Korean Legislation 'Act for Resource Recycling of Electrical and Electronic Equipment and Vehicles' Published (25th April 2007)
The Korean legislation 'Act for Resource Recycling of Electrical and Electronic Equipment and Vehicles' is a mix of the European WEEE, RoHS and ELV directives with a hint of some of the Chinese RoHS features on labelling. A list of substances covered by the act has not yet been published, but they are expected to be in line with the European RoHS.
Feedback on the act has been given till the 13th May, and comes into force on the 1st July 2007. Since the maximum penalties for non-compliance is a year in jail and/or heavy fine it is not a piece of legislation companies can afford to ignore if they sell their products in that country.
As with the China RoHS there are some differences, which again raises the question of whether many companies that have taken the easy route for European RoHS of not getting proper material declarations, only declarations of conformance from their suppliers, will end up spending far more money in the long run trying to satisfy each variation that appears. This legislation requires companies to label their products based on hazardous material content in order to improve recycling efficiency. Details again have yet to be announced, although Korea prefers an international harmonisation of standards. However since these don't yet exist it will be interesting to see what the requirements will be on the 1st July.
Exemptions as with the RoHS and ELV will be allowed, but not yet specified. In this area there are some major differences between the electronics and automotive sectors in the EU. Lead for instance in automotive electronics is allowed, but in its place a threshold of 60 grams per vehicle has been put in place. It is yet to be seen whether these differences will remain in the Korean legislation.
As with the EU producer responsibilty has been extended to end-of-life management and companies will have to join a compliance scheme.
European REACH Regulations Passed (15th January 2007)
The REACH Regulation (EC) No 1907/2006 and Directive 2006/121/EC amending Council Directive 67/548/EEC were published in the Official Journal on 30 December 2006. The regulations come into force across the whole of the EU on the 1st June 2007.
The aims of the proposed new Regulation are to improve the protection of human health and the environment while maintaining the competitiveness and enhancing the innovative capability of the EU chemicals industry. REACH would furthermore give greater responsibility to industry to manage the risks from chemicals and to provide safety information on the substances. This information would be passed down the chain of production.
Many of the REACH requirements start to come into effect from the 1st June 2008 when a 6 months window to pre-register substances comes into effect. The 1st December 2010 is the deadline set for producers and importers to register the following:
- All category 1 and 2 carcinogens, mutagens and reprotoxins produced above 1 tonne
- Substances classed as very toxic to aquatic organisms above 100 tonnes
- All other substances above 1000 tonnes.
Substances not registered by the dealine can not be sold in the EU.
One of the requirements of REACH is to ensure that not only manufacturers and importers but
also their customers, i.e. downstream users and distributors, have the information they need to use chemicals safely. Information relating to health, safety and environmental properties, risks and risk management measures is required to be passed both down and up the supply chain. The primary tool for information transfer is the 'Safety Data Sheet (SDS)
For substances of very high concern, an authorisation is required for their use and their placing on
the market. Substances that fall into this category will be fed into the authorisation system as resources allow. Their uses will not be banned by default. The REACH agency will publish a list of substances meeting the criteria above and reflecting its multiannual work plan, taking into consideration comments from interested parties.
UK WEEE Directive Finally Becomes Law (New 15 January 2007)
The UK Regulations (SI 2006 No. 3289) implementing the WEEE Directive were laid before Parliament on 12 December 2006 and enter into force on 2 January 2007. The UK was the last EU country to transpose the European Waste Electrical and Electronic Equipment (WEEE) directive. A guidance document has yet to be published. There are no real surprises in the regulations. There are no incentives within the legislation to design for end-of-life, other than the loose statement:
'It shall be the duty of the Secretary of State to encourage the design and production of EEE that takes into account and facilitates dismantling and recovery, in particular the reuse and recycling of WEEE, their components and materials.'
On reporting of materials content for end-of-life treatment it follows the EU diective and the regulations states:
'(1) A producer shall provide information on reuse and environmentally sound treatment
for each new type of EEE put on the market by that producer within one year of such equipment
being put on the market.
(2) The information mentioned in paragraph (1) shall identify so far as it may be reasonably
required by any person carrying out treatment activities—
(a) the different components and materials of the EEE; and
(b) the location of any dangerous substances and preparations in the EEE.'
The annual costs are:
- £12,174 for each compliance scheme
- £30 for a scheme member below the VAT threshold
- £220 for a scheme member with turnover at £1 million or less
- £445 for a scheme member with a turnover greater than £1 million
The maximum penalty is a fine for any breach of the WEEE regulations.
New EU Batteries and Accumulators Directive (New 24 October 2006)
On the 6th September 2006, directive 2006/66/EC was published in the EU official journal. It repeals 91/157/EEC and restricts the use of mercury, cadmium and lead. It also covers the end-of-life and sets targets for collection and recycling.
Under the legislation products can not be put on the market containing more than 0.0005% by weight of mercury, with the exception of button cells where the maximum threshold is 2% by weight. For cadmium the maximum threshold is 0.002% by weight for portable batteries/accumulators, with the exception of emergency and alarm systems, medical equipment and power tools. All batteries require the crossed out wheeled bin label and in addition the chemical symbols for mercury, cadmium and lead have to be added if the mercury content is greater than 0.0005%, cadmium content is greater than 0.002% and lead content is greater than 0.004%.
