What is WEEE Recast?

Waste Electrical and Electronic Equipment Directive 2002/96/EC (WEEE) set collection, recycling and recovery targets for electrical goods and is part of a legislative initiative to solve the problem of huge amounts of toxic e-waste. It was replaced by DIRECTIVE 2012/19/EU, called WEEE Recast. The WEEE Directive requires each member state to transpose the Directive into its own regulations. In effect, this creates a different implementation in each country, including varying requirements for registering and reporting.

What is included

WEEE applies to Electrical and Electronic Equipment (EEE). Unlike RoHS 2, the definition of EEE stays the same: “equipment which is dependent on electric currents or electromagnetic fields in order to work properly”.

WEEE Directive In Plain English

There are not enough landfills for trash in many parts of Europe; electronics tend to leach chemicals into groundwater when put in a landfill. WEEE is designed ensure that recycling happens more and more. Retail stores are obligated to take electronics back from consumers at no charge. Business to business commerce is a little different. Producers that sell Electrical and Electronic Equipment (EEE) are obligated to register in each member state where their EEE is sold. They are also obligated to recycle EEE that they sold. In a nutshell, you’re the “Producer” if your name is on the product label.

There are three steps:

  1. Register in each country (member state)
  2. Report total weight sold in that member state
  3. Arrange for shipping to a recycler

Registration is different for each country. Reporting is different for each country: some annual, some quarterly, some monthly, each may have different categories of reporting. Each member state has it’s own billing calculation for total products imported by weight.

There are several ways to accomplish recycling in each member state, including the Producer joining a compliance scheme as a member, arranging to have relevant products recycled, and in some cases shipping the product to the recycler.

Lead Free Design has the experience to assist you in WEEE compliance customized for your requirements and distribution system.

WEEE vs. WEEE Recast

We are in a transition period until August 15, 2018. In addition to new recovery targets, the number of categories changes from ten to the following six:

  1. Temperature exchange equipment
  2. Screens, monitors, and equipment containing screens having a surface greater than 100 cm2
  3. Lamps
  4. Large equipment (any external dimension greater than 50cm) including, but not limited to: Household appliances; IT and telecommunication equipment; consumer equipment; luminaires; equipment reproducing sound or images, musical equipment; electrical and electronic tools; toys, leisure and sports equipment; medical devices; monitoring and control instruments; automatic dispensers; equipment for the generation of electric currents. This category does not include equipment included in categories 1 to 3.
  5. Small equipment (no external dimension more than 50cm), including the same type of products as large equipment, except for Small IT equipment, which is treated as a separate category.
  6. Small IT and telecommunication equipment (no external dimension more than 50 cm)

Exclusions to WEEE requirements are now backed up by clear definitions, of particular interest are definitions for the “Large Scale” equipment exclusions.

Exclusions of interest are:

  • equipment designed to be sent into space
  • large scale industrial tools
  • large-scale fixed installations
  • equipment specifically redesigned for R&D and are only available on a business to business basis
  • medical devices and in vitro diagnostic medical devices, where such devices are expected to be infective prior to end of life, and active implantable medical devices.

What is RoHS?

Originally, RoHS (“Restriction of Hazardous Substances”) was the term applied only to EU RoHS.  It is now a generic term for any country’s environmental safety directive having to do (primarily) with reductions in six common hazardous materials routinely found in electronic information products.

EU RoHS

The original EU Restriction of Hazardous Substances Directive (EU RoHS) 2002/95/EC became European Law in February 2003. This directive restricts the use of six hazardous materials in the manufacture of various types of electronic and electrical equipment. Often called RoHS 2, DIRECTIVE 2011/65/EU went into effect January 2, 2013.

There are two important differences between RoHS 1 and RoHS 2:

  • RoHS 1 required Certificates of Compliance for the product, a kind of honor system. RoHS 2 added the requirement to have Technical Documentation that demonstrates compliance for every component in the product. This Technical Documentation must be produced for any “a reasoned request from a competent national authority”.
  • RoHS 2 is now part of CE, which in practice means enforcement is higher, and penalties greater than under RoHS 1. RoHS marking is no longer valid, as it is part of CE.

RoHS currently restricts the use of the following six substances in electrical and electronic equipment:

  • Lead
  • Mercury
  • Cadmium
  • Chromium VI (Also known as hexavalent chromium)
  • PBB
  • PBDE

PBB and PBDE are flame retardants used in some plastics.

These four phthalates will become restricted in 2019 and 2021, depending on product category:

  • DEHP
  • BBP
  • DBP
  • DIBP

While the environmental concerns vs. the economic impact continue, these banned substances can cause very serious health problems.

The maximum concentrations are 0.1% (except for Cadmium which is limited to 0.01%) by weight of homogeneous material. This means that the limits do not apply to the weight of the finished product, or even to a component, but to any single substance that could (theoretically) be separated mechanically – e.g. . the sheath on a cable, the tinning on a component lead etc).

As an example, a radio comprises a case, screws, washers, a circuit board, speakers etc. A circuit board comprises a bare PCB, ICs, resistors, switches etc. A switch comprises a case, a lever, a spring, contacts, pins etc. The contact might comprise a copper strip with a surface coating.

Everything that can be identified as a different material must meet the limit. So if it turns out that the switch’s contact coating was gold with 2300 ppm cadmium then the entire radio would fail the requirements of the directive.

Note that batteries are not included within the scope of EU RoHS, therefore Ni-Cd batteries are permitted despite the Cadmium. This is not true for China RoHS (more below).

RoHS applies to these products in the EU whether made there or imported.

For EU RoHS, many exemptions apply.  This is not true for China RoHS.

China RoHS

China RoHS requires stringent marking, and China-approved testing prior to product entry into China.

On November 6, 2006, China’s Ministry of Information signed three standards into law:

  • Marking: labeling and information disclosure
  • Levels: maximum concentration value
  • Testing: testing methods

EU RoHS compared to China RoHS:

  • EU RoHS compliance does not equal China RoHS compliance.
  • EU RoHS has no Marking requirements.  China RoHS Marking requirements are stringent.
  • Many components with EU RoHS certificates will still have hazardous materials which must be disclosed.
  • EU RoHS exempts many components from compliance.
  • China RoHS currently has no RoHS exemptions.