RoHs directives

The second possibility is the European waste legislation, which includes the Restriction of Hazardous Substances Directive (RoHS). The RoHS Directive is closely linked with the Waste Electrical and Electronic Equipment Directive (WEEE) which sets collection, recycling, and recovery targets for electrical goods and is part of a legislative initiative to solve the problem of toxic e-waste. 

For this purpose, the WEEE Directive has been complemented with an additional directive that limits the use of certain pollutants in these products. The EC Directive 2002/95/EC on the Restriction of the use of certain Hazardous Substances in electrical and electronic equipment (RoHS Directive) ([7], recast 2011 [9]) restricts the use of the six harmful substances/substance families lead, mercury, hexavalent chromium, polybrominated biphenyls (PBB), and polybrominated diphenyl ethers (PBDE) to 0.1% and cadmium to 0.01% w/w per homogenous material in equipment and components, but with several exemptions for a wide range of applications (Annex III and IV). 

In particular, the RoHS Directive has been proven in Europe. Those substances are now banned from the products (below the limit values). In addition, the international equipment manufacturers have switched their production, not limited to Europe, but made for the world market. This in turn has led to the creation of laws similar to the RoHS regulation in other regions of the world. 

In the sector of electrical and electronic equipment, the RoHS Directive, as explained, has successfully resulted in reduction of hazardous chemicals in line with goals of the RISKCYCLE project and has reduced many problems. This raises... 

Article 6 of the RoHS Directive (recast 2011 [9]) says 1. With a view to achieving the objectives set out in Article 1 and taking account of the precautionary principle, a review, based on a thorough assessment, and amendment of the list of restricted substances in Annex II shall be considered by the Commission before 22 July 2014, and periodically thereafter on its own initiative or following the submission of a proposal by a Member State. .. . 

Furthermore, the instrumentation of the RoHS Directive has to be considered in this context. The Directive is targeting a clearly structured business sector with very few clear substance bans (or more precisely limits). For the regulated pollutants in turn very unique risk considerations are possible. Without an extension of the instrumentation to a more sophisticated control system, the complex (chemical) process cannot be reproduced in other sectors. 

Since the implementation of the RoHS Directive, many problems have already been addressed and hazardous components have been limited or banned. The outcome of the RISKCYCLE project and further research initiatives could be a reason to extend the scope of the directive either by a broader scope (not only electrical and electronic equipment) or by extending the catalogue of restricted substances (Annex II of the Directive). 

The RoHS Directive was a major catalyst for research and adoption of lead-free solutions in electronic equipment. Alternatives to lead in soldering range from tin (Sn), silver (Ag) and copper (Cu) to bismuth (Bi) and zinc (Zn). These heavy metals do not have the same toxicity and bioaccumulation potential of lead (Pb). ... 

On the basis of RoHS, practically all PBDPE were banned, however article 6 of the RoHS requires the European Commission (EC) to carry out a review of the RoHS directive and to consider any changes that are needed. The review started in 2005 and all aspects of the directive have been considered. There have been stakeholder consultations and studies by consultants into several aspects of RoHS. The Commission published its proposals on 3 December 2008. The main changes are as follows. 

Unlike in the original RoHS Directive, the European Commission now has to take into account the aims of the Lisbon strategy so that development of an environmental strategy also considers growth and employment. Another fundamental change is that RoHS substance restrictions would be imposed only if there is an unacceptable risk to human health and the environment, whereas previously it was based only on the precautionary principle. 

The predominant regulations in the EU impacting flame-retardants have been the Restriction of the Use of certain Hazardous Substances in Electrical and Electronic Equipment (RoHS) Directive, Waste of Electrical and Electronic Equipment (WEEE) Directive, and more recently the REACH Regulation. While RoHS and WEEE only deal with electrical and electronic equipment as defined in the directives, REACH impacts all substances manufactured and used in the EU. 

Discussions and debate related to the inclusion of deca-BDE in the RoHS Directive have been going on for years. It was originally planned that the inclusion of deca-BDE in the RoHS Directive was to be addressed upon completion of the results of the EU Risk Assessment. With a conclusion that there was no need for restrictions, eca-BDE was exempted from the provisions of the RoHS Directive for polymer applications on October 15, 2005. Confusion centering on what was meant by deca-BDE (commercial product with minor impurities or pure congener) came up in the summer of 2006. Since the commercial deca-BDE was the material evaluated in the EU Risk Assessment, major parts of the chemical, polymer, and electronics industries and significant elements within the EU shared this view. 

On April 1, 2008, the European Court of Justice ruled that the European Commission used improper procedures to exempt deca-BDE from RoHS Directive. The ruling did not question positive EU Risk Assessment outcome of deca-BDE. The outcome of this April 1 ruling was that deca-BDE was banned in the use of electronic and electrical equipment after June 30, 2008. 

