Understanding the EU Environmental

Transcription

1 Understanding the EU Environmental Directives --RoHS (Restriction of Hazardous Substances) --WEEE (Waste of Electrical and Electronic Equipment) --EuP (EcoDesign Requirements for Energy Using Products) By Bob Straetz, Office of the European Union U.S. Department of Commerce 1

2 RoHS Directive--Overview An Article 95 (Single Market) Directive Seeks to reduce the environmental impact of electrical and electronic equipment (EEE) at end of life Products which do not comply cannot be placed on the EU market Complementary to the WEEE Directive 2

3 RoHS Directive - Requirements From July 1, 2006, new electrical and electronic equipment put on the market should not contain. --Lead --Mercury --Hexavalent Chromium --Cadmium --Polybrominated Biphenyls (PBB) --Polybrominated Diphenyl Ethers (PBDE) 3

4 RoHS Directive Scope All equipment dependent on electrical currents or electromagnetic fields in 10 indicative categories: Large Household Appliances Small Household Appliances IT/Telecommunications i Consumer Equipment Lighting gequipment includes electric light bulbs and household luminaires Electrical and Electronic Tools Toys, y, Leisure & Sport Medical Devices Monitoring and Control Instruments Automatic Dispensers 4

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6 RoHS -- Scope In most cases the answer is straightforward. (i.e. Cookers, mobile phones, DVD players and so on) But significant areas of doubt, particularly in the specialized or industrial sectors (such as gas analyzers, telecom test equipment and actuators used as a valve in a utility plant) Decisions at the EU level are essential 6

7 RoHS Max Concentration Values Agreed levels (published August 19, 2005): --0.1% for lead, hexavalent chromium, mercury --0.1% for PBBs and PBDEs --.01% for cadmium By weight in homogeneous materials..shall be tolerated. (uniform composition i throughout) h 7

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9 RoHS Exclusions Medical Devices, Monitoring & Control Instruments Large-scale stationary industrial tools Spare parts that are used for the repair or reuse of electrical and electronic equipment put on the market before 1 July 2006 Exemptions listed in Annex (plus additions) 9

10 ROHS Directives Compliance and Enforcement Key Principles Self-certification by manufacturers Backed up by standards on agreed tests (IEC and ASTM standards for products and materials are available IEC 62321, IEC 62596, F2617, F 2577) Standardized Reporting Formats (Material Declaration Forms) RoHS mark is voluntary (at this time) 10

11 RoHS -- Compliance and Enforcement Create a compliance plan and strategy for implementation; Educate and manage the supply chain; Collect information from the supply chain (ie materials declaration forms, suppliers test certificates); Verify and validate collected information (by audits), and fill in compliance gaps by testing and monitoring 11

12 RoHS Compliance and Enforcement Store information and frequently audit and update the information from the supply chain Be aware of the exemptions that apply to your product Other Issues (Compliance) CE marking in Re-Cast RoHS Directive under New Approach Directive 768/2008/EC (has requirement for technical file) Issue of RoHS standards and tests (will you be required to use European RoHS standards and get a test)? 12

13 RoHS Enforcement Each Member State is responsible for their own enforcement of RoHS Products placed on the market are presumed to comply with the RoHS Directive Enforcement body can challenge manufacturers declaration of RoHS compliance If so, producers will need to demonstrate they have taken reasonable steps to comply So far, Member States seem to be working cooperatively with companies not in compliance, but that could change 13

14 Revision of RoHS Directive- December 2008 Medical devices and monitoring and control instruments (Categories 8 & 9) included 2014 and RoHS Directive is separated from the WEEE Directive and the annex of binding products now resides in the RoHS Directive (not the WEEE Directive) Exclusion of spare parts Exemptions limited to 4 years (to encourage substitute materials) 14

15 Revision of RoHS Directive No new substances were added; however, new substances can be added if there is an unacceptable risk to human health h and the environment using REACH methodology (Includes socio-economic risk committee to weigh economic costs of a new substance ban) Three phthalates (BBP, DBP and DEHP) used as plasticizers to make plastic soft and flexible and the flame retardant HBCDD have been put under study 15

16 Revision of RoHS Directive RoHS revision linked to CE mark Regulation 768/ technical documentation (internal production control) --affix the CE mark and fill out the DOC Provides definitions iti for homogeneous materials and industrial monitoring and control instruments 16

