Transcript RoHS Enforcement in LEADOUT EU Member States

Low Cost Lead-Free Soldering Technology to Improve Competitiveness of European SME
RoHS Enforcement
in LEADOUT EU Member States
Susana Escala,
on behalf of LEADOUT consortium
ELFNET Dissemination Event,
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Low Cost Lead-Free Soldering Technology to Improve Competitiveness of European SME
The Directives WEEE and RoHS
LEADOUT EU Members Implementation
 RoHS
Directive 2002/95/EC (27 January 2003): Restriction of the use of
certain Hazardous Substances in electrical and electronic equipment
 WEEE
Directive 2002/96/EC (27 January 2003): Waste of Electrical and
Electronic Equipment
 Directive 2003/108/CE – Modification of the previous one
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Low Cost Lead-Free Soldering Technology to Improve Competitiveness of European SME
The Directives WEEE and RoHS
RoHS (“Reduction of Hazardous Substances”, 2002/95/EC)
- Deals with the ban of 6 substances within electronic components
and products
- Mandatory since 1st July 2006
- Banned substances: lead, mercury, cadmium, hexavalent
chromium, polybrominated biphenyls and polybrominated diphenyl
ethers
WEEE (“Waste electrical and electronic equipment”, 2002/96/EC)
- Deals with the pickup and recycling of certain products and devices
within the EU and pushes the responsibility of the manufacturer to
new limits
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PROJECT BACKGROUND AND
MOTIVATION
 SME lack of knowledge and
low level of LFS implementation
 Lack of Research work
regarding low scale production
(small series)
 European Benchmarking of
LFS process
STRATEGIC OBJECTIVES
 Development/implementation
of low cost lead-free soldering
processes to support SMEs in meet
the EU directives
 Establishment of process
quality standards, reduction of
defect rates, improve reliability
and therefore competitiveness
 Improve Health and Safety
awareness and pollution
prevention
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RTDs
IAGs
European Lead Free
soldering NETwork
SMEs
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RoHS in FRANCE*
RoHS and WEEE transcribed in French law (very similar to original EC text)
by Decree 2005-829 (20 July 2005) of Ministry of Ecology and Durable
Development
- Title II → RoHS
- Titlle III → WEEE
 First Statute, 25 November 2005: adds 16 exemptions to the list of
equipments not subject to RoHS restriction (e.g. Microprocessor leads and the
lead in wire bonding)
 Second statute, 6 July 2006: extention of the list with 5 more exemption
*Source: JEMI-France
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RoHS in FRANCE*
ADEME (Agency for Developing and Mastering the Energy) is in charge of listing
the producers for WEEE treatment.
EU legislation: list of applicable texts
Directive
2002/96/CE
“WEEE”
Directive 2003/108/CE
Décision 2004/249/CE «Rapport EM»
Décision 2005/369/CE «Formats de données EM»
«Adaptation au progrès technique»
Décision 2006/618/CE
Directive
Décision 2005/717/CE
2002/95/CE “RoHS”
Décision 2005/747/CE
Décision 2005/310/CE
*Source: JEMI-France
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RoHS in FRANCE*
National legislation: list of applicable texts
Arrêté du 23/11/2005 «Agrément DEEE professionnels»
Arrêté du 23/11/2005 «Traitement DEEE»
Décret 2005-829
Arrêté du 13/03/2006 «Registre national des producteurs»
Arrêté du 25/11/2005 «RoHS»
Arrêté du 06/12/2005 «Agrément DEE ménagers»
Rectificatif à la loi de finance 2005 «Contribution visible»
Décret 2005-1472 «Plans départementaux»
Code de l’Environnement Art.L541-10-2
*Source: JEMI-France
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RoHS in SPAIN*
ROYAL DECREE 208/2005 (25/02/2005) by the Spanish Ministry of Environment
Under RD 208/2005 the PRODUCERS of electrical and electronic equipment are Individual or
legal entities:
- Who manufacture and sell electrical and electronic equipment under their own brand;
- Who put equipment manufactured by third parties on the market under their own brand
- Who import from or export to other countries
All producers of EEE must be registered at the National Register of Industrial
Establishments
*Source: AETIC/APROTECH
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RoHS in SPAIN*
DISTRIBUTORS shall not be considered to be producers in the brand of the producer
appears on the equipment and the owner of that brand is registered on a State level in
the special section of the Register of Industrial Establishments
The LEGISLATION applies to manufacturers, importers, distributors and users of all
categories of electric and electronic equipment – Annex 1 RD 208/2005
Regional Governments Consume Departments
– in charge of Vigilance, Inspection and Sanction procedures
Although some Spanish laboratories have the right equipment to test, there is neither
European nor National Legislation establishing what kind of TEST should be
implemented
*Source: AETIC/APROTECH
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RoHS in SPAIN*
Concerns/Frequently Asked Questions:
 Is there a list of exempted products?
