FAQ
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WEEE related questions

  • What is WEEE?
  • Why do we need the WEEE directive?
  • Which products are affected under the WEEE directive?
  • How will WEEE from business users be collected?
  • ‘According to WEEE, all EEE put on the market after 13 August 2005 must be marked as required by national legislation implementing the WEEE directive.’ How can manufacturers prepare for the marking compliance for the products manufactured before that day but possibly put on the market after that day?
  • Location of the marking: should the mark be labeled on the accessories? If so, what is the scope of accessories?


RoHS related questions

  • What is RoHS?
  • What are the substances referred to in the RoHS directive?
  • Where are banned materials used?
  • What are the benefits of the RoHS Directive?
  • What if I need to maintain or repair my present equipment after July 2006?
  • Are there any exemptions?
  • What about low levels of the restricted substances, which may be found naturally in particular materials or components?
  • Can we continue to sell products containing the restricted substances outside Europe?
  • How will compliancy with RoHS directive of HKAEL products will be identified?
  • How will compliancy with RoHS directive will be demonstrated?
  • What is the HKAEL approach on part numbering?
  • Does the RoHS directive only refer to lead?
  • What are the important issues relating to lead-free solder?
  • Is the RoHS legislation global?
  • Do distributors have a role to play?


General questions

  • Who is affected by these directories?
  • What are we doing to help you?
  • Are the 2 directives related?
  • Are the WEEE/RoHS directives just local directives?
  • Will prices increase?
  • Who can I contact to receive Weee/RoHS compliance information for a given product?


FAQ European Commission


1. What is RoHS?
The European Union (EU) Directive on the Restriction of certain Hazardous Substances. This bans the use of certain substances in electrical and electronic equipment products placed on the European market after July 2006.

RoHS_Directive.pdf   RoHS_Chinese.pdf

 


2. What are the substances referred to in the RoHS directive?
Cadmium (Cd), mercury (Hg), hexavalent chromium (Cr (VI)), polybrominated biphenyls (PBBs) and polybrominated diphenyl ethers (PBDEs) and lead (Pb).

 


3. Where are banned materials used?
Mercury: Thermostats, sensors, relays in switches and discharge lamps.
Lead: Soldering of printed circuit boards, glass for cathode ray tubes and light bulbs.
Cadmium: Switches, springs, connectors, housings and printed circuit boards.
Hexavalent Chromium: Metal coatings for corrosion protection and wear resistance.
Polybrominated biphenyls and diphenyl ethers: Flame retardants in printed circuit boards, connectors and plastic covers

 


4. What are the benefits of the RoHS Directive?
The extraction of these raw materials and their eventual disposal, can cause damage to both the environment in terms of pollution, as well as to human health from occupational exposure and exposure following disposal. The removal of these materials from production will reduce the health risks of exposure, particularly for children, the elderly and pregnant women.


 


5. Who is affected by these directories?
Anyone that:
Manufactures and sells electrical and electronic equipment within the specified categories under his own brand
Sells equipment produced by other suppliers under their own brand.
Imports (or exports) affected equipment into European Union (EU) member states.

will be affected by both directives.
It is expected that from August 2005, such producers will be responsible for financing the collection of waste electrical and electronic equipment from central points, specialist treatment, and meeting targets for re-use, recycling and recovery.

 


6. What if I need to maintain or repair my present equipment after July 2006?
The use of "banned" substances (lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls and polybrominated diphenyl ethers) in spare parts to repair equipment put on the market before July 2006 will be permitted, but will not be allowed in new equipment.

 


7. Are there any exemptions?
The Annex of RoHS Directive lists a number of exemptions where the restricted substances can continue to be used. This list of exceptions can be reviewed at European level. Additional exemptions can be proposed when the elimination or substitution with other substances is technically or scientifically impracticable or would cause other undesirable impacts. However, this review process will take time and any further exemptions will need to be supported sufficient and suitable evidence. It will need to be agreed at a European level.

 


8. What about low levels of the restricted substances, which may be found naturally in particular materials or components?
The Directive recognizes that low levels of the restricted substances may be found in electrical products or components. A committee at European level has established maximum concentration levels of the restricted substances, which allow certain minimum levels to exist in products (MAV).