17 Revision of RoHS Directive -- Annexes Annex I Categories of electrical and electronic equipment covered by the Directive (i.e., large household appliances, consumer equipment) --Electrical and electronic tools (with the exception of large scale industrial tools, but no definition is provided) Annex II Binding list of products that fall under the categories listed in Annex I 17

18 Revision of RoHS Directive Annex III New substances for review and possible addition to RoHS: HBCDD, DEHP, BBP, DBP (plasticizers and flame retardants) Annex IV Maximum concentration values allowed by weight in homogeneous materials: --lead.1%; Same as the original --mercury.1% RoHS Directive --cadmium 0.01% --hexavalent chromium.1% --flame retardants PBB and PBDE.1% 18

19 Revision of RoHS Directive Annex V Full list of approved exemptions Annex VI Applications exempted from the directive regarding Category 8 (medical devices) and Category 9 (monitoring and control instruments) Annex VII EC Declaration of Conformity name and address of manufacturer must list the RoHS directive along with others that apply can list relevant harmonized standards signature 19

20 Revision of RoHS Directive Key websites:

21 Cost of RoHS for Companies CEA study estimates U.S. companies spent $32 billion complying with RoHS Research and development Changes in manufacturing process Changes in materials used in production Testing Cost of keeping records (material declaration forms) from or to suppliers 21

22 WASTE OF ELECTRICAL AND ELECTRONIC EQUIPMENT (WEEE) EN Companies affix WEEE insignia to their hi product Effective August 2005

23 Waste of Electrical and Electronic Equipment (WEEE) All Electrical and Electronic Equipment placed on the EU market after August 13, 2005 must provide these markings: A Unique identification of the producer Date marking of manufacturer/placing the product on the market (after August 13, 2005) Some companies put website ( under the WEEE insignia to give information 23

24 WEEE Directive s Key Objectives Reduce electrical and electronic equipment waste Increase reuse, recycling and other forms of recovery Improve environmental performance of all operators involved in the life cycle of electrical and electronic equipment (e.g., producers, distributors, consumers) and in particular those operators involved in the treatment of WEEE 24

25 Key Principle of WEEE Directive Producer Pays Member State infrastructure for WEEE Directive -Registration Agencies in each Member State -Collection Centers -Treatment Centers Reporting Requirements -Companies are required to keep records on how much EEE they place on the market and report this to a Member State agency 25

26 How will U.S. exporters be affected? Parties putting the product on the national market are responsible for WEEE financial obligations - Sales subsidiaries - Manufacturing plants - Distributors Technically, US exporters should not be affected by WEEE registration requirements but sometimes they are 26

27 Join Compliance Scheme or Take Individual Responsibility Most companies will join a compliance scheme Companies might have to give a bank guarantee on a yearly basis (to cover expenses in case the firm goes out of business) Compliance schemes base rates on tonnage and percentage of market Compliance scheme will take care of collecting, transport, treatment, and record keeping (WEEE Data Sheets) 27

28 Join Compliance Scheme or Take Individual Responsibility Compliance scheme will meet WEEE goals on recovery, reuse and recycling Producer must include instructions on how product should be treated and recycled (instructions identify components and materials with dangerous substances) 28

29 Pan-European Schemes These organizations operate in multiple EU countries and have partnerships with recycling companies. They can handle administrative functions, collection, transport, treatment, and record-keeping. 29

30 Some Pan-European Schemes Rene European Advanced Recycling Network (EARN) Landbell (located in Germany) European Recycling Platform (ERP) WEEE Forum 30

31 Commerce Website Tracking WEEE Implementation ountries.html - Tracks WEEE implementation in each Member State - Gives names, phone numbers, and contact points for all Registration i Centers - Provides names of recyclers, some of which offer Pan- European services - General WEEE & RoHS documents 31

32 Key Features of the new WEEE Proposal A one-stop-shop approach to registration (register in one country for all EU sales) Commission proposes p to set mandatory collection targets equal to 65 percent of the average weight of electrical and electronic equipment placed on the market over the two previous years in each Member State Whole appliances and medical devices will also have targets set 32

33 Key Features of the new WEEE Proposal Proposal calls for producers to pay for the expense of collecting and transporting household WEEE to treatment centers Discussions for the RoHS and WEEE proposed revisions will take place during the next two years. There will undoubtedly be changes to these initial revisions 33

