WEEE and RoHS Directivesthor.inemi.org/webdownload/newsroom/Presentations/... · Professional...

WEEE and RoHS DirectivesWEEE and RoHS DirectivesImplications for Material Composition Implications for Material Composition

Data Exchange and ReportingData Exchange and Reporting

August 30, 2004Jean-Philippe [email protected]

www.allenovery.com

ALLEN & OVERY

August 30, 2004August 30, 2004JeanJean--Philippe BrissonPhilippe [email protected]

www.allenovery.com

ALLEN & OVERYALLEN & OVERY

2 ALLEN & OVERYALLEN & OVERY

OutlineOutlineOutlineSection One Background and Overview

Section Two WEEE Directive

Section Three Open Issues under WEEE

Section Four RoHS Directive

Section Five Open Issues under RoHS

Section Six Final Thoughts

Section OneSection One Background and OverviewBackground and Overview

Section TwoSection Two WEEE DirectiveWEEE Directive

Section ThreeSection Three Open Issues under WEEEOpen Issues under WEEE

Section FourSection Four RoHS DirectiveRoHS Directive

Section FiveSection Five Open Issues under RoHSOpen Issues under RoHS

Section SixSection Six Final Thoughts Final Thoughts


NoticeNoticeThis Presentation is for General

Guidance Only and does not Contain Definitive Advice

This Presentation is for General This Presentation is for General Guidance Only and does not Guidance Only and does not

Contain DefinitiveContain Definitive AdviceAdvice


Section One Section One

Background and OverviewBackground and Overview


RoHS Directive OverviewRoHS Directive OverviewRoHS Directive Overview

PbPb, Hg, Cd, Cr6+, PBBs and PBDEsPb, Hg,Pb, Hg, CdCd, Cr6+,, Cr6+, PBBsPBBs andand PBDEsPBDEs

Adopted, published and effective

Industry must comply by July 1, 2006

Adopted, published and effectiveAdopted, published and effective

Industry must comply by July 1, 2006Industry must comply by July 1, 2006

Restriction of Hazardous Substances

Electrical and Electronic Equipment (EEE)

Restriction of Hazardous SubstancesRestriction of Hazardous Substances

Electrical and Electronic Equipment (EEE)Electrical and Electronic Equipment (EEE)


Private sector manages and funds program

Adopted, published and effective

Must be up and running by August 13, 2005

Private sector manages and funds programPrivate sector manages and funds program

Adopted, published and effectiveAdopted, published and effective

Must be up and running by August 13, 2005Must be up and running by August 13, 2005

Recycling and recovery programRecycling and recovery programRecycling and recovery program

WEEE Directive OverviewWEEE Directive OverviewWEEE Directive OverviewWaste of EEEWaste of EEEWaste of EEE


Key European Union InstitutionsKey European Union InstitutionsKey European Union InstitutionsEU Commission

EU Council

EU Parliament

EU Court of Justice

EU CommissionEU Commission

EU CouncilEU Council

EU ParliamentEU Parliament

EU Court of JusticeEU Court of Justice


European Union LawmakingEuropean Union LawmakingEuropean Union LawmakingCommission initiates, Commission and Parliament agree, and Council adopts

Directives are binding only on Member States

Member States must implement Directives into domestic law

* This is where we are with WEEE & RoHS

Regulatory flexibility of Member States is different for WEEE and RoHS Directives

Commission initiates, Commission and Parliament Commission initiates, Commission and Parliament agree, and Council adoptsagree, and Council adopts

Directives are binding only on Member StatesDirectives are binding only on Member States

Member States must implement Directives into Member States must implement Directives into domestic lawdomestic law

* This is where we are with WEEE & RoHS* This is where we are with WEEE & RoHS

Regulatory flexibility of Member States is different Regulatory flexibility of Member States is different for WEEE and RoHS Directivesfor WEEE and RoHS Directives


So What? Why Should You Care?So What? Why Should You Care?So What? Why Should You Care?PenaltiesPenaltiesPenalties


So What? Why Should You Care?So What? Why Should You Care?So What? Why Should You Care?Penalties

Import Bans

PenaltiesPenalties

Import BansImport Bans

Playstation One



Import Bans

Remaining Competitive

PenaltiesPenalties


Remaining CompetitiveRemaining Competitive



Import Bans

Remaining Competitive

How much of your business goes to the EU?

PenaltiesPenalties


Remaining CompetitiveRemaining Competitive

How much of your business goes to the EU?How much of your business goes to the EU?


