The European Union's current 15 member states have until Aug. 13 of this year to determine how they will implement the directives on Waste Electrical and Electronic Equipment (WEEE) and on the Restriction of the Use of Hazardous Substances in Electrical and Electronic Equipment (RoHS), which became effective Feb. 13, 2003.

U.S. electronics manufacturers, electronics recyclers and legislators will likely watch the WEEE implementation process closely. The directive will spur further discussion of electronic scrap management in the U.S., offering a legislative model governing the disposal of electronic waste.

The WEEE and RoHs Directives, however, will tangibly impact electronics manufactures that sell products in the EU as they implement design changes, address funding and collection issues and prepare for reporting responsibilities. Eventually, the design changes set forth by the RoHs Directive will affect U.S. electronics recyclers as these products reach the end of their life spans. (Though some observers believe at that point, the U.S. might have a nationwide regulation of its own.) But the ramifications on U.S. consumers are still uncertain.

MANDATING CHANGE. The WEEE Directive covers 10 product caregories--large household appliances, small household appliances, information and telecommunications equipment, consumer electronics, lighting, electronic tools, toys and sports equipment, medical devices, monitoring instruments and automatic dispensers--and establishes a financing mechanism based on extended producer responsibility to fund the recycling of these products. Producers can address financial responsibility for managing their end-of-life branded products individually or collectively.

The costs associated with the management of historical products, or those products that reach market prior to Aug. 13, 2005, will be shared by all the producers in operation at the time those costs are incurred. Producers can charge a fee to cover these costs for 10 years in the case of large household appliances and for eight years in all other categories. Each producer will bear individual responsibility for its products produced after Aug. 15, 2005, with no visible fee to fund waste management permitted.

The first performance deadline will be Dec. 31, 2006. At this time, member states will need to have collected about four kilograms, or nearly nine pounds, of end-of-life electrical or electronic equipment per capita annually.

The RoHs Directive regulates the use of toxic materials in electrical and electronic equipment and calls for the elimination of lead, mercury, cadmium, hexavalent chromium and two brominated flame retardants by July 1, 2006. RoHS exempts the leaded glass in CRTs, some lead solder uses and some uses of mercury in fluorescent bulbs.

INFLUENCING DESIGN. "The Rolls directive will probably set the international standard for most electronics companies, whether they are Japanese, American or European," Heather Bowman, director of environmental affairs for the Electronics Industries Alliance, Arlington, Va., says. Global marketing of electronics makes it highly unlikely that electronics manufacturers based outside the EU will establish a second product line strictly for the EU, she says.

The EIA describes itself as a partnership of electronic and high-tech associations and companies that promotes the market development and competitiveness of the U.S. high-tech industry through domestic and international policy efforts.

"Global companies such as Dell are faced with a decision of whether to provide products designed for specific markets or, as Dell has chosen, to incorporate these changes into product offerings globally," Pat Nathan, sustainable business director, Dell Inc., Round Rock, Texas, says.

"WEEE has hastened the necessity to design for recycling. I think that there is going to be a tendency in a lot of areas for OEMs to try to harmonize designs across their global marketplace," Robert Houghton, president of Redemtech, Columbus, Ohio, says.

Redemtech is a corporate asset recovery and recycling firm with joint ventures in the U.K., Europe and Canada.

The Silicon Valley Toxics Coalition, an environmental group, through its Computer Take-Back Campaign, has tracked design trends in the computer industry with its annual computer report card. "What we've been able to determine is that there are a couple of important trends going on," Ted Smith, executive director of the San Jose-based coalition, says. "One is that the mere fact of requiring take back, which is requiring companies to internalize the cost of end-of-life treatment, has been sending pretty important economic signals to the designers to make it easier to recycle." This is happening through material selection changes and through modifications to facilitate disassembly, he says.

"I think we are going to see more and more design issues that are focused not just on the materials, but also on the ease of disassembly to remove the toxic materials," Smith adds.

"Certainly, the combination of WEEE and RoHS together has led to significant changes in the use of materials," Smith says. "You see that particularly with the brominated flame retardants and with lead." He says some companies have almost entirely phased out the use of brominated flame retardants in all of their products and that the industry has also made significant progress in phasing out lead.

"Lead is the biggest challenge for all of us ... designing the lead out of the product by finding other means of soldering the parts," Nathan says. "I think the whole industry is challenged in that there is no widely accepted, proven alternative technology. While it's challenging, we're confident that we can find alternatives."

Houghton also says he thinks electronics manufacturers will begin to use modular designs that make disassembly and the separation of the various recycling streams easier. "Just standardizing plastics and labeling plastics would be a big move in the right direction," he says.

Bowman says material standardization will occur throughout the electronics industry as a result of RoHS. EIA is doing its part to aid this standardization through its development of a materials declaration guide. The organization recently completed a harmonization process with European and Japanese trade associations for electronics manufacturers, establishing what Bowman refers to as a "global standard" for declaring the content of electronic products. "It's really a consistent way to tell recyclers what is in the product, whether it is a component or the final product," she says.

"I think we have developed a good dialogue with the OEM community in the U.S. through the Electronics Recycling Summit and through the cooperation of the Electronics Industry Alliance and its affiliated members to be able to understand the new materials," Peter Muscanelli says. Muscanelli is president of the International Association of Electronics Recyclers, Albany, N.Y. The IAER represents the international electronics recycling industry as it seeks to develop an effective and efficient infrastructure for managing end-of-life electronics.

"This is a large industry and changes come in pieces," Muscanelli continues. "The more pieces we can put together, the better we are going to be."

"As companies embrace these changes, the materials available to recycle will contain less environmentally sensitive elements, and, hence, their value for reuse will be enhanced," Nathan says. "This will be an evolution, however, as it takes a number of years for products to enter the recycling stream."

Recyclers can expect a number of benefits once electronics incorporating these design changes reach their facilities at end of life. After all, that's the whole point of the directives, as Lauren Roman of West Chicago, Ill.-based electronics recycler United Recycling Industries points out.

IMPACTING RECYCLING. Reducing toxic materials used in electronics and facilitating disassembly will make the operational side of the electronics recycling industry easier and less expensive for recyclers, Houghton says.

"To the extent that folks are struggling today with low commodity costs and high operational costs, I'd expect that more recycler friendly designs will help leverage operational costs down for the recyclers and make it easier to be profitable in this part of the business," he says.

Even electronics recyclers who shred incoming streams find ease of disassembly pertinent when it comes to accessing components that contain mercury. Smith cites a Hewlett-Packard effort to make the mercury filament in its LCD backlighting more accessible and easier to remove. The company reduced the time it takes to perform this task from five or six minutes to a matter of seconds, he says.