Although there are a growing number of relevant environmental directives on the horizon, to date the electronics industry has primarily concentrated on the European Union's Restriction of Hazardous Substances (RoHS) legislation. This can be attributed to the far-reaching business and technology impact associated with the removal of lead from electronic products.
While RoHS is a groundbreaking initiative in that it ensures that environmentally friendly products are placed on the market, to achieve a truly "green" product ecosystem, other initiatives are needed to mitigate negative environmental impact at the end of the product life cycle. In light of this, and the fact that a greater number of electronic products are being recycled with improving results, the EU established the Waste Electrical and Electronic (WEEE) directive in 2003 to regulate the collection, recovery and recycling of electronic and electrical waste.
Through WEEE, EU member states require that producers take back, free of charge, any product placed on the EU market after Aug. 12, 2005. The first collection targets are scheduled to be attained by December 2006.
Today, some retail stores in Ireland are posting signs that clearly state how much the product costs and what the charge is for recycling. In fact, the first European fine for nonconformance to WEEE has already occurred in Ireland.
Due to rapid technological development, the majority of electronic equipment has been discarded, making way for newer, faster and more high-tech systems. The result is a massive rise in the volumes of electronic waste being sent to landfills. In Europe alone, companies currently dispose of tens of millions of kilograms of electronic waste every year.
Today, however, we are witnessing a far more ecological approach from many of the world's OEMs. In response to heightened corporate social-responsibility programs, growing expectations from consumers and emerging legislation such as RoHS and WEEE, the makers of electrical and electronic equipment are beginning to introduce changes in their product designs to ensure they meet legislative requirements and better facilitate recycling.
This trend is driving the evolution of the electronics industry's overall approach to product life cycle planning moving from a "cradle to grave" (that is, landfill) to a "cradle to rebirth" mentality (alternatives to landfills, like remanufacturing, refurbishment and recycling).
WEEE provides rules and regulations that govern product design, information for users, waste treatment, financing, penalties, inspection, recovery and collection. In doing so, it discourages the disposal of waste in landfills by encouraging a movement up the waste hierarchy, toward greater product recycling and reuse. Placing responsibility for the safe disposal of products on OEMs will further drive them to design and produce equipment that is more environmentally friendly overall.
That said, WEEE is not currently generating the same level of industry buzz as RoHS, even though compliance with this legislation requires a good deal of planning and promises to present its own share of complex challenges.
WEEE challenge
In future, it will be necessary to offer very specific information on the materials and components used in OEM equipment, and to state the location of any dangerous substances found within it. This information would then be used to facilitate the treatment and reuse of products, and would be made available to any organization involved in the treatment and refurbishment of electrical/electronic waste.
It's important to note that OEMs will not be required to disclose proprietary information or full dismantling instructions for every piece of equipment, or to provide complete lists for every component part. There may, however, be increasing requirements in future.
Currently, various steps need to be taken to ensure compliance with WEEE depending on whether an OEM has a business-to-consumer or a business-to-business model. For example, importers need to register in each member state to which they ship product, and need to engage with an end-of-life partner to process electronic waste.
In addition to the EU's RoHS and WEEE legislation, there are other emerging regulations driving OEMs toward a green future. The most talked-about currently is China's version of the EU's RoHS legislation the Ministry of Information Industry's Cleaner Production Promotion Law. Scheduled to be enacted on March 1, 2007, this legislation differs from the EU's in several ways, the most overarching being its more encompassing nature.
In addition to banning six hazardous substances, the law, often referred to as "Chinese RoHS," will cover elements similar to the EU's WEEE and EuP (Energy using Products) legislations, promoting a more holistic approach to environmental responsibility.
For its part, the EuP directive, which is also due to be enacted next year, will be the first law to require the electronics industry to produce more energy-efficient products and mitigate negative environmental impact throughout the entire product life cycle. Essentially, EuP products will be designed, manufactured and operated with a focus on ease of end-of-life management.
Also on the horizon is Reach the EU's regulatory framework for the registration, evaluation and authorization of chemicals. It too is scheduled to be made law in 2007. The overall impact on the electronics industry specifically has yet to be determined.
A new era
In keeping with the industry's growing cradle-to-rebirth mind-set, the ideal future state will see:
- Electronic equipment designed and manufactured in an environmentally responsible way.
- Less-toxic products being placed on the market.
- Avenues such as returns, repair, reverse-engineering, remanufacturing, refurbishment, rekitting and recovery leveraged instead of disposal or recycling.
- Product recycling, or the breakdown of equipment into raw materials, considered only when all other avenues have been exhausted.
A cradle-to-rebirth philosophy offers a number of environmental and business benefits:
- In the preliminary stages of design, the environmental impact of component selection, energy usage and design for de-manufacturing are already considered.
- New-product introduction activities can leverage the information obtained during repair cycles to potentially lengthen product life span and minimize repair loops.
- An understanding of product markets and distribution channels can enhance companies' grasp of how product refurbishment and upgrading can benefit emerging markets. There will be a significant opportunity to support market growth in these regions with reuse solutions that meet growing demand for product.
- Since the majority of existing high-tech installations are in North America and Western Europe, remanufacturing can be done in relatively high-cost geographies to limit freight-forwarding charges to lower-cost facilities. This may be the next manufacturing opportunity for North America and Western Europe.
- In a reuse scenario, the only real cost is manufacturing value-add, as raw-material costs are covered when products are initially put on the market.
- Since new raw materials are not mined, the remanufacturing, refurbishment, repair and redeployment of electronic equipment will be the most environmentally conscious solution to end-of-life management.
New role for EMS providers
In an era in which the environmental impact of products is becoming increasingly tied to a company's brand and image, it's unlikely that brand-conscious OEMs will want their end-of-life products managed by an unknown source. This is driving concern in the industry around sourcing reputable and dependable partners to handle such activities.
As part of Celestica's preparation for RoHS, our Green Services team has been gathering information on behalf of our OEM customers and maintaining databases of component material content. This activity has helped us to prepare for the materials-declaration requests we expect to receive, help our customers demonstrate their compliance with RoHS and make data available for recycling initiatives.
In keeping with the ongoing trend toward deeper (end-to-end) outsourcing in the electronics industry, emerging environmental legislation presents an opportunity to leverage trusted OEM/EMS relationships to manage environmental compliance and end-of-life management. By ensuring customers' ability to meet legislative deadlines, and by reducing the time, investment and in-house resources required to manage the sweeping changes facing the electronics industry, EMS providers with environmental-services offerings will enable OEM customers to concentrate on the core aspects of their business, such as the new products that differentiate them in the marketplace.
Environmentally forward-thinking EMS providers are uniquely positioned to offer the necessary support for OEMs striving to comply with RoHS and WEEE. Service offerings such as refurbishment, recycling, repair, redesign and remanufacture will be key drivers in the electronics industry's transition to environmental compliance.
Marjory Craw-Ivanco is director of engineering, lab and green services at Celestica Inc.
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