Allen & OveryAllen & OveryAllen & Overy

2,400 attorneys

50 environmental attorneys

WEEE and RoHS Product Team

2,400 attorneys2,400 attorneys

50 environmental 50 environmental attorneysattorneys

WEEE and RoHS WEEE and RoHS Product TeamProduct Team


Section TwoSection Two

WEEE DirectiveWEEE Directive


Categories and Examples of EEE Regulated Under the WEEE DirectiveCategories and Examples of EEE Categories and Examples of EEE Regulated Under the WEEE DirectiveRegulated Under the WEEE Directive1. Large Household Appliances 2. Small Household Appliances

3. IT and Telecommunications EquipmentCentralized Data Processing Personal Computing

RefrigeratorsWashing MachinesMicrowaves

Vacuum cleanersToasters

MainframesMinicomputersPrinter units

Personal computers(CPU, mouse, screen & keyboard included)Lap-top computers(CPU, mouse, screen & keyboard included)PrintersCopying equipmentTelephones

User Terminals and SystemsCellular telephonesFax machines


Categories and Examples of EEE Regulated Under the WEEE DirectiveCategories and Examples of EEE Categories and Examples of EEE Regulated Under the WEEE DirectiveRegulated Under the WEEE Directive4. Consumer Equipment 5. Lighting Equipment

Radio setsTelevision setsMusical instruments

Straight fluorescent lamps

7. Toys, Leisure and Sports Equipment6. Electrical and Electronic ToolsDrillsSawsSewing machines

Electric trains or car racing setsHand-held video game consolesVideo games

8. Medical Devices 9. Monitoring and Control InstrumentsPulmonary ventilators Smoke detectors

Heating regulators10. Automatic Dispensers

Coke Machine


Four Exemptions Under WEEEFour Exemptions Under WEEEFour Exemptions Under WEEE(1) EEE intended for military purposes

(2) Large-scale stationary industrial tools

(3) Implanted and injected medical devices

(4) EEE “part of another type of equipment that does not fall within the scope” of the WEEE Directive

Issue Which exemptions, if any, also apply to the RoHS Directive?

(1)(1) EEE intended for military purposesEEE intended for military purposes

(2)(2) LargeLarge--scale stationary industrial toolsscale stationary industrial tools

(3)(3) Implanted and injected medical devicesImplanted and injected medical devices

(4)(4) EEE “part of another type of equipment that does EEE “part of another type of equipment that does not fall within the scope” of the WEEE Directivenot fall within the scope” of the WEEE Directive

IssueIssue Which exemptions, if any, also apply to the Which exemptions, if any, also apply to the RoHS Directive?RoHS Directive?


Product CycleFrom EEE Manufacturing to

WEEE TreatmentCollection of WEEE

Collection Center

Distributor(Retail)

Waste Household

Area No. 2Europe

Distributor(Retail)

ProfessionalImporter?

Mail Order

Internet

or

or

Sale

Waste Non-Household

, Inc.

Area No. 3

WEEE Reused as a Whole

Second-Hand Market

for WEEE Reused as a

Whole

Annex II

3 2 1

Area No. 5

Selective Treatment

Treatment, Recovery and Disposal of WEEE

De-Pollution, Disassembly,

Shredding, Recover, and

Others

Removal of Fluids

WEEE Not Reused as a whole

Are

a N

o. 4

Tran

spor

tatio

n of

WEE

E

10%*

65%*Minimum

25%*

75%*Minimum

Rec

over

y

* for EEE Categories 3 and 4

Environmentally Sound Disposal

Incineration for energy

Reuse and Recycling of Components

and Substances

Area No. 1

(Comp X)Component

Information Requirement

Financial Guarantees

Substance and Design Restrictions

Crossed-out Dustbin Icon

(OEM)New Product

(EMS)Manufacturing

Producer?

Producer?

U.S.


