24 November 2004�People are calling it a data-gathering nightmare. In 2003 the European Commission, the European Union�s executive arm in Brussels, Belgium, adopted a pair of directives aimed at sparing landfills the estimated 12 to 20 kilograms of electronic waste that every European generates each year. The first of the two directives, called WEEE (Waste [from] Electrical and Electronic Equipment), requires producers to take back and recycle, at no cost to consumers, nearly anything that uses a battery or an electric cord�for example, computers and smoke detectors.
Acknowledging that some electronic waste is going to end up in the landfills anyway, where it could pose a danger to human health and to the environment, a second directive known as RoHS (Restriction of Hazardous Substances) does just what it says: it restricts the use of certain hazardous substances in electrical and electronic equipment. Starting on 1 July 2006, with few exceptions, new equipment entering the European market will have to comply with maximum permissible levels of lead, mercury, cadmium, and hexavalent chromium, as well as with two flame retardants commonly used in molded plastics.
The RoHS directive is a surprisingly tidy document, running only five pages in the Official Journal of the European Union. But its impact promises to be enormous�not just in obvious compliance issues when products must be redesigned but also in data collection and reporting�as industrial participants made clear at a recent teleconference sponsored by the consulting firm Raymond Communications Inc., in College Park, Md. Under RoHS, making a single computer could require as many as 3000 materials declarations�and in as many different formats.
Materials declarations are nothing new to manufacturers doing business with the EU, which introduced similar producer responsibility legislation covering product packaging and vehicles being discarded. The difference, observes Mark Myles of Goodbye Chain Group LLC, in Colorado Springs, Colo., is that "the electronics industry is very, very diffuse today, and the supply chain is many layers deep."
The cryptic character of RoHS does not help. The directive instructs producers to certify that their products meet requirements, but it does not say how they should do that. Moreover, the EC has still to formally rule whether the maximum concentration levels of banned substances will apply to homogenous materials such as plastics and coatings or to components like capacitors or transistors�or both. "We don�t know exactly what �RoHS-compliant� really is," said Hewlett-Packard�s Paul Quickert at the teleconference.
Ideally, said Quickert, who is responsible for HP�s satisfying regulatory requirements, products should be allowed to enter the market under the presumption that they are compliant, and data should then be collected to back up that presumption. But owing to the vagueness of the regulations, no one can agree what those data should be, and companies are already complaining about being asked by customers along the supply chain to report information in all kinds of ad hoc formats. Semiconductor supplier Toshiba, for example, has seen customer compliance requests jump to more than 1000 a month. These can come from a manufacturer using a Toshiba component in a finished product or from a company further down the chain using a device supplied by another firm that happens to contain Toshiba material, and so on. What is more, compliance requests can range from simple e-mail queries to elaborate spreadsheets requiring substantial manual data entry. For that reason, each request has to be handled individually, said Phil de Guzman, quality assurance manager for memory products at Toshiba American Electronic Components Inc., Irvine, Calif.
In an attempt to standardize data collection, reporting, and transfer, the European Information and Communications Technology Industry Association, Brussels; the Japan Environmental Management Association for Industry, Tokyo; and the Electronics Industry Alliance (EIA), in Arlington, Va. are developing a Joint Industry Guide. It aims to reach global industry agreement on what and above what amounts materials need to be disclosed and to develop data-exchange formats and tools. According to Jason Linnell of the EIA, "the guide is flexible enough that it can be incorporated into [whatever] electronics forms that companies may wish to use."
Individual member states of the EU were required to enact laws complying with RoHS by 13 August 2004. Only Greece made it. "I am disappointed that 24 member states have missed today�s deadline and urge them to speed up the legislative process," stated Margot Wallström, the EU�s commissioner for the environment, in a press release. Also slow to react are many small producers in both Europe and the United States who reportedly remain largely unaware of WEEE and RoHS. But producers eager to avoid trouble at European borders are not delaying. Said Steven Boychyn, supply chain manager at electronics manufacturer Celestica Inc., in Toronto, "We are going to be compliant and ready for RoHS well in advance of the 1 July 2006 deadline."