 What is going to happen with those products that are in stock and are no longer
valid to be put on the market according to new legislation?
 What is the suitable definition for “put on the market”?
 How are going to do the authorities the inspection and saction procedures?
*Source: AETIC/APROTECH
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RoHS in SPAIN*
Feelings:
- 95% of the companies had enough information about RoHS directive
- 90% of the polled companies had started the transition to lead free technologies
- Alternative solders to SnPb 63-37, alterations in designs and lead free components
availability were the most repeated concers
- Currently, close to 90% of the delivered components are lead free (even some components
are no longer available in lead technology)
- Most of the Spanish manufacturers have changed their equipment to bear lead free (just
companies working with products exempted in RD 208/2005 still have not changed)
*Source: AETIC/APROTECH
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RoHS in PORTUGAL*
RoHS and WEEE transcribed in Portuguese by a law by decree 230/2004,
dated 10 December 2004
Defines the Juridical Regime of:
- Management of the Waste of Electric and Electronic Equipment
- Management of the use of certain Hazardous Substances in EEE
*Contains the same objectives and principles of the EC Directives
*Source: ANIMEE
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RoHS in PORTUGAL*
Regarding RoHS:
Scope of Application:
Not Applicable to:
- EEE categories 1,2,3,4,5,6,7 and 10
(Annex IA of 2002/96/EC)
- Spare parts
- Reuse of EEE put in the market
before 1st July 2006
- Electric Bulbs
- Luminaires
After 1st July 2006, new EEE only without:
* Lead
* Mercury
* Hexavalent Chromium
* Cadmium
* PBDE
* PBB
Not Applicable to:
- Annex of the Directive
*Source: ANIMEE
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RoHS in PORTUGAL*
Problems of Decret Law 230/2004
 Transposes Directives based on different Articles of the EC Treaty:
- Article 175 for WEEE Directive (Minimum Requirements) and Article 95 for RoHS
Directive (Aims at Harmonising the legislation)
 Main concern is Management of the WEEE and not RoHS
 Some definitions must be different for WEEE and RoHS Management: Producer and Place in
the Market
 New (after the Directive) Exceptions are not included
 Nothing about the obligation of the Producer to declare HS free Products and how to do it
 DG Alfândegas (Customs) is not included as an Inspection Entity
*Source: ANIMEE
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RoHS in PORTUGAL*
Conclusion:
The Portuguese Law by Decret 230/2004 has to be reviewed and replaced
* No info about When
Status Quo:
 No concrete additional Information was given to producers (responsible – Instituto dos
Resíduos)
 Meetings between Instituto dos Resíduos and Inspection Entities for advising → No
definitive or clear instructions were given
 The Associations of Producers are advising their Members to have a Declaration of
Compliance, for each product, prepared by themselves
 Instituto dos Resíduos is part of EU RoHS Enforcement Authority Informal Network
that published, in May 2006, a “RoHS Enforcement Guidance Document” → it is expected
that Portugal will follow the future common agreements of the 25 Member States
*Source: ANIMEE
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RoHS in UNITED KINGDOM*
Concerning RoHS:
Enforcing body in the UK: National Weights and Measures Laboratory, that works
through a combination of documentation requests and product testing
Accessible Information can be found at:
www.rohs.gov.uk
Feelings:
- Most companies are attempting to comply but very few are achieving full compliance
of all their products to RoHS, usually because of component availability
- Many companies are also seeking exemptions for their products
*Source: TWI / www.rohs.gov.uk
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RoHS in UNITED KINGDOM*
Concerning WEEE:
 UK regulations came into force on 2nd January 2007, a little behind most other EU
countries
 Envolvement of several government bodies: Department of Trade and Industry
(transposing the directive into law), Environment Agency (enforcement) and Department
of Environment, Food and Rural Affairs (Treatment facilities)
Accessible Information can be found at:
www.netregs.gov.uk
*Source: TWI / www.netregs.gov.uk
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RoHS in UNITED KINGDOM*
In the UK, the timescale are:
15 March 2007: Producers to join a compliance scheme
