Transcript Document

US Electronic
Product
Stewardship
Heather S. Bowman
Electronic Industries Alliance
Director Environmental Affairs
and Deputy General Counsel
APEX
February 24, 2004
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Presentation Overview
I.
Electronic Industries Alliance
II. Elements of Global Regulations driving Electronics Product
Stewardship in the United States
III. United States Environmental Laws
III. 2004 Legislation – Electronics Recycling
IV. Voluntary Initiatives
V.
Questions/For More Information
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Electronic Industries Alliance
Public Policy
Meetings &
Networking
Standards &
Technology
 2,500 Members
 80% of a $430 billion industry
 Unique alliance structure
 Environmental Issues Council
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Electronic Industries Alliance
“The Whole is Greater Than the Sum of the
Individual Parts”
Telecommunications
Industry Association
(TIA)
Consumer Electronics
Association (CEA)
Government Electronics &
Information Technology
Association (GEIA)
(JEDEC)
NSTEP National Science &
Technology Education
Partnership (Foundation)
Affiliates
Electronic Components,
Assemblies & Materials
Association (ECA)
Electronic Representative
Association (ERA)
Internet Security Alliance
(ISAlliance)
National Association of
Relay Manufactures
(NARM)
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Examples of Regulatory Elements
1. Require Life Cycle Assessments when Products are
Designed
2. Ban Certain Chemicals from Use in Products
3. Require Consumer Notification and/or Product
Labeling at point of sale
4. Require Electronic Products to Achieve Certain
Energy Efficiency During Use
5. Require Collection and Proper EOL Management
* Europe and parts of Asia in lead; Americas moving forward
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US Recycling Legislation
 Federal Level – US EPA CRT Rule, Thompson
legislation, Appropriations language
 Maine, Minnesota, Massachusetts, California and
Washington all ban CRTs from landfill – either by law
or regulation
 In September 2003, California Enacted First State
Law Establishing a System for Electronics Recycling
 SB20 will Impose Fee ($6-$10) on Sale of CRT/Display
Products starting in July 2004
 Implement EU RoHS directive for covered products in 2007
 Working with DTSC and CIWMB to implement fairly
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Scope of CA SB 20
 Scope of Products, per SB 20 definition
 Currently only CRTs (TVs, Computer Monitors)
 Others, Flat Panel Screens, other Video Display Devices greater
than 4” diagonally, subjected to testing
 SB 20 RoHS provision references this scope of “covered
electronic devices”
 Regulations cannot go beyond requirements in other parts of SB
20, i.e. different product scope, etc
 Regulations also cannot prohibit product allowed in EU
 Chemicals Banned by SB 20 (“presence of certain heavy
metals”)
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Lead
Mercury
Cadmium
Hexavalent chromium
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Relevant EU RoHS Exemptions
 Mercury in compact fluorescent lamps not exceeding
5 mg per lamp.
 Mercury in straight fluorescent lamps for general
purposes not exceeding: - halophosphate 10 mg;triphosphate with normal lifetime 5 mg, long lifetime
8 mg
 Mercury in straight fluorescent lamps for special
purposes.
 Mercury in other lamps not specifically mentioned in
this Annex.
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Relevant EU RoHS 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), and any lower melting temperature solder
required to be used with high melting temperature
solder to complete a viable electrical connection
 Yellow text addition suggested to the EU TAC in
May 2003
 Cadmium plating except for applications banned
under Directive 91/338/EEC 1.
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Need Harmonization
 SB 20 references RoHS directive as it stood on
January 27, 2003
 DTSC can implement regulations to track the evolving
EU changes
 Need ability to evolve regulations after 2007
 Industry is also learning more and more as we
prepare to comply with the law, so we continue to
share information with the TAC (and the Commission)
so its decisions are based on the latest scientific and
technical evidence available.
 In order to ensure harmonization and the ability for
companies to market products globally, high tech
industry has requested and continues to advocate for
IDENTICAL IMPLEMENTATION of RoHS requirements.
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2004 US State Legislation
 Total of 52 bills introduced (several in some states)
 Full Producer Responsibility
 MD, MA, MN, NY (cell phones), PA, RI, VT, WI
 Advanced Recovery Fee
 CA, CT, HI, IL, MD, NE, SC, TN
 Landfill Ban or Study Committee
 ID (Res), MI, NM, NY, RI, WA (amend)
 Combination of ARF/Partial Cost Internalization
 Maine – DEP recommendation after Advisory
Committee Meetings over summer
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US Legislation Concerns
 Level Playing Field
 Enforcement
 Consumer reaction
 Use of funds and true costs
 Consumers
 Company
 Government
 Design Restrictions: Harmonization with EU, China
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Industry Initiatives
 EIA Consumer Education Initiative
(www.eiae.org)
 Provides Consumers with Recycling and Reuse Opportunities
for Electronics
 Manufacturers individual voluntary programs listed
 EIA Track (www.eiatrack.org)
 International Regulatory Tracking Database for Electronics
Industry
 EIA Material Declaration Guide
 Industry Supply Chain Procurement Tool to Ensure Global
Sale - US, Europe, Japan
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Conclusions
 Diversity in approaches, the book is not closed, wait
to evaluate how any of the laws will apply in practice
 Jurisdictions differ on elements of product
stewardship bills, however many common elements:
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Landfill bans
Fees (point of sale or point of disposal)
Chemical bans
Producer responsibly
Voluntary / Market driven
 Over next 5 years anticipate jurisdictions without take
back laws may see pressure to enact
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For More Information:
Heather Bowman
Director of Environmental Affairs
Deputy General Counsel
Electronic Industries Alliance
2500 Wilson Blvd
Arlington, VA 22201
Tel: (703) 907-7576
Fax: (703) 907-7501
[email protected]
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