The Many Lives of EEE Regulations in the EU

The European Union (EU) has the world's most complex system of regulations when it comes to the life cycle of electric and electronic equipment (EEE). This web of rules touches upon every step of the life cycle of EEE, from manufacturing to use to disposal and recycling.

To the uninitiated, navigating these rules--and understanding how they relate to one another--is a daunting task.

To get you started, here is an in-a-nutshell overview of the many EEE life cycle regulations in the EU.?

WEEE: The Waste Electrical and Electronic Equipment Directive

WEEE came into effect in 2003. The latest version dates back to 2014. In a nutshell, WEEE requires EU members to implement basic collection and recycling measures for EEE within their territories. Some more specific measures include:

1. Special provisions on how to treat the end of life of batteries, printed wiring boards, and cables;
2. Requiring manufacturers and sellers of EEE to support customers in recycling and disposing of EEE;
3. Requiring the use of the crossed-out wheeling bin symbol to separate EEE from other waste; and
4. Imposing targets for recycling rates.

RoHS: Restriction of Hazardous Substances

RoHS went into effect in 2004. The latest amendment dates back to 2019. In a nutshell, RoHS restricts the concentration of certain hazardous substances in EEE manufactured in, imported to, or distributed in the EU.

There is a total of ten substances that RoHS currently restricts. Four of them are heavy metals (lead, cadmium, mercury, and hexavalent chromium); two are flame retardants; and the other four are phthalates.

The Ecodesign Directive

The Ecodesign Directive came out in 2009. One of its major contributions was to create the Electronic Product Environmental Assessment Tool, or EPEAT.

EPEAT is a voluntary program where manufacturers of certain EEE can get certified in environmentally-friendly practices. For a manufacturer to receive EPEAT certification, the manufacturer needs to show that its manufacturing process includes:

1. Reducing or eliminating hazardous materials
2. Selecting environmentally-friendly materials
3. Incorporating end-of-life considerations in the product's design
4. Incorporating manufacturer support for product end-of-life management

The Waste Framework Directive

The Waste Framework Directive came out in 2008. The Waste Framework Directive created a standardized recycling system, including separate collection and processing of recyclable materials, and a standardized process for EU countries to classify recycled materials as a new product.

The Waste Framework Directive was updated in 2018. The update established a public database of substances of very high concern (SVHCs). The objective was to better regulate the disposal of products with SVHCs in them.

The list of SVHCs fell within the purview of our last regulation of the day: EU REACH.

REACH: Registration, Evaluation, Authorization and Restriction of Chemicals

REACH dates back to 2006. REACH requires manufacturers, importers, and distributers of products--even beyond EEE--to disclose or register substances in their products for public knowledge and evaluation.

The REACH disclosure requirements allow the entire supply chain, along with consumers, to know if a product contains any SVHC. Manufacturers, importers, and distributers must assess their products for the presence of any SVHC. If SVHC's are present in a concentration higher than 0.1%, buyers and consumers must be informed as much.

The REACH registration requirements are new and bring the EU's end of life efforts full circle. As of January 2021, any manufacturer, importer, or distributer of a product containing an SVHC in a concentration of 0.1% or higher must register that product with SCIP. That registration includes information on how to safely handle the product and, more importantly for our purposes, how to handle the product's end of life.

Needless to say, this is a nutshell overview. Stay tuned for more in-depth information on each of the regulations above.