function. An example of this might be a cuddly toy with synthesized speech. If the speech module fails, the item is still usable for its primary purpose as a cuddly toy.
| A very important aspect of the WEEE Regulations is that they are retrospective. So, you may need to consider products for which you have had some responsibility in the past. |
| If you are uncertain about your responsibilities in this area, a call to EDP could straighten you out. EDP’s consultants are fully conversant with the details of the legislation. |
RoHS Regulations
Both sets of regulations work in tandem with each other. Whilst the WEEE Regulations concentrate on the waste end of a product’s lifecycle, the RoHS Regulations put greater emphasis on what goes into a product when it is designed and manufactured.
There is a lot of similarity in what is covered by the two sets of regulations, the exceptions being that the RoHS Regulations do not cover Medical Equipment or Monitoring Instruments.
Under the RoHS Regulations, the specified hazardous substances are not entirely banned, but there are threshold limits to the amounts that can be used – calculated as a percentage by weight. Currently, these are:
- Cadmium – 0.01%
- Lead – 0.1%
- Mercury – 0.1%
- Hexavalent Chromium – 0.1%
- Polybrominated Biphenyls (PBBs) – 0.1%
- Polybrominated Diphenyl Ethers (PBDEs) – 0.1%
Does this affect you?
If you are in business, you are almost certainly affected. By way of example:
- As a Producer of equipment, you have to register with your Environmental Regulator and then contribute financially to collecting and processing waste products, based on your calculated market share. You must also report on what happens to waste products as well as providing information on new products you are introducing to the UK market.
- As a Supplier of equipment, you have responsibility for collecting, recycling and disposing of waste equipment in an environmentally friendly way. There is a retrospective element to this in that you may be responsible for equipment that you have supplied to business users in the past.
- As a Business User of equipment, you are responsible for its disposal. You will need evidence that it has been collected and treated in accordance with the regulations.
Some of our clients, as part of their tendering process, have been challenged as to how they are implementing RoHS. In fact, more and more organisations are requiring vendors to demonstrate that the goods they are selling have been checked for compliance. Perhaps a letter to your supplier is required to demonstrate what measures are being taken to comply with these new regulations.
Here at EDP we have found it necessary to strengthen our environmental specialists as a result of increased demand from our clients, who are wanting to implement Environmental Systems to ISO14001. Give us a call if you would like to talk this through with someone.
Additional Help & Information
In this newsletter, we can only provide a high-level treatment of this topic.
| However, we have practitioners who can assess the full implications of how these regulations will affect your business. For peace of mind, you need to call us on 08456 44 53 51 or visit our website for alternative contact details |
Meanwhile, the government has provided some excellent easy to read publications on the Envirowise website, they include:
You can download these guides as Adobe Acrobat (pdf) files, though you will first need to register on the site.
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CASE LAW |
You can’t be too meticulous when it comes to taking positive action once you know there is a potential hazard. This warning comes after a football club paid out a little under £100,000 in fines and costs, following a fatal accident in one of its car parks.
The death occurred when a 14 year old boy, who was riding a motorcycle, collided with a chain that was intended to prevent unauthorised use of the car park. The chain, which struck the boy under the chin, didn’t have any high visibility markings on it.
There had been two previous accidents at the same place some months earlier. Reflective sleeves had been fitted to the chain after the first incident, but these had disappeared and the club had failed to take additional precautions after the second incident.
In mitigation, it was pointed out that the club had spent more than £500,000 to improve health and safety since the stadium was opened in 1997. The tragedy in this case was failing to follow through on a relatively small action that just might have avoided the death of a young boy.
You can read the full story as reported in the Bolton Evening News - http://archive.boltoneveningnews.co.uk/2005/9/7/869471.html
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LEGAL MONITOR |
The main change to report this month is the subject of our main article. The Restriction of Hazardous Substances Regulations (RoHS) came into force on the 1st July 2006.
The Waste Electrical and Electronic Equipment Directive has yet to become law in the UK though it is expected soon.
There was a review of the WEEE proposals in December 2005, with a view to maximising the environmental benefits whilst minimising the costs for business. Following the review, a full consultation was scheduled for Spring 2006, after which we expect the government to publish a revised timetable for implementation.
Watch this space!
View more anticipated legal changes. Then decide if they affect you and what changes you need to make by way of preparation.
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David Skews, (CEO)
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EDP Health Safety & Environment Consultants Ltd
Lakeside, Alexandra Park, Prescot Road, St. Helens, Merseyside, UK
Telephone: 08456 44 53 52
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