For end-of-life products must be designed for easy removal of batteries and the following recycling targets have to be met by 26th December 2010.
- 65% by weight for lead-acid batteries
- 75% by weight for nickel-cadmium batteries
- 50% by weight for other batteries/accumulators.
Minimum collection rate of 25% by 26th September 2006 and 45% by 26th September 2016 have been set.
New Labelling Requirement for Electronics in Japan (August 2006)
A new regulation requires companies to supply information on chemical substances. The requirements are in standard JIS C 0950:2005, known as J-Moss (Japanese Industrial Standard for Marking the presence of the Specific Chemical Substances for electrical and electronic equipment) It came into effect on the 1st July 2006. It is designed to encourage companies to phase out the substances restricted under the EU RoHS. It requires manufacturers that put electronics on the Japanese market to attach a label if it contains lead, mercury, hexavalent chrome, PBB, and PBDE over 0.1% and cadmium over 0.01%
|The label indicates the specific substance has to be handled within the supply chain for poper recycling|
The label has to be put on the equipment and the packaging. Also the label mark and substance symbols have to be put in catelogs etc. Finally information on the specific substances has to be put on a website.
The main impact will be that because there are no exemptions manufacturers will need to know where these substances are used, and a simple declaration of conformity to RoHS wont be suffiicient anymore.
Products impacted are PCs, televisions, washing machines, air conditiopning units,and refrigerators,
Chinese RoHS and WEEE (Updated 25th April 2007)
China passed its version of the RoHS directive on the 31st December 2005 which is entitled 'Administrative Measures on the Control of Pollution Caused by Electronic Information Products' It came into force on the 1st March 2007 with all parts that are within the scope having to be labelled on the product and packaging.
The Chinese RoHS applies to products sold in China and does not impact goods exported from their. The law extends to the complete supply chain. A catalogue will be published soon taking items from the products within the scope of the legislation (See below) and the date these products will have to be compliant will be given in the catalogue. Items will be added to the catalogue annually. Unlike the EU medical devices will not be exempt. The Chinese government initially said there will be no exemptions as in the EU legislation.
The Chinese legislation have added one other complication to the scope in that if a product not covered by the legislation contains part(s) covered by the legislation that in value equal or exceed 60%, the whole product is then covered by the legislation. For levels below 60% only the part(s) are covered by the legislation. It is feared the above will result in many automotive vehicles coming under the legislation.
The banned substances follow the EU RoHS (eg Lead, mercury, cadmium, hexavalent chromium, PBBs and PBDEs) with the same thresholds applied at the homogeneus material level. All products listed ion the catalogue must be tested at certified laboratories for these substances before they can be sold in China. This has created considerable concern partly because of the current lack of certified labs, and secondly to test every product at the homogenous material level is a massive task with a large number of products containing 1000s of homogeneous materials.
The thresholds for hazardous substances is slightly different to the EU. For normal parts it is the same as for the EU, but for parts smaller than 4mm3 in size the thresholds apply to the component rather than the homogeneous material. For platings the threshold is 'Not Intentionally Added' Details on the concentration levels are given in standard SJ/T 11363-2006 'Requirements for Concentration Limits for Certain Hazardous Substances in Electronic Information Products'
In addition to the above manufacturers must list the hazardous and toxic materials in their products if they come under the scope, even if they are not in the catalogue. Those substances are currently are the same as the EU RoHS. The manufacturer must also state what the safe working life is of its product before any of the hazardous/toxic materials start to leech out, and whether the product is recyclable. The standard SJ/T 11364-2006 'Marking for Control of Pollution Caused by Electronic Information Products' has now been published.
Once the safe working life has been reached it is understood manufacturers will have to meet the costs of collection and end-of-life treatment. The details of this should become more clear when Chinese WEEE directive is eventually passed.
Further information can be found on the China Country Profile page along with an English translation of the legislation and links to further information.
Further RoHS Exemptions
The European Commission has agreed lots of exemptions in addition to those in the orignal directive. These are:
The first set of exemptions was approved under Commission Decision 2005/717/EC
These exemptions are:
- DecaBDE in polymeric applications (see note above)
- Lead in lead-bronze bearing shells and bushes
The second exemptions was approved under Commission Decision 2005/747/EC
These exemptions are:
Section 7 amended to:
- Lead in high melting temperature type solders (i.e. lead-based alloys containing 85 % by weight or more lead)
- lead in solders for servers, storage and storage array systems, network infrastructure equipment for switching, signalling, transmission as well as network management for telecommunications,
- lead in electronic ceramic parts (e.g. piezoelectronic devices)
- Cadmium and its compounds in electrical contacts and cadmium plating except for applications banned under Directive 91/338/EEC (*) amending Directive 76/769/EEC (**) relating to restrictions on the marketing and use of certain dangerous substances and preparations.
Lead used in compliant pin connector systems.
Lead as a coating material for the thermal conduction module c-ring.
Lead and cadmium in optical and filter glass.
Lead in solders consisting of more than two elements for the connection between the pins and the package of microprocessors with a lead content of more than 80 % and less than 85 % by weight.
Lead in solders to complete a viable electrical connection between semiconductor die and carrier within integrated circuit Flip Chip packages.’
Further information can be found on the EU Country Profile page along with the text of the legislation and links to further information.
If you have any product environmental news from your part of the world, that you would like to share, please email Graham Adams the seeba co-ordinator with the details.