RoHS, WEEE, the EU and You and Me.
On 1 July, 2006, the European Union adopted a directive (law) that has far-reaching consequences to manufacturers and consumers alike. That directive (2002/95/EC) restricts the use of certain hazardous substances in electrical and electronic equipment. This directive has become known as the RoHS (Rules of Hazardous Substances) Directive.

This directive is actually the result of another directive put into place in 2003 which directs manufacturers (producers) to finance the reuse and recycling of these products, known as Waste Electrical Electrical and Electronic Equipment or WEEE. Furthermore, the WEEE directive (2002/96/EC), compels member countries of the EU to write and implement legislation supporting its provisions.

"The purpose of this directive is, as a first priority, the prevention of Waste Electrical and Electronic Equipment (WEEE), and in addition, the reuse, recycling and other forms of recovery of such wastes so as to reduce the disposal of waste."
I think that on the surface, at least, this is a good thing.

RoHS == Rules of Hazardous Substances

The EU has enacted laws designed to keep certain hazardous substances out of landfills and subsequently from groundwater. They did this by mandating the recycling and reuse of WEEE. It is no longer allowed to turn WEEE into landfill.

The RoHS rules are a consequence of the WEEE Directive. On the surface, I think this is good, but it is a sticky and messy tar baby (not that anyone ever claimed this would be neat, tidy, and/or painless).

There are several banned substances

The banned substance affecting electronics manufacturers is lead since it is a component of tin/lead solder. RoHS compliant manufacturers now have to assemble equipment with lead-free solder. They are finding out, the hard way, that the transition is not trivial. The finished joints don't look the same as a comparably finished joint made with tin/lead solder does. (a lead-free solder joint looks like a cold solder joint made with tin/lead solder). There are also issues with the long-term durability of connections made with this solder. Note that military and other mission-critical products (medical equipment) are exempt and may use tin-lead solder.

Anyone, big or small, who wants to market their goods within the EU must comply. For the near term, some manufacturers (like me) maintain dual inventories. But my take is that any manufacturer who markets to the EU will simply make everything to comply with the RoHS directives. In the global sense, this is nearly everyone, so the WEEE and RoHS directives will affect manufacturing well beyond the member states. In the end, if manufacturers adopt this approach (single inventories), everyone benefits whether you are in the EU or not.

The unfortunate part of this is that within the United States, the new rules do nothing to get things out of the refuse stream. Our throwaway society has ensured that because new goods are nearly always not repairable or deemed not worth repairing. When something breaks, it nearly always ends up in the trash, and thence in the waste stream. In this respect, WEEE is a Good Thing since it mandates member states to recycle and reuse cast-off equipment.

Another part of the new laws/rules/directives mandates that you must dispose of certain things via an approved disposal method, usually via a third party who takes the item and recycles what can be recyled and the rest becomes landfill. Here in the US, people must pay to get rid of old computers and TV sets. They haven't gotten down to things like transistor radios, etc. yet, but the writing is on the walls.

Here in Washington State, the legislature directed the establishment of a system to recycle computers, televisions, and certain other electronic equipment at no cost to consumers. This system is operated by the electronics industry, but funded by state revenues. The state has levied a special tax on companies who produce computers and television sets.

California has measures SB20 and SB50 on the books as well, requiring recycling of EEE having displays larger than 4 inches. Other state legislatures are working on their own versions. China (surprise!) is trying to beat Europe at itís own gameÖ and they just might succeed.

Is This Really the Right Thing?

For Europe, at least, this is a good thing. Sadly, we (the USA) are behind them. Getting contaminates out of landfills and out of groundwater is a good thing. But a better thing is to keep EEE (thatís what electrical/electronic gear is before it becomes WEEE) out of the waste stream in the first place by keeping it in service, and for as long as reasonably possible.

My thought: our society is completely and totally obsessed with the concept of "more for less." Our unending quest to buy the cheapest stuff has been met by manufacturers getting more and more clever about how they build stuff.
For electronics, the reductions in cost have come about from two major changes: manufacturing technique and overseas manufacturing. In the past, electronic things were assembled from parts with wire leads that were inserted into circuit boards and/or connected by hand from point to point, and then soldered into place. Eventually machines were developed to automate this process, lowering costs. Because the parts are physically large enough to hold with your fingers, equipment made this way is mostly repairable.

Today, the method uses surface mount components (SMT). These components are very tiny; in some cases smaller than the sesame seed on your Big Mac's bun. During assembly, an moving table positions the circuit board underneath an applicator head that receives the parts from a sequencing unit. 10 years ago, when I was active in high-volume manufacturing, the machines used then could apply a part every 120 milliseconds (30k parts/hour).

A byproduct of surface mount electronics is density. Density, both in terms of how much functionality is packed into todayís application-specific integrated circuits and the density afforded by SMT and mechanized assembly. The modern cell-phone is a prime example of this technology. The problem is these things are mostly unrepairable. They are too small, too complex, and nearly impossible to apply standard bench servicing techniques to. We have traded repairability for manufacturing time and product size. There is no easy way for humans to deal with such things.

It used to be, when something broke, you got it repaired. Today, when something breaks, you toss it. This has got to stop. This is the part of the puzzle that goes beyond WEEE.

If you make the producers responsible for the waste stream, they will pass the extra cost onto the consumers. Price goes up. This is bad (from the standpoint of cheaper, cheaper, cheapest), but what can consumers do? Nothing. So let's change what the extra cost represents.

My concept is to encourage people to repair their electronic goods. The original point was that things are being made so that they are not repairable (at least by mere mortals such as myself). But what if manufacturers had to support their products past the customary 1-year warranty? That is if you (the manufacturer) decided to make something that was fundamentally non-repairable, then perhaps you have to warrant it for some longer period of time, like 3-5 years. In this case, the warranty is just an exchange program, and maybe you have a repair line in a third-world country to refurbish the broken units or perhaps you just recycle them.

Intrinsically this doesnít keep things out of the waste stream, although it does shift the point at which something enters the waste stream. Perhaps manufacturers will be encouraged to make things more repairable, so they have longer service lives, which in the long run may cost them less than having to provide the extra warranty.

But assuming that something is repairable, then what? We have to take our bean-counter hats off and eschew the notion that nothing is worth its purchase price to repair. This sort of misguided cost accounting results in many pieces of EEE becoming WEEE. Since we paid less for something (because someone was clever enough to figure out how to make it cheaper), we should still be willing to spend a major fraction of the unitís cost, to keep it in service and out of the waste stream.

Let the extra cost represent the extra cost of making something repairable, the cost to the manufacturer of performing the repair; in or out of warranty, and/or the extra cost of extending the warranty via an exchange program.

I realize that it would be easier to piss up a rope.

Either way things cost more for the consumer. Pushing this back on the original manufacturer is a better way to keep this stuff out of the waste stream and (hopefully) enhance its service life. That is far more proactive than simply following the WEEE directive and recycling. We must give up our cheapskate ways.

Dig A Bit Deeper

Mouser Electronics, one of my suppliers, has two excellent pages:
http://www.mouser.com/index.cfm?handler=rohs 
http://www.mouser.com/index.cfm?handler=weeemap 

Newark Electronics also has a very informative site:
http://www.newark.com/services/rohs/ 

The Directives
eur2002.95.ec -- The WEEE Directive 
eur2002.96.ec -- The RoHS Directive 

A Workable WEEE Solution
http://www.hp.com/hpinfo/globalcitizenship/environment/return/index.html 

Last modified 07/22/2009 13:56:52.