There is now discussion as to whether more substances, including other flame-retardants, should be added to the RoHS Directive. The history of the RoHS Directive and potential additions raises some very real concerns over the fundamental relationship between results of risk assessments under regulation 793/93, REACH registrations and evaluations, and the RoHS Directive. Consistency is needed between the REACH Regulation and the other EU directives. REACH evaluations will determine whether restrictions are necessary in all applications including electronic applications, and where authorization for use is necessary. 

Challenges and innovations are also made by the private sector. Responding to strict regulations introduced by the European Union (EU), in particular responding to the RoHS directive that entered into force in July 2006, many manufactures of electric appliances eliminated designated chemical substances from their products. 

Panasonic is still a front runner in the field of lead-free challenges. It has announced that lead was now elimnated from their plasma display panel (PDP), which is currently one of the exceptional items of RoHS Directive. 

Furthermore, from a regulatory vantage point, it can be mentioned that several risk reduction measures have been taken for these chemicals both within the European Union and in international conventions. The use of Penta, Octa and Deca in electrical and electric equipment is, for example, restricted in EU legislation through the RoHS Directive (2002/95/EC). Penta is also included (and Octa is suggested for inclusion) in the Stockholm Convention on persistent organic contaminants. Thus, decision-makers appear to have treated the available and often uncertain information on Penta, Octa and Deca as if their properties, use and emission were known to pose intolerable risks (at least to the extent reflected by the above described risk reduction measures). 

In 2004, Sony and Mitsubishi Plastics teamed up to develop a flame retardant PLA biodegradable resin claimed to be as strong as ABS. The new material will be used in the front panel of Sony standalone DVD players. The resin employs an aluminium hydroxide flame retardant, is rated UL94 V-2 and complies with the EU s Restrictions on Hazardous Substances (RoHS) directive. Sony says the use of additives and modifications to moulding parameters allows it to process PLA compound on conventional injection presses in commercially viable cycle times. 

The Legislative History of Deca-BDE in the European Union and within the Restriction on Hazardous Substances (RoHS) Directive, CPA, 2005. 

In the case of green chemistry, and more especially chemical substitution, a number of policy instruments are relevant. The traditional approach is to ban certain toxic chemicals in order to induce substitution efforts. Such bans are usually preceded by examples of successful substitutions, as it is controversial to ban chemicals when no alternatives exist at reasonable cost. Otherwise, industry is often granted generous phase-in periods, in order to develop substitutes. A third way is to grant derogations when it is hard or very costly to develop substitutes. The latter approach has been applied in the context of the EU Restriction of Hazardous Substances (RoHS) Directive (Directive 2002/95/EC), which bans six substances in electrical and electronic products. A slightly less interventionist approach is to put restrictions on uses of certain chemicals. Other administrative approaches include the ban of chemicals, or restrictions in use, in individual operations when these apply for permits. 

For example, the electronics industry was adamant that the material phase-outs stipulated within the Restriction of Hazardous Substances (RoHS) Directive for new electrical and electronic equipment must apply equally across Europe. In a joint letter to the Commission sent by leading producers, they urged a clear legal basis for the RoHS directive, so as to provide a high level of protection for citizens without creating uncertainty for business and undermining the Single Market (EC, 2001). 

EC (European Commission), Joint letter by Electrolux, HP, ICL, Nokia, Ericsson, Agilent, IBM, Gillette, Sun Microsystems, and Intel to the European Commission, 2001, concerning the WEEE and RoHS Directives, 2001. 

There is also the EU Restriction of the Use of Certain Hazardous Substance Directive (RoHS) in electrical and electronic equipment which bans new electrical and electronic equipment with more than agreed levels of cadmium, hexavalent chromium, lead, mercury, polybrominated biphenyls (PBB) and polybrominated diphenyl ether (PBDE) flame retardants, in the EU. The RoHS Directive and the UK-RoHS regulations came into force on 1st July 2006 [9]. To prevent the generation of hazardous waste, the Directive 2002/95/EC requires the substitution of all heavy metals (cadmimn, hexavalent chromium, lead and mercury) and brominated flame-retardants (PBB or PBDE) in new electrical and electronic equipment sold as of 1st July 2006 [10]. 

As representative environmental laws in the EU, four items can be mentioned RoHS directive, WEEE directive, ELV directive and REACH regulation. 

RoHS directive stands for Restriction of the use of certain Hazardous Substances in Electrical and Electronic Equipment. The purpose of the directive is to control the use of certain hazardous chemical substances such as mercury, cadmium, lead, hexavalent chromium, polybrominated biphenyl (PBB) and polybrominated diphenyl ether (PBDE) for electrical and electronic equipment. In the EU, no one is allowed to place electric and electronic equipment on the market that would include those hazardous substances exceeding a certain limit. The regulation values are mentioned in Table 2. 

European commission (2015) RoHS directive, http //ec.europa.eu/environment/waste/rohs eee/ index en.htm... 

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