Harvey Miller has recently posted a discussion of recent changes to the
European legislation relating to lead and other "hazardous substances". (For
those who have not been following this activity closely, the previous draft
directive on "Waste Electrical and Electronic Equipment" was split into two:
one, retaining the original title and emphasizing reuse and recycling, and
the other, commonly referred to as "Restriction on Hazardous Substances"
(RoHS) that contains the ban on substances.)
Mr. Miller states that the RoHS draft directive as now written contain
"loopholes" that "may delay any real implementation or enforcement of the
ban on lead in electronics forever." I wish that I could agree that things
look that hopeful. What I read, however, makes me pessimistic. Here's what I
see:
*       RoHS Amendment 4 Recital 9 b (new): "The scope of the Directive
should , in the future, be expanded to include other hazardous substances"
... including "other halogenated flame retardants".
*       RoHS Amendments 10 and 22 Article 4: "The European Parliament and
the Council shall decide ... on the prohibition of other hazardous
substances and the substitution thereof by more environment-friendly
alternatives.
*       WEEE Amendment 17 Recital 17 a (new): "The costs of collection,
treatment and environmentally sound disposal should be internalised within
the product price." This means that manufacturers are discouraged now, and
prohibited after ten years, from disclosing how much it is costing the
consumer to recycle his used electronic product. This cost must be hidden in
the overall product sales cost, presumably to prevent protests that the
benefits of recycling are not worth the cost.
*       WEEE Amendment 51 Article 9, paragraph 2: previously encouraged
consumers to recycle, now requires member states to "adopt measures to
ensure that consumers recycle" and allows member states to impose penalties
on consumers who don't comply.
*       WEEE Amendment 61 Article 14 a (new) Penalties: requires member
states to determine penalties for the breach of the national provisions that
are "effective, proportionate, and dissuasive." What happens to those
jurisdictions that fail to enforce the provisions to the liking of the
Directorate remains to be seen.

Those who care to examine the documents can go to
http://www3.europarl.eu.int/omk/omnsapir.so/pv2?PRG=CALEND&APP=PV2&LANGUE=EN
&TPV=PROV&FILE=010515 , click in left column on Use of certain hazardous
substances in electrical equipment and then on Proposal for a European
Parliament and Council directive on the restriction of the use of certain
hazardous substances in electrical and electronic equipment for RoHS and on
Waste electrical and electronic equipment for WEEE.

Gordon Davy
Baltimore, MD
[log in to unmask]
410-993-7399

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