The Waste Electrical and Electronic Equipment (WEEE) Directive 2002/96/EC of the European Union aims at minimization of the impact of e-waste (discarded or end-of-life electrical or electronic equipment [EEE]), on the environment by increasing re-use and recycling and reducing the amount of WEEE going to landfills. It is closely linked to the Restriction of Hazardous Substances (RoHS) Directive 2002/95/EC which seeks to limit the presence of six hazardous materials in electrical and electronic equipment.

There are several categories of electronic waste or e-waste that fall under the WEEE Directive: large and small household appliances as well as consumer products are included. E-waste in this directive means electrical and electronic equipment (EEE) designed for use with voltage ratings of up to 1000V ac or 1500V dc. Hence manufacturers of most electronic consumer goods used in day to day life, fall under the purview of the directive. Since the consequences of non-compliance are serious (including possible ban on doing business in EU countries), manufacturers need to be conversant with the WEEE and the related RoHS directives.

The WEEE Directive seeks to minimize the environmental impact of e-waste by mandating its collection, treatment, recovery and/or recycling should be facilitated and financed by producers. It also proposes that consumers be able to return their waste equipment free of charge. Manufacturers, therefore, need to assess the impact of these requirements and initiate appropriate action for implementation.

This involves setting up collection centers for e-waste, arrangements for transportation to the recovery and/or recycling centers, facilities for recycling and determination of final disposal options. Recovery and recycling of electronic waste is specialized work and recycling plants must conform to certain minimum standards.

Operation of captive recycling facilities may be both uneconomical and beyond the core competence of equipment manufacturers. Hence suitable tie-ups with external recycling establishments may need to be entered into by manufacturers, either singly or through collective arrangements. The foregoing are post-sales activities.

It is very important for a manufacturer to also understand the importance of certain pre-sales actions which impinge upon compliance significantly. These are actions at the design and manufacturing stages.

First is the effort to design equipment which can be dismantled into the smallest possible parts and components. This will facilitate recovery of the parts for reuse; a more economical proposition than say, recycling.

Second, manufacturers must ensure labeling of products is in line with the requirements of the WEEE Directive including a "Do Not Landfill" note.

Third, reduction of hazardous material content in the product greatly reduces the need for expensive recovery efforts. It also contributes to overall environmental conservation. For this reason, the importance of RoHS compliance of products and processes cannot be over emphasized. The sooner manufacturers recognize this fact; the better their profits will be long term.

The WEEE 2002/96/EC Directive is not a law and individual EU member states are to incorporate its provisions into their own legislations. Since differences in the laws across the EU member states are inevitable, multi-national manufacturers may need to develop innovative compliance solutions.

Further, the WEEE Directive is based on Article 175 of the EC (European Community) Treaty - the Treaty establishing the European Union. This allows member states to include additional products as long as they countries adhere to European Community laws governing overall trade and commerce within and beyond the EU. Manufacturers must stay abreast of more environmentally sound practices and current WEEE changes. They also need to be aware of the implication of such changes on their businesses.

About the Author

Sandra Noble, president, Noble & Associates Consulting: I.T. Strategy Analysis/Assessments, Software Evaluation ERP/Oracle/SAP and the cure for Post Implementation Distress

Noble Finances: A/R Financing, Equipment Leasing and Lawsuit Funding