WEEE Directive Key RequirementsWEEE Directive Key RequirementsWEEE Directive Key Requirements(1) Information requirements

(2) Design requirements

(3) Financial guarantees

(4) Collection of WEEE

(5) Financing of treatment, recovery and disposal of WEEE

(1)(1) Information requirementsInformation requirements

(2)(2) Design requirementsDesign requirements

(3)(3) Financial guaranteesFinancial guarantees

(4)(4) Collection of WEEECollection of WEEE

(5)(5) Financing of treatment, recovery and disposal Financing of treatment, recovery and disposal ofof WEEEWEEE


Section ThreeSection Three

Open Issues under the WEEE DirectiveOpen Issues under the WEEE Directive


Issue 1 - Covered Companies – WEEEIssue 1 Issue 1 -- Covered Companies Covered Companies –– WEEEWEEEThree types of companies are “Producers”

manufacture and sell EEE under their own brand namesell under their brand EEE manufactured by othersexport or import EEE into the EU on a “professional basis”

Irrespective of selling technique (e.g., internet)

Three types of companies are “Producers”Three types of companies are “Producers”manufacture and sell EEE under their own brandmanufacture and sell EEE under their own brand namenamesell under their brand EEE manufactured by otherssell under their brand EEE manufactured by othersexport or import EEE into the EU on a “professional export or import EEE into the EU on a “professional basis”basis”

Irrespective of selling technique (e.g., internet)Irrespective of selling technique (e.g., internet)


Issue 2 – Scope of Information Reporting Obligations (1)Issue 2 Issue 2 –– Scope of Information Reporting Scope of Information Reporting Obligations (1)Obligations (1)

WEEE Directive Art. 11(1)Obligation on producer to report info to treatment centersMust identify location of dangerous substances and preparations in EEE

What material must be reported?6 banned substances?RoHS Annex II substances?References to Directive on Dangerous Substances and Preparations? ELV precedent?

WEEE Directive Art. 11(1)WEEE Directive Art. 11(1)Obligation on producer to report info to treatment centersObligation on producer to report info to treatment centersMust identify location of dangerous substances and Must identify location of dangerous substances and preparations in EEEpreparations in EEE

What material must be reported?What material must be reported?6 banned substances?6 banned substances?RoHS Annex II substances?RoHS Annex II substances?References to Directive on Dangerous Substances and References to Directive on Dangerous Substances and Preparations? ELV precedent?Preparations? ELV precedent?


Issue 3 – Scope of the DirectiveIssue 3 Issue 3 –– Scope of the DirectiveScope of the DirectiveTAC Guidance Document

General guidelinesBatteriesInk cartridgesRelationship with ELV Directive

Will Member States follow the guidance?

TAC Guidance DocumentTAC Guidance DocumentGeneral guidelinesGeneral guidelinesBatteriesBatteriesInk cartridgesInk cartridgesRelationship with ELV DirectiveRelationship with ELV Directive

Will Member States follow the guidance?Will Member States follow the guidance?


Issue 4 – Meeting the WEEE RequirementsIssue 4 Issue 4 –– Meeting the WEEE RequirementsMeeting the WEEE Requirements(Collection, treatment, recovery and disposal)

Collective or Individual Compliance?

EU solution or Member State per Member State Approach?

Factors includePrivate household v. non-private household WEEEProduct types and value of WEEEKey markets

(Collection, treatment, recovery and disposal)(Collection, treatment, recovery and disposal)

Collective or Individual Compliance?Collective or Individual Compliance?

EU solution or Member State per Member State EU solution or Member State per Member State Approach?Approach?

Factors includeFactors includePrivate household v. nonPrivate household v. non--private household WEEEprivate household WEEEProduct types and value of WEEEProduct types and value of WEEEKey marketsKey markets


Section FourSection Four

RoHS DirectiveRoHS Directive


Covered Products – RoHSCovered Products Covered Products –– RoHSRoHSApplies to same EEE Categories as WEEE

Exceptions (specific to RoHS)EEE Categories 8 and 9 – medical devices, and monitoring and control instrumentsCertain “applications” of the banned substances are exempted pursuant to RoHS Directive Annex e.g., lead in– high-melting temperature-type solders (i.e., tin-lead solder alloys

containing more than 85% lead)

– solders for servers, storage and storage array systems (exemption granted until 2010)

Applies to same EEE Categories as WEEEApplies to same EEE Categories as WEEE

Exceptions (specific to RoHS)Exceptions (specific to RoHS)EEE Categories 8 and 9 EEE Categories 8 and 9 –– medical devices, and medical devices, and monitoring and control instrumentsmonitoring and control instrumentsCertain “applications” of the banned substances are Certain “applications” of the banned substances are exempted pursuant to RoHS Directive Annex exempted pursuant to RoHS Directive Annex e.g.e.g., lead in, lead in–– highhigh--melting temperaturemelting temperature--type solders (i.e., tintype solders (i.e., tin--lead solder alloys lead solder alloys

containing more than 85% lead)containing more than 85% lead)

–– solders for servers, storage and storage array systems solders for servers, storage and storage array systems (exemption granted until 2010)(exemption granted until 2010)


RoHS Supply Chain ImpactsRoHS Supply Chain ImpactsRoHS Supply Chain ImpactsQuestion for the component manufacturersQuestion for the component manufacturersQuestion for the component manufacturers

Who will buy a componentthat contains lead in 2006?Who will buy a componentWho will buy a componentthat contains lead in 2006?that contains lead in 2006?


