Gordon
Of course, what will be most interesting is Amendment 5 recital 10,
stating "The technical development of electrical and electronic
equipment without heavy metals ... should be taken into account.". The
term "heavy metals" is very vague and unscientific but is most often
considered as all metallic elements or alloys containing them with an
atomic number exceeding 26 (iron). This would therefore include (amongst
many others) Ni, Cu, Ag, Sn, Au. It would be interesting to see any
electronics device not containing any of these metals!
Brian
"Davy, Gordon" wrote:
>
> 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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