34 Costs of the WEEE Directive to US Companies Product labelling Administrative: registration and record-keeping Cost of joining a compliance scheme or setting up a takeback system 34

35 EcoDesign of Energy Using Products (EuP) Establishes a framework for setting EcoDesign requirements for all energy using products in the residential, service and industrial i sectors The EuP Directive seems to be primarily aimed at electrical products at this point but coverage could be for products using gas, fossil and renewable energy as well (Also, proposed new directive establishes EuP for objects like doors and windows) Defines conditions and criteria for setting EcoDesign requirements, taking into account the whole product life cycle 35

36 EcoDesign Requirements for EuP Directive Key Definitions -- EuP EcoDesign the integration of environmental aspects into product design with the aim of improving the environmental performance of the EuP throughout its whole life cycle Life Cycle the consecutive and interlinked stages of an EuP from raw material to use and to final disposal 36

37 EcoDesign Requirements for EuP -- Approach The environmental aspects to be improved include: Predicted consumption of materials, energy and water Anticipated emissions to air, water and soil Anticipated pollution through noise, vibration, radiation and electromagnetic fields Expected generation of waste Possibilities of reuse, recycling, and recovery of materials 37

38 EcoDesign Requirements for EuP Directive Life cycle stages that need to be assessed in the EuP design process Raw material selection and use Manufacturing Packaging, transport and distribution Installation and maintenance Use End-of-life, from end of first use to disposal 38

39 EcoDesign Requirements for EuP Chronology EuP Directive adopted in July 2005 Creation of the Consultation Forum in June 2007 Creation of the Regulatory Committee in 2007 EuP Directive transposed into Member State legislation in August 2007 First implementing measure named in December 2008; second implementing measure published in March

40 EuP Directive Preparatory Studies Preparatory studies lead to implementing measures These studies provide information that the Commission and Consultation Forum need in order to decide if a product should be considered for an implementing measure under EuP U.S. companies affected by a preparatory study can comment by at the end of the study to the consultants who wrote it 40

41 First Set of Preparatory Studies (all are finished) Boilers Water Heaters Personal Computers and Monitors Imaging Equipment Televisions Domestic Refrigeration Washing Machines and Dishwashers Simple set-top boxes Domestic Lighting Public (Street) Lighting 41

42 First Set of Preparatory Studies (cont) Battery Chargers and External Power Supplies Residential Air Conditioners Commercial Refrigeration and Freezers Motors, Pumps, Fans and Circulators Off Mode and Standby losses 42

43 Implementing Measures Implementing Measures have been adopted (since December 2008) for: Standby and off mode electric power consumption of household appliances, office equipment and consumer equipment Simple set top boxes Office lighting Public (street) lighting Battery chargers and external power supplies The implementing measures usually become mandatory a year after they ve been adopted 43

44 Second Set of Preparatory Studies Five more studies are underway: Solid Fuel Boilers Laundry Dryers Vacuum Cleaners Domestic Lighting Complex set top boxes 44

45 Naming of Implementing Measures The Commission, with recommendations from the Consultation Forum and the EC s Regulatory Committee, should name several more implementing i measures in Implementing measures are directives that provide specific requirements for products (i.e., energy consumption, water consumption, noise limits, etc). 45

46 Naming of Implementing Measures Likely Implementing Measures in 2009: Electric Motors Televisions Washington Machines and Dishwashers Stand alone circulators Water Heaters (all have been voted on by the Regulatory Committee) 46

47 Other Features of Implementing Measures Emphasis on standards at the design phase EuP standards being developed by CEN and CENELEC for each implementing measure Self-certification likely, but we still need to follow up on this (internal production module) CE marking required 47

48 Working Plan Air Conditioning systems and ventilation systems 2. Electric and fossil fueled heating equipment 3. Food preparing equipment 4. Network, data processing, data storing equipment 5. Industrial and laboratory furnaces and ovens 6. Machine tools 7. Refrigeration and freezing equipment 8. Sound and image processing machines and equipment 9. Transformers 10. Water-using equipment 48

49 Key EuP Directive Websites htm 49

50 Other EU Environmental Directives Battery Directive End of Life Vehicles Directive REACH (Chemicals Regulation) 50

51 Contact Information Bob Straetz Office of EU Affairs US Department of Commerce Tel: