Global impact of environmental legislations in 2008

Once there was only the RoHS Directive in the European Union (EU) causing concerns for the design engineer community. Today, several other legislations provide challenges to the industry and often impact the design phase of a product. Many of these directives are driven from Europe, but the world now seems to be a smaller place when it comes to tackling environmental issues with China, Korea, Australia, North America and, to a lesser extent, India all considering their own approaches to restricting hazardous substances and more efficient ways of recycling.

Taking a quick look at what is happening today, the EU is undertaking a review of the RoHS Directive to widen the scope of restriction to include medical products as well as monitoring and control instrumentation devices. Less likely, but certainly possible, is the inclusion of flame retardants as restricted substances. No changes are likely to be implemented until around 2012. At that time, Categories 8 (medical) and 9 (monitoring and control instruments) are expected to be included. From 2008 onwards, manufacturers will be making changes to their product ranges in preparation for the additional restrictions.

In Asia, the Korean RoHS will come into full force this year. At present, the Korean directive affects a limited range of products, but the scope will likely broaden. Substance restrictions and exemptions will be the same as EU-RoHS. Thailand, Taiwan and Australia are also considering new legislations and voluntary agreements, but these are not likely to be implemented in 2008.

In the US, so far mercury and two polybrominated diphenyl ethers are banned in several states. The California-RoHS is in force for displays only, but legislators are likely to try again in 2008 (vetoed in 2007) to broaden the scope to follow that of EU-RoHS.

NOT JUST ROHS

Two pieces of legislation known as the Eco-design of Energy using Products (or EuP) Directive and REACH regulations will also have a significant impact on the industry and the environment. The focus of the EuP is on energy efficiency throughout the lifecycle of a product. Reviews are currently taking place on 14 product categories such as consumer items, power supplies, and lighting. Five categories will follow in the first review. The second review, which is set to take place over the next three years, will look further at 25 priority A and nine priority B product categories.

Recommendations, known as “implementing measures,” will be made to improve power efficiency. Implementing measures will be introduced in 2008 that will affect external power supplies and battery chargers, standby and off-mode power (most products have off-mode power losses, and many products such as PCs, TVs, and microwave ovens use standby); lighting (office, street, and residential); and TV and computers (possibly late 2008 or early 2009). One of the several implementing measures is to cut the power consumption of electronic products in half. Other possible implementations would include less reliance on fans, using switch-mode power supplies, and low power ICs.

These measures will affect the design of equipment. The design engineer – who will be obligated to implement these measures – may need to look for solutions to lower voltages. Linear power supplies will continue to be phased out and replaced by switch-mode. There will be an increasing demand for more energy-efficient components such as microprocessors, lamps, and electric motors.

On the other hand, the REACH Policy Reform looks to register around 30,000 chemicals brought onto the market. Today we do not fully understand the effects, uses, and handling of many of the chemicals available. REACH looks for these to be registered along with all the necessary safety data. The cost to industry could be significant but, in the long-term, there could be considerable health benefits such as a potential reduction of people suffering from allergies, asthma, and certain types of cancer, as well as a positive impact on wildlife.

The pre-registration of chemicals is required from June 1, 2008. The industry is already seeing withdrawal of products, and this will likely continue through 2008. The main goal is to eliminate substances that are toxic, carcinogenic, mutagenic, or are reproductive toxins. Many manufacturers will begin to introduce substitutes during 2008. However, these substitutes may potentially cause production difficulties. It is also possible that some chemicals will become more expensive, although the European Commission (EC) believes that price increases will be minimal. Clearly there will be variation, but some significant price increases are probably due to the cost of registration/evaluation via the REACH process.

Material Safety Data Sheets (MSDS) are a requirement under REACH and should now follow the format in Annex II of the regulations, although most currently do not. It is important that suppliers make these available for all substances and preparations that are being sold now. These are required for all materials that meet the EC’s definition of substances, which includes ink in inkjet cartridges and electrolytes in batteries. MSDS should be updated by suppliers when new data becomes available and when registration starts, they will need to include “exposure scenarios” in an appendix.

Equipment suppliers are also obliged to provide information on SVHCs (substances of very high concern) present within 45 days of request. At present there is no SVHC list, but this will be published during 2009. Greenpeace and other environmental organizations are encouraging consumers to write to suppliers requesting this information.

Global recycling legislations are already emerging. The goal is to have an efficient collection, treatment, recycling, and disposal of products at their end-of-life. However, there is a design emphasis with early consideration given to the ease of recycling. Quickly dismantling a product into its major parts such as the printed circuit board and enclosure, right through to using plastic clips rather than screws that are time consuming to remove, all aids the recycling process.

Meanwhile, the new EU-Batteries Directive comes into force in September 2008, although Member State legislation has not yet been formulated and so this is likely to be late. The scope of this legislation includes substance restrictions (Cd and Hg), labelling, collection and recycling of spent batteries, registration by “producers” (including companies that import into the EU equipment that contain batteries), and ensuring that batteries are easy to remove from equipment.

Many countries have either implemented or are considering RoHS-style legislation, including China, South Korea, Australia, Thailand and Taiwan. The US and Canadian states continue to introduce substance restrictions and recycling initiatives, and the likes of Mexico, Australia, Taiwan and several South American countries are planning, or have already implemented WEEE (Waste Electrical and Electronic Equipment)-based legislation. WEEE-type legislation is also being introduced in other countries – notably in China and South Korea where it is expected to come into force this year.