Section FiveSection Five

Open Issues under the Open Issues under the RoHS Directive RoHS Directive


Issue 1 – MCVs (1)Issue 1 Issue 1 –– MCVsMCVs (1)(1)RoHS Directive Art. 5(1)(a)

2 documentsCommission decisionGuidance document

December 5, 2003 Proposed Commission Decision0.1% for lead, mercury, Cr6+, PBB and PBDE0.01% for cadmium = same as current EU law (applicable only to some products)By weight of “homogeneous materials” with short definitionNo reference to intentional addition of banned substance

RoHS Directive Art. 5(1)(a)RoHS Directive Art. 5(1)(a)

2 documents2 documentsCommission decisionCommission decisionGuidance documentGuidance document

December 5, 2003 Proposed Commission DecisionDecember 5, 2003 Proposed Commission Decision0.1% for lead, mercury, Cr6+, PBB and PBDE0.1% for lead, mercury, Cr6+, PBB and PBDE0.01% for cadmium = same as current EU law 0.01% for cadmium = same as current EU law (applicable only to some products)(applicable only to some products)By weight of “homogeneous materials” with short By weight of “homogeneous materials” with short definitiondefinitionNo reference to intentional addition of banned substanceNo reference to intentional addition of banned substance


Issue 1 – MCVs (2)Issue 1 Issue 1 –– MCVsMCVs (2)(2)June 10, 2004 TAC Meeting

Proposal to move definition of “homogeneous material” from Decision to RoHS GuidanceProposal is rejected and, with it, the proposal to establish the MCVs!

July 16 and 20, 2004 TAC MeetingsDefinition of homogeneous material is moved to the RoHS guidanceDecision adopted by TAC (without definition)Commission has 3 months to adopt

June 10, 2004 TAC MeetingJune 10, 2004 TAC MeetingProposal to move definition of “homogeneous material” Proposal to move definition of “homogeneous material” from Decision to RoHS Guidancefrom Decision to RoHS GuidanceProposal is rejected and, with it, the proposal to establish Proposal is rejected and, with it, the proposal to establish the the MCVsMCVs!!

July 16 and 20, 2004 TAC MeetingsJuly 16 and 20, 2004 TAC MeetingsDefinition of homogeneous material is moved to the Definition of homogeneous material is moved to the RoHS guidanceRoHS guidanceDecision adopted by TAC (without definition)Decision adopted by TAC (without definition)Commission has 3 months to adoptCommission has 3 months to adopt


Issue 1 – MCVs (3)Issue 1 Issue 1 –– MCVsMCVs (3)(3)Accordingly

Risk that Member States will implement MCVs differently

Most recent draft RoHS Guidance documentHomogeneous material means a unit that can not be mechanically disjointed in single materials.“Homogeneous” means "of uniform composition throughout", so examples of "homogeneous materials" would be individual types ofplastics, ceramics, glass, metals, alloys, paper, board, resins and coatings“Mechanically disjointed” means that the materials can be, in principle, separated by mechanical actions such as unscrewing, cutting, crushing, grinding and abrasive processesIntentionally added?

AccordinglyAccordinglyRisk that Member States will implement Risk that Member States will implement MCVsMCVs differentlydifferently

Most recent draft RoHS Guidance documentMost recent draft RoHS Guidance documentHomogeneous material means a unit that can not be mechanically Homogeneous material means a unit that can not be mechanically disjointed in single materials.disjointed in single materials.“Homogeneous” means "of uniform composition throughout", so examples of "homogeneous materials" would be individual types ofplastics, ceramics, glass, metals, alloys, paper, board, resins and coatings“Mechanically disjointed” means that the materials can be, in principle, separated by mechanical actions such as unscrewing, cutting, crushing, grinding and abrasive processesIntentionally added?Intentionally added?


