Things You Wanted to Know, Yet Have Never Dared to Ask – RoHS (part II)

In the last issue [of the journal "Electronica"] we referred to a number of practical questions we were confronted with regarding the implementation of the WEEE Directive on Waste Electrical and Electronic Equipment, respectively of the national legislation transposing it. You need to remember that parallel to the WEEE Directive dealing with the registration and marking of electrical equipment and its collection and recycling at the end-of-life, also the RoHS Directive was legislated restricting the use of certain hazardous substances in this equipment. One can learn about the tight connection between the two directives from the Preamble of the RoHS: Here you can read that the available evidence indicates that the restriction of heavy metals and flame retardants in electrical and electronic equipment is necessary for the treatment, recycling and disposal of WEEE as set out in the WEEE Directive. Therefore, not only are the directives complementary one to the other, but they are overlapping each other. The scope of the RoHS Directive, for instance, i.e. the equipment to which the directive is applicable, is extracted directly from the WEEE Directive. Also many other definitions are identical in both directives. 

On the structural difference between the both directives we have already elaborated before. The WEEE is a framework directive setting minimum standards which have to be transposed by the member states. The RoHS, on the other hand, is a single-market directive setting uniform standards all over the EU.

In this paper, we focused on the number of practical questions we encountered during the process of preparation guidance for compliance with the directives to our clients.

The RoHS becomes effective on 1 July 2006. Unnecessary to mention that for companies exporting electrical and electronic equipment (EEE) to the European Union the remaining time is short and a lot has to be done. We recommend these companies to prepare the implementation of the requirements of RoHS already now.