The EU directives RoHS and WEEE

From 01/07/2006, the implementation of the RoHS and WEEE directives will result in considerable changes in the electronics production world. Here you will find information designed to simplify the first steps toward "lead-free production".

What is behind WEEE and RoHS?

WEEE (EU directive 2002/96/EC):

The Waste from Electrical and Electronic Equipment is a directive that governs the recovery and recycling of waste electrical and electronic devices => E scrap recycling directive

RoHS (EU directive 2002/95/EC):

The Restriction of the use of certain Hazardous Substances is a directive for the restriction of the use of certain hazardous substances in electrical and electronic devices. These directives lay down actual bans or limit values for particular substances that endanger people and the environment => banned substances directive

Both directives have been binding EU law since 13 February 2003 and must be transposed into national law by the member states.

Important paragraphs and exceptions:

Article 4 / Prevention

Member States shall ensure that, from 1 July 2006, new electrical and electronic equipment put on the market does not contain lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB) or polybrominated diphenyl ethers (PBDE). Since the current state of the art will make it impossible to achieve 100% freedom of hazardous substances in certain fields, and because safety systems cannot be allowed to fail, exemptions are still allowed at present.

Exemptions

• Lead in glass of cathode ray tubes, electronic components and fluorescent tubes
• Lead as an alloying element in steel containing up to 0.35% lead by weight, aluminum containing up to 0.4% lead by weight and as a copper alloy containing up to 4% lead by weight. Lead in high melting temperature type solders (i.e. tin-lead solder alloys containing more than 85% lead)
• lead in solders for servers, storage and storage array systems (exemption granted until 2010)
• Lead in solders for network infrastructure equipment in the field of telecommunication
• Lead in electronic ceramic parts (e.g. piezo electronic devices)

The aim of these exemptions is not to protect the existence of any particular technology or sector, but to cut the risks involved in any changeover where tried and tested processes are replaced by technologies that have not been in use for so long. Article 5 is particularly important in this respect.

Article 5 / Adaptation to scientific and technical progress

1a) Establishing, as necessary, maximum concentration values up to which the presence of the substances referred to in Article 4(1) in specific materials and components of electrical and electronic equipment shall be tolerated.

1b) Exempting materials and components of electrical and electronic equipment from Article 4(1) if their substitution is:

• Technically or scientifically impracticable
• Harmful to the environment or health
• Or endangers the safety of the users.

1c) Carrying out a review of each exemption in the Annex at least every four years.

Transposing the directive into national law is the responsibility of the individual EU member states. The date stipulated in the RoHS (01/07/2006) is binding for all states concerned. Member states are responsible for the final text, national laws, regulations and administrative provisions, but the following regulations and definitions must always be included.

Producer as defined by the act:

A producer as defined by the act means any person who, on a professional basis and irrespective of the selling technique used:

• Manufactures electrical and electronic equipment under his own brand and puts it on the market for the first time within the territory governed by the act.
• Resells under his own brand equipment produced by other suppliers in the territory governed by the act (a reseller not being regarded as the "producer" if the brand of the producer appears on the equipment, as provided for in subpoint (1)); or
• Imports electrical and electronic equipment for the first time to the territory governed by the act and puts it on the market or exports it to another member state of the European Union and immediately passes it on to an end user.

Since it will also be technically impossible in the above-mentioned product groups to achieve 100% freedom of hazardous substances, maximum levels of clearly defined units still permitted are currently under discussion:

Limit values and homogenous materials:
The TAC (= Technical Adaption Committee) of the EU commission is currently discussing the following limits and the term Homogenous Material:

Limits:

• 0.1 percent lead, mercury, hexavalent chromium, polybromide biphenyl (PBB), polybromide diphenyl ether (PBDE) by weight
• 0.01 percent cadmium by weight

Homogenous material:
The term "Homogenous material" is understood as of "Uniform Composition Throughout".

Behind "mechanically disjointed" is the suggestion that the materials can in principle be separated by mechanical actions such as cutting, crushing, unscrewing, coarse grinding or abrasive processes.

At the same time, some EU member states are calling for a manual covering limit values and their relation to the product or parts of a product.

Examples for "homogenous material" in acc. with the TAC draft

A plastic housing is a "homogenous material" if it is composed of one (single) type of plastic that has no other coating and if it contains no other materials inside or (added) outside. In this case, the Pb limit of 0.1% in the RoHS would apply to the housing.

An electrical cable containing wires enveloped in plastic is an example for a "non homogenous material", since both materials can be separated mechanically. The limit values in the RoHS would apply for each component in this case.

A semiconductor component contains a wide variety of homogenous materials such as plastic for the housing, tin electroplating on the lead frame, the lead frame alloy and gold bond wires.

The ElektroG
, Germany, is the transposition into national law in the form of the electrical and electronic equipment act, referred to as ElektroG. The ElektroG combines the contents of the WEEE and the RoHS and goes on to describe the process of putting the product on the market, recovery at the end of its lifecycle, and disposing of electrical and electronic equipment in an environmentally friendly manner. The act has been in force since March 2005 and must now be implemented in corresponding organizational and functional structures.

Information on ElektroG can be found on the Internet site of the Federal Ministry for Environment, Nature Conservation and Nuclear Safety:

Further information and services related to this article

• Product and process modifications in line with RoHS and WEEE
• Product identification and return