 


9. Can we continue to sell products containing the restricted substances outside Europe?
As the ROHS Directive is a European Directive, it will be implemented in all European Member States. Countries outside the European Union will not need to impose the same restrictions however they may choose to do so under their own domestic legislation.

 


10. How will compliancy with RoHS directive of HKAEL products will be identified?
Our Target is to clearly identify HKAEL materials that are in compliance with the RoHS directive. This will be done by a label on the individual packaging of the product stating “Compliant to EU directive 2002/95/EC RoHS”.

 


11. How will compliancy with RoHS directive will be demonstrated?
Evidence of compliance will only be required if an enforcement authority asks for it, but they will expect to see evidence that the producer has taken what will be regarded as “reasonable steps” to comply with legislation.
If the “producer” imports electrical and electronic equipment into the European Union then, in theory, he would ask his supplier for a declaration that that the equipment complies.
If the producer assembles equipment within the EU, then he should obtain a declaration for all the parts, components and materials he uses and this information would be stored in a technical file.
One certificate or declaration is enough for each class or type of component, for example all chip resistors of one type irrespective of size or value could be covered by one declaration as long as they have similar composition and all are RoHS compliant.

 


12. What is the HKAEL approach on part numbering?
The HKAEL items that comply with the RoHS directive will keep the same name.
Non-compliant products will be replaced by a compliant alternative with another part number. Doing so will guarantee that our customers do not receive mixed deliveries.

 


13. Does the RoHS directive only refer to lead?
Lead is just one of several banned substances in the RoHS Directive. While the industry has adopted the terminology of "lead free", removing lead alone will not achieve RoHS compliance.

 


14. What are the important issues relating to lead-free solder?
Compatibility
Soldered surfaces must be free of lead to begin with. This includes the PCB as well as the component. Lead contamination on a lead-free solder joint will significantly reduce the reliability of the joint.
Temperature
All lead-free alloys melt at a higher temperature than traditional tin-lead alloys. The temperature of the soldering iron may need to be increased, and both the components and PCB will need to withstand these higher levels. Increased temperatures also place a greater demand on the flux, and it may be necessary to opt for a higher solids content, or more active flux if the soldering becomes difficult when using lead-free materials. Typical melting points:
Tin-Copper 227°C
Tin-Silver 221°C
Tin-Silver-Copper 217°C
Tin-Silver-Bismuth 205°C to 215°C
Tin-Zinc 199°C
Tin-Lead 183°C
Tin-Bismuth 138°C

Inspection
Lead-free solder joints have a different appearance to those of tin-lead. They are usually quite dull, and the spread is less, resulting in fairly steep contact angles at the perimeter of the solder joint, where the solder meets the substrate. This does not mean that the joint is faulty. Studies suggest that a lead-free solder joint is even more reliable than the equivalent tin-lead joint.

Rework or repair
Repair or rework should also be carried out using lead-free solder. It is necessary to be sure which solder has been used before attempting to rework it. Alloys used in lead-free solder can vary depending on the application, but it is generally felt safe to use tin-copper for lead-free hand soldering.

 


15. What are we doing to help you?
We will provide you with compliant products before the final effectivity date. Doing so we help our customers to fill their supply chain with compliant products before the RoHS start date of July 1, 2006.
HKAEL has setup a strong organization focused on these WEEE/RoHS directives. We are able to answer your specific questions in a reasonable time. We have been gathering information for several months and put it into databases for global use.

 


16. What is WEEE?
Waste from Electrical and Electronic Equipment.
Deals with the best available treatment, recovery & recycling of electrical and electronic equipment. Legislation becomes effective Aug 13, 2005. All EEE put on the market as from that date have to be WEEE marked (EN50419) and have to be collected after the products end of life.

WEEE_Directive.pdf   WEEE_Chinese.pdf

 


17. Why do we need the WEEE directive?
In Europe, over 90% of electrical and electronic equipment goes into landfill sites - around 6 million tones of waste every year. Emissions to the air that result are a risk to both health and the environment.