1 April 2007: Producers to mark their products
1 July 2007: Producer responsibility for recycling and treating househld waste
Feelings:
- Most companies are looking to join a compliance scheme than do it themselves – such
schemes will collect, treat and recycle the WEEE for a producer for a certain fee
depending on the products
- Companies seem to be more unsure of WEEE – more complicated, especially whether
their products are covered or not
*Source: TWI / www.netregs.gov.uk
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RoHS in UNITED KINGDOM*
In September 2006, SMART Group Lead-Free/RoHS Survey 2006 presented the following
results:
*Source: SMART Group
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RoHS in UNITED KINGDOM*
*Source: SMART Group
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RoHS in UNITED KINGDOM*
“RoHS: 99% compliance as enforcers sweep up”
“Ninety nine per cent of products are ninety nine per cent compliant...”
“We are not in business of putting business out of business, we are in the business of
generating compliance”
“When we find poor compliance, we have been to see a company and worked with them,
and their compliance has gone up.”
“We have spoken to a range of these companies, large and small, and 20 per cent – even
some of the multi-million turnover companies – have the view that they are not
‘producers’ in the terms of the Directive, even though they are”
“The most common faults...are on rework where lead-inclusive solder has been used and
where there has been hand soldering, on flying leads for example”
...says Chris Smith, Head of UK RoHS enforcement
*Source: ElectronicsWeekly
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RoHS in DENMARK*
The implementation of the RoHS Directive into Danish Law is a 1:1 mapping
RoHS Directive implemented as Statutory Order issued by the Danish Ministry of the
Environment
- As Statutory Order No.1008 of 12 October 2004
- In August 2006 as a new Statutory Order – Statutory Order No. 873 of 11 August 2006
which replace the previous one. The new Stutory Order includes the exemptions from the
Commission until mid 2006
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*Source: ITEK
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RoHS in DENMARK*
- RoHS enforcement: Enforcement by the Chemical Inspection Service which is in charge
of the Danish Environmental Protection Agency (supervision of legislation regulating
chemicals in Denmark)
Note: The Chemical Inspection Service will launch a one-year campaign in June 2007.
Primarily, samples will be picked up in shops. The campaign findings will be presented in a
report.
- Company concerns:
-“What’s in and out of the Directive?” and “Put on the Market definition”
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*Source: ITEK
Low Cost Lead-Free Soldering Technology to Improve Competitiveness of European SME
RoHS in ITALY*
The EU Directives (RoHS and WEEE) became operative through the entering into force of
the Legislative Decree 151/2005 (1st July for RoHS and 13th August for WEEE)
• The decree law is effective as of 13 August 2005 but its full implementation has been
August 2006, as it has been necessary to create an operational infrastruture
• To date, registration in Italy is only for manufacturers, importers and distributors
located in Italy.
• Companies located in Italy importing ad distributing foreign electrical and electronic
products will be considered as “producers”.
*Source: Camera di Commercio di Milano
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RoHS in ITALY*
Concerning RoHS implementation....
1. Creation of new supporting tools for companies implementing the leadfree soldering method
Sectorial Associations have created guidelines and supporting documents to help companies
to face new leadfree methodology
Italian Electrotechnical Committee (CEI), Italian Independent Body:
- Drafted a Technical Guide for the RoHS application, considering the technical and
organisational aspects and offering practical support to its implementation. It also
addresses environmental protection (link to the WEEE Directive)
*Source: Camera di Commercio di Milano
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RoHS in ITALY*
Technical Guide for the RoHS application
Characteristics
Structured through:
- Drafted by CEI, an Italian Independent
body, with the cooperation of ANIE
(National Association of Electric and
Electronic Companies), IMQ (Institute for
the Quality Certification) and some
resercah centres
-General principles
- Checked by Public Entities (e.g.
