Categorically speaking, the RoHS isn’t complying with its own rules
When the ROHS WEEE directive first came into force, some mechanical designers were delighted to find their products were exempt from the ruling. However, the expiry dates for many of these exemptions has expired, and many more are due to expire in 2011. This is not the way it was originally going to be. Companies with well organised enterprise data management systems, using compatible part obsolescence management tools, will be aware of this. They will have amended their system designs to use alternative components, or found component engineering companies able to fashion RoHS compliant versions of components made obsolete by the RoHS ruling. However, a lot of others will be in the dark; they may not even realise their exempt products had an expiry date. In July 2006 the EU commissioned a study into the application of the RoHS directive to products in Categories 8 and 9. At the time, the final report stated products would remain exempt until 2012 or 2018 depending on specific criteria. However, the goalposts have not so much been moved as shifted to another playing field since then. Many exempt products were re-evaluated and as a result their exemption dates expired earlier this year. Many more are due to expire in 2011, and there are few if any products with an expiry date of 2018. We at Enventure Technologies will be the first to admit that that RoHS compliance is a confusing and complex area. This is why we specialise in environmental compliance management solutions for engineering companies such as yours. We offer a range of high value engineering services including obsolescence management, BOM management, component engineering and data cleansing solutions.
The ROHS directive Category 8 and 9 – where are we now?
There is still much confusion over the RoHS directive in mechanical engineering companies, especially with respect to the category 8 and 9 exemptions. These were hardware devices which: 1) Generally had a long lifespan and were manufactured in small amounts. 2) Were often used in mission-critical applications where their failure would have catastrophic effects. The reliability of lead-free components and solders was unknown (five years being the minimum period for risk assessment) and so these products were made exempt. The exemptions covered mainly the medical, military/defence, monitoring/recording and telecommunications fields. However, the exclusions were only temporary, lasting as long as it took for RoHS compliant alternatives to be quality assessed. Mechanical engineering companies must not get complacent just because they manufacture medical or aerospace equipment on the exclusion list. This list is constantly being reviewed, with products being deleted at regular intervals, either due to re-evaluation or because the expiry date has passed. The EU recently published an updated list of the exemptions that had either expired or been removed. They included: Lead in RIG (rare earth iron garnet) Faraday rotators of fibre optic communication systems. DecaBDE in polymeric applications. Lead solder in transducers of high-powered loudspeakers. Hexavalent chromium used in corrosion protection and Electromagnetic Interference Shielding of certain IT and telecommunications equipment. Cadmium optocoupler photoresistors used in professional audio equipment. Mercury as a cathode sputtering inhibitor in DC plasma displays. It is essential your obsolescence management is up to scratch in order to keep ahead of RoHS and REACH compliance issues. Luckily, we at Enventure technologies have obsolescence management tools and master data management services to keep you totally RoHS compliant.
Getting up to speed on ELV compliance
Automotive recycling was always a lucrative area for those in the trade. 75% of each car was easily turned into cash, with healthy returns on scrap metal, part-worn tyres and second-hand automotive components. However, the new ELV directive is calling for at least 85% of each vehicle to be recycled, which means recycling plastics, which isn’t traditionally a money spinner. Automotive plastic recycling is still in its infancy and, currently, there is no proven technology in common use. However, several mechanical design firms in the EU have come up with their own solutions, which they have sold on, so there is a profit there somewhere. In the Netherlands, the 85% minimum target has been met courtesy of impressive government subsidies. In countries where such funding is not forthcoming, such as the UK, firmware development and mechanical engineering companies are working to create affordable, compliant recycling solutions. ELV compliance is one of three EU rulings specific to the automotive industry. However, the ELV directive is the most expensive to implement. The days of the local scrap dealer making a sideline in second-hand auto parts is spent. Any company handling end-of-life vehicles today must be an Authorized Treatment Facility (ATF), investing in specialised plant machinery and with facilities for removing hazardous residues as per REACH regulations. The site must have a complex infrastructure to ensure it achieves the standards required for ATF licensing. If you are finding ELV compliance a problem, we at Enventure Technologies have master data management and cost reduction consultants to help you.
Recycling an end-of-life vehicle – more than just a metal cube
The complex new GADSL, ELV and REACH directives mean heavy work for vehicle dismantlers, or rather, Authorized Treatment Facility engineers. It goes a lot further than simply “cubing” a car that failed its MOT test. So, what is involved when a car reaches the end of its life, or in other words, becomes an ELV, or end-of-life vehicle? ATF plants have to dispose of all hazardous materials, and recycle at least 85% of the rest. The first thing to be removed is the battery, then the fluids; engine oil, fuel, hydraulic fluids, anti-freeze, and even the windscreen wash. Holes are drilled to facilitate this, with oils and fluids suctioned or drained into special containers. Recyclable components such as tyres are also removed. This all sounds familiar, but ELV, GADSL and REACH regulations mean extra care with hazardous components. Lead balancing weights, mercury-rich internal switches and trims containing hexavalent chromium must all be removed and disposed of in an environmentally compliant manner, such that they do not re-enter the supply chain as recycled goods. Other physically hazardous components, such as air bags and seat-belt pretension mechanisms, must be removed or made inactive. The car must be totally safe before being sent for further recycling. There, things become more complex, with a drive to recycle everything, from plastic fascias to fabric upholstery. ATFs invest large sums of money to reach ELV compliance. Mechanical engineers, FPGA design consultants and system development teams are working overtime to get novel recycling patents off the ground. We at Enventure Technologies can help, offering manufacturing support at every level.
Taking the initiative on ELV compliance
The most easily recyclable part of a motor vehicle is its metal component, but there’s a lot more to a modern car than that. Although scrap yards recycle as much as they can (tyres, useful engine components etc), a significant amount of the average ELV, or end-of-life vehicle still ends up in landfill sites. Much of this content contains substances, such as lead, which are hazardous to the environment and our health. For this reason, the ELV directive was introduced. The ELV directive was imposed by the EU to ensure a minimum level on vehicle recycling, and in a sustainable fashion. Introduced in 2000, and legally implemented in 2006, the ELV directive states that at least 80% of each ELV vehicle in the EU must be recovered for recycling, with a further 5% retrieved for use in energy-recovery processes. By 2015, these environmental compliance figures will rise to 85% and 10%. An ambitious plan, fraught with difficulty, the status report for November 2005 stated that although most member states were trying to achieve ELV compliance, the targets were far from being reached. A lot of the problem lay in the plastic component. Metal, fuel, tyres, fluids, batteries etc can all be recycled easily. However this still left a shortfall of around 5% to meet the EU target. At present, a number of mechanical engineering companies are working on systems to recover automotive plastics. We at Enventure Technologies offer a range of ELV compliance solutions, from master data management for recycling plants, to 3d modelling of novel hardware to furnish those plants.