 


18. Which products are affected under the WEEE directive?
Large domestic devices (refrigerator, washing machine, microwave, … )
Small domestic devices (vacuum cleaner, iron, hair dryer, …)
IT & remote communication device (mainfraime, PC, … )
Consumer devices (radio, TV, video, audio, … )
Illumination (fluorescent, discharge lamp, … )
Power Tool (drill, lathe, polishing tool, lawnmower, … )
Toys (train/car racing set, game devices, … )
Medical devices (radiation therapy device, electrocardiogram, … )
Measure & controller (scale, measuring machine, … )
Vending machines (various)

 


19. How will WEEE from business users be collected?
Producers will need to establish or contribute to collection schemes that allow businesses to return their WEEE.

 


20. ‘According to WEEE, all EEE put on the market after 13 August 2005 must be marked as required by national legislation implementing the WEEE directive.’ How can manufacturers prepare for the marking compliance for the products manufactured before that day but possibly put on the market after that day?
The way Article 11(2) is drafted assumes that the mark will not be applied when the product is manufactured but at the time it is put on the market. This poses an issue in particular in the transition phase for EEE manufactured between now and the effective date of the marking requirement, i.e. 13 August 2005. Manufacturers will have to devise systems (i) for determining when EEE is put on the market, and (ii) if that happens after 13 August 2005, for applying the required mark to the EEE. For EEE manufactured after 13 August 2005, this is not much of an issue, as the EE can be labelled at the manufacturing stage (since it cannot possibly have been put on the market before 13 August 2005 and thus be exempt from marking).

 


21. Location of the marking: should the mark be labeled on the accessories? If so, what is the scope of accessories?
This is still unclear. At the very least, the body of the EEE must be labeled. A future European standard may provide clarity on this issue.

 


22. Are the 2 directives related?
Yes. The WEEE Directive aims to raise levels of recycling of WEEE and encourage products to be designed with dismantling and recycling in mind. A key part of this is to make manufacturers and importers (“producers”) of electrical and electronic equipment responsible for meeting the costs of the collection, treatment and recovery of WEEE. If products are designed with this in mind, there is an opportunity to reduce these costs. The ROHS Directive fits into this by reducing the amount of hazardous substances used in products. This reduces the risks to recycling staff and means that less special handling is required, again leading to a reduction in recycling costs.

 


23. Are the WEEE/RoHS directives just local directives?
"Single market" Directives such as RoHS apply to all EU member states and must be implemented in the same way to prevent differences in interpretation across the member states. The WEEE Directive is not a single market Directive; it sets minimum criteria for the collection of waste that member states may exceed if they wish. The RoHS directive is a single market directive, since it sets product standards.

 


24. Is the RoHS legislation global?
While the implementation deadlines form part of EU legislation, the need to comply will evolve globally. Japanese manufacturers have been reducing lead levels for 3 or 4 years and, in the USA, California has already passed legislation to fall approximately in line with the EU timescales. It is unlikely that electronics manufacturers will make "lead free" components for Europe and lead-based components for the rest of the world.

 


25. Do distributors have a role to play?
As a major partner of HKAEL, our distributors have an important role to play in this process. They will receive and forward requests from their clients, and inform them on the compliancy status of the different products referring to the information they receive from HKAEL. Later on they will pro-actively inform their clients regarding compliancy of HKAEL products with these directives. This of course will be done in close cooperation with the HKAEL project teams.

 


26. Will prices increase?
WEEE
The cost for collection of WEEE is at this moment totally unclear. HKAEL awaits the different country specific financial setups for collection schemes. The effect of WEEE on the product price is therefore at this moment unknown.
ROHS
The European Commission estimates an average cost increase of between 5% to 10% for most EEE products in order to get products RoHS compliant and 10 to 20% for a few large or more complex products. However, HKAEL products that are already compliant will not increase in price related to RoHS activities. When a product is not compliant, any change in price, will depend on the difference in cost of the alternative solution.
The cost for collection of WEEE is at this moment totally unclear. HKAEL awaits the different country specific financial setups for collection schemes. The effect of WEEE on the product price is therefore at this moment unknown.

 


27. Who can I contact to receive Weee/RoHS compliance information for a given product?
Different project teams have been established to address all aspects of these directives. These teams consist of key people from different areas. To facilitate the communication about WEEE/RoHS with our customers we established a local coordinator for every location. Should you have any questions or require further information, please contact your sales representative or the local WEEE/RoHS coordinator.