On Thu, 18 Aug 2005 16:48:23 -0600, Genny Gibbard <[log in to unmask]>
wrote:

[deletia]

>Is anyone else getting the impression that WEEE is largely an
administration challenge, with technical aspects only a very minor part of
it?  Registration, reporting, determining costs, fees, volume of sales etc.
 RoHS compliance is the technically challenging one.
>
>Genny Gibbard
>

Genny,

Right now WEEE is largely administrative, since merely complying is largely
administrative and that's the deadline in everyone's face. The technical
aspects are the ones that are below the surface.

WEEE requires that your company pay the cost of "the collection, treatment,
recovery and environmentally sound disposal" of WEEE. This fiduciary
responsibility is going to bite those that think registering and paying the
fees is the end of it when they get the bill.

These costs should be understood and technical actions taken to reduce that
cost, like extending the product lifecyle through various design means,
reviewing materials that are used for recycleability and possibly replacing
them, more clearly labeling recycleable materials (e.g., plastics and
metals), and so on.

The other "technical" impact is in Article 4. Producers can not "prevent,
through specific design features or manufacturing processes, WEEE from being
reused..." A technical review of the product is required to assess this.

Michael Kirschner
President
Design Chain Associates, LLC
www.designchainassociates.com

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