There is really no denying that recycling and hazardous waste elimination initiatives will be the trend for the future. While many manufacturers are scrambling to meet the requirements of the WEEE (Waste of Electric and Electronic Equipment) and RoHS (Restriction of Hazardous Substances) directives in the European Union (EU), this is just the tip of the iceberg. Similar voluntary plans are underway in China and Japan, while in the U.S., California is considering WEEE/RoHS legislation.
Go Back and Document
So how can manufacturers best cope with the current change in the regulatory market?
We all need to accept that these types of initiatives are going to be growing in popularity in the coming years. Now is the time to start assessing your existing product line and products in development to make sure they fit the bill. But how best to do that?
We do that by going back through the supply chain and documenting the various materials that are used in end products. Once this has been done, you will need to amass documentation on each of the components making up the products and confirm they meet hazardous materials codes. The downside here is obtaining this documentation will be tedious and time consuming. Worse still, if you're a component manufacturer, this could mean obtaining declarations all the way back to when the metals were pulled out of the ground! Adding to the difficulty might be some of your suppliers may have “proprietary” materials and won't tell your company exactly how they create their product or alloy.
Testing and Product Safety
To help make the process a bit more manageable, another option is to do non-destructive testing on the materials that make up the product. These tests, done by an independent body, can be performed on the populated circuit board, cables, etc., and will show what types of materials are in the product and if there are any banned substances being used. These tests will tell you what component (if any) in the product has a problem. You can then go back to the supplier and demand a change in materials or get a new supplier to ensure that product's future.
These tests should not be a one-time exercise. Audits should be done on at least a semi-annual, or even better, a quarterly basis because the EU requires companies to show proof that they are doing due diligence to keep contaminants out of the waste stream and are being proactive about product safety. Regular audits will also save your company from fines. For example, let's say you make calculators and you've tested all of your products and one day the EU randomly tests your calculator and it comes back hot for cadmium. You go back to your last test and it shows proof that you were indeed making a clean product. After further tests you find that a component of the calculator is causing the cadmium problem. You can now go to your supplier and demand answers. The EU will levy fines on your subcontractor, not your company, because you have proof that you were being diligent to keep the product safe. Considering current fines could be 50,000 Euros (approximately $60,000) for each instance of a problem, this can be a significant cost savings for your company.
Do it Now
My advice to companies is to start testing and documentation as soon as possible. Don't wait for the RoHS deadline, because the requirements will probably cause significant changes to some products. This could be anything from a complete redesign to something as “small” as eliminating lead solder. But as we all know, any change in the makeup of a product can result in changes in function or reliability. All modified products will need to undergo some R&D testing. Additionally, any change to a product will require recertification by a third party Nationally Recognized Testing Laboratory (NRTL) for product safety. All of a product's specifications are contained on the controlled data form listed with the NRTL. In order to maintain a current safety certification, the changed product will need to be retested. So if your company is making changes to products in response to RoHS, this is a double hurdle you must jump in order to stay compliant.
It's a Good Thing
To comply with current and future recycling and waste elimination initiatives, companies will have to start seriously looking back through their supply stream to document and test all of the various components used in their products. Failure to do so will result in the company being locked out of markets, or worse, fined. Of course, with all bad there must be some good. While you will now have to do more documentation and keep a better watch on suppliers, the increased rate of recycling will eventually lower costs for your company. Costs associated with disposal will eventually go down and raw material costs will also drop as companies are able to reuse older parts when they are returned to the factory. While it may seem like a headache now, looking back on how your company gets the materials it needs for a product will lead to a more profitable future, and safer products, while using less resources and eliminating hazardous substances from the waste stream.
Geoffrey Bock is an engineer with TUV Rheinland of North America Inc. and is the program manager for RoHS/WEEE. TUV Rheinland of North America, Inc. is a subsidiary of TÜV Rheinland Group, Germany, a provider of compliance engineering, testing and certification for domestic and worldwide markets.
TUV Rheinland of North America Inc.
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