Ministries)
- Other Directives for Environmental
protection
-Rohs Directive: contents and basic
definitions
-RoHS and WEEE – Environmental
protection
- based on experiences and results from
WG3 IEC
*Source: Camera di Commercio di Milano
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RoHS in ITALY*
2. Elaboration of models/documents for the product certifiation concerning
RoHS compliance
- RoHS product certification is not mandatory for producers and distributors
- A producer, to check RoHS compliance, has to control each component → it’s important to be
sure that the suppliers guarantee RoHS compliance of their products
→ carrying out chemical analysis → good solution, expensive but safe
→ request of a special declaration from the suppliers → less safe but cheaper
*Source: Camera di Commercio di Milano
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RoHS in ITALY*
3. Creation of special marking to be put on the products
The producer decide independently which marks can be used: no compulsoriness but
can be requested by customers for storehouses management
*Source: Camera di Commercio di Milano
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RoHS in ITALY*
Concerning WEEE Directive...
Delay in the definition of the collection strategy for electric and electronic waste →
practical decrees (providing function modalities and operational aspects) have not been
published on time
Last decree “Milleproroghe”, 28th December 2006 → date for starting the collection of
electronic and electric waste: 30th June 2007
Producers have to create and finance collection and management systems for
electric and electronic waste. Producers are also responsible for hazardous
substances (eg. Mercury and Lead) and have to replace them in the new products
Distributors have to withdraw the waste for free when a new product is
bought
Missing decrees – Decree on the forced subjects and Decree for the establishment of a
control and supervision committee – shuld be ready shortly
*Source: Camera di Commercio di Milano
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RoHS in GERMANY*
The EC Directives are transposed to German law through Electrical and Electronic
Equipment Act, or ElektroG, of 16 March 2005
Electrical and Electronic Equipment Act, or ElektroG
Act Governing the Sale, Return and Environmentally Sound Disposal of Electrical and
Electronic Equipment
The law ElektroG is about to control the nonpolluting disposal of electrical and
electronic goods and came into force at March 2005
*Source: DVS
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RoHS in GERMANY*
• In the future, a standardized symbol shows the end-consumer that these products are
not to be considered as domestic waste, but have to be collected at local collecting points
• Waste collected by the manufacturers directly, under supervision of an authority to
be established in each Member state, which will be responsible for the organisation of the
WEEE
• Within Germany, the registration of waste materials to meet the WEEE had to be done
until 24th November 2006. Since 24th March 2006, the products have to be marked
*Source: DVS
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RoHS in HUNGARY*
The implementation of the WEEE and RoHS Directives into Hungarian Laws:
264/2004 Decree of the
Government
Regulation of collecting
of WEEE
15/2004 Decree of
Ministry Environment
and Water *
Detailed rules for
handling of WEEE
16/2004 Decree of Ministry Regulation of
Environment and Water *
application of materials
according to the RoHS in
electrical and electronic
devices.
*The decrees were amended by changing of EC directives.
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RoHS in HUNGARY*
WEEEs in Hungary
160,00
Waste are collected by a wide
networks and alliances,
established by the
manufacturers under supervision
of Environmental authority
which will be responsible for the
organisation of the WEEE.
WEEE in
households
140,00
(tonns)
120,00
collected
100,00
recyling
80,00
60,00
recovering
40,00
20,00
burnig in power
station
0,00
2003
2004
2005
2006
2007
2008
*Source:Ministry of Environment and Water
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RoHS in HUNGARY*
Important deadlines in the
Hungarian rules
• 1 of July 2006 to finish the
production of equipment
contained materials
according to the RoHS
• 31 of December 2008 to
achieve the collecting of 40 000
tons in WEEEs
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Guides for the companies
The companies interesting in
materials and tools in lead free
soldering or in the collecting of
WEEE have created guidelines and
supporting documents, websites to
introduces the new lead free
technologies as well as the rules of
managing the WEEE.
Low Cost Lead-Free Soldering Technology to Improve Competitiveness of European SME
On behalf of LEADOUT consortium,
THANK YOU for your attention!
Dont’ forget to visit us at:
www.leadoutproject.com
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