REACH / RoHS / WEEE
The European Union (EU) regulation for the Registration, Evaluation and Authorization of Chemicals, which entered into force on 1 June 2007, aims to protect human health and the environment from the risks arising from the use of chemicals.
Among other regulations and guidance, it requires EU companies to comply with an authorization process for substances identified as being of very high concern (SVHC) to human health or the environment, if used or produced beyond specified limits. These chemicals can only be used in strictly authorized ways and are candidates for replacement with non-hazardous alternatives.
The European Chemicals Agency (ECHA) is the registrar, regulating and facilitating body for implementation of the REACH legislation. ECHA maintains and updates the lists of SVHC, authorized substances and candidates.
The regulations impact non-EU companies as well. Exporters of SVHC must go through an authorization process. EU importers will require its supply chain to provide documentation to demonstrate compliance. In other words, the regulation affects US companies that are supplying products into EU countries, or are in the supply chain of EU companies.
RoHS and WEEE
The exponential manufacture and recycle of electronic devices has tremendous global environmental and economic impact. Electronic device materials are recycled at a very high rate. Without proper care and control, hazardous materials recycled from electronic goods have a high likelihood to be reused. Furthermore, waste from electric and electronic equipment (WEEE) is exploding and, without management, can lead to environmental risks and negatively affect sustainable economics for electronic devices.
To address these problems, many countries have enacted regulations and laws to control and manage WEEE. There are also global and localized multi-national cooperative efforts to address and combat the problem. In the United States for example, individual states have passed legislation such as California’s Electronic Waste Recycling Act. The Environmental Protection Agency (EPA) supports the National Strategy for Electronic Stewardship and coordinates the International E-Waste Management Network, with member nations from 4 continents.
The European Union has acted strongly in unison trying to address WEEE. It passed the Waste Electrical and Electronic Equipment Directive (WEEE Directive) to limit collection, recycling and recovery targets for all types of electrical goods. The directive applies broadly to ten categories of goods (from consumer electronics to medical devices).
The EU also implemented a sister initiative to the WEEE Directive which addresses specific hazardous chemicals used in the manufacture of electrical and electronic goods. It is called the Restriction of Hazardous Substances Directive 2002/95/EC, (RoHS). RoHS restricts the use of Lead (Pb), Mercury (Hg), Cadmium (Cd), Hexavalent chromium (Cr6+), Polybrominated biphenyls (PBB), Polybrominated diphenyl ether (PBDE), Bis(2-ethylhexyl) phthalate (DEHP), Butyl benzyl phthalate (BBP), Dibutyl phthalate (DBP), and Diisobutyl phthalate (DIBP).
EU member nations were required to codify both directives into law and to assign enforcement bodies. For example, the United Kingdom (UK) transposed WEEE and RoHS into law in January 2013, assigning enforcement responsibility to the National Measurement and Regulation Office (NMRO). This office has published obligations for manufacturers of electrical and electronic devices made or used in the UK.
EU companies are required to comply with the WEEE and RoHS Directives (and related individual EU country legislation). Non-EU companies are also affected. Exporters of devices used in the EU must comply. EU companies require documentation from its supply chain to demonstrate compliance with WEEE and RoHS Directives. In other words, affected US companies include those that export devices into the EU or that are in the supply chain of such goods.
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