Issue 2 – EU Commission Consultation on Application Exemptions (1)Issue 2 Issue 2 –– EU Commission Consultation on EU Commission Consultation on Application Exemptions (1)Application Exemptions (1)

RoHS Directive Art. 5(1)(b)

Stakeholder Consultation launched by EU Commission

Started early May 2004Ended July 5, 2004

Commission requests information on 13 exemptions, including1. Lead in solders for servers, storage and storage array

systems and certain network infrastructure equipment2. Lead used in compliant-pin VHDM

RoHS Directive Art. 5(1)(b)RoHS Directive Art. 5(1)(b)

Stakeholder Consultation launched by EU Stakeholder Consultation launched by EU CommissionCommission

Started early May 2004Started early May 2004Ended July 5, 2004Ended July 5, 2004

Commission requests information on 13 Commission requests information on 13 exemptions, includingexemptions, including1.1. Lead in solders for servers, storage and storage array Lead in solders for servers, storage and storage array

systems and certain network infrastructure equipmentsystems and certain network infrastructure equipment2.2. Lead used in compliantLead used in compliant--pin VHDMpin VHDM


Issue 2 – EU Commission Consultation on Application Exemptions (2)Issue 2 Issue 2 –– EU Commission Consultation on EU Commission Consultation on Application Exemptions (2)Application Exemptions (2)

Commission Requests Information (cont’d)4. Lead in high-melting temp. solders and any lower melting

temp. solder required to complete a viable electrical connection

5. Lead in solders to complete a viable electrical connection internal to certain integrated circuit packages (flip chips) (until 2010)

Results91 responsesNo decision because “insufficient information” Commission will wait until technical study by mid-October

Commission Requests Information (cont’d)Commission Requests Information (cont’d)4.4. Lead in highLead in high--melting temp. solders and any lower melting melting temp. solders and any lower melting

temp. solder required to complete a viable electrical temp. solder required to complete a viable electrical connectionconnection

5.5. Lead in solders to complete a viable electrical connection Lead in solders to complete a viable electrical connection internal to certain integrated circuit packages (flip chips) internal to certain integrated circuit packages (flip chips) (until 2010)(until 2010)

ResultsResults91 responses91 responsesNo decision because “insufficient information” No decision because “insufficient information” Commission will wait until technical study by midCommission will wait until technical study by mid--OctoberOctober


Issue 3 – Compliance with RoHS (1)Issue 3 Issue 3 –– Compliance with RoHS (1)Compliance with RoHS (1)How do you comply? How do you demonstrate compliance?

Within supply chainTo governmental authorities

Compliance is a Member State responsibility

Potential approachesGovernment TestingIndependent Laboratory TestingCertificationSelf-declaration

How do you comply? How do you demonstrate How do you comply? How do you demonstrate compliance?compliance?

Within supply chainWithin supply chainTo governmental authoritiesTo governmental authorities

Compliance is a Member State responsibilityCompliance is a Member State responsibility

Potential approachesPotential approachesGovernment TestingGovernment TestingIndependent Laboratory TestingIndependent Laboratory TestingCertificationCertificationSelfSelf--declarationdeclaration


Issue 3 – Compliance with RoHS (2)Issue 3 Issue 3 –– Compliance with RoHS (2)Compliance with RoHS (2)Commission hired consultant to review these issues

April 2004 ReportClarification of definition of MCVSelf-DeclarationAdoption of Standard for Reporting FormatsAdoption of Standard for Compliance TestingInformation Exchange Networks

Commission hired consultant to review these issuesCommission hired consultant to review these issues

April 2004 ReportApril 2004 ReportClarification of definition of MCVClarification of definition of MCVSelfSelf--DeclarationDeclarationAdoption of Standard for Reporting FormatsAdoption of Standard for Reporting FormatsAdoption of Standard for Compliance TestingAdoption of Standard for Compliance TestingInformation Exchange NetworksInformation Exchange Networks


Issue 3 – Compliance with RoHS (3)Issue 3 Issue 3 –– Compliance with RoHS (3)Compliance with RoHS (3)Self-Declaration

Every product “put on the market” is presumed to comply

Producer’s responsibilitiesRequest declaration from each supplierReview accuracy when in doubtFocus on specific productsFocus on specific suppliers

EnforcementIf challenged, producers would show enforcement authorities that have taken reasonable steps to comply– Material composition data may be audited by authorities

SelfSelf--DeclarationDeclarationEvery product “put on the market” is presumed to complyEvery product “put on the market” is presumed to comply

Producer’s responsibilitiesProducer’s responsibilitiesRequest declaration from each supplierRequest declaration from each supplierReview accuracy when in doubtReview accuracy when in doubtFocus on specific productsFocus on specific productsFocus on specific suppliersFocus on specific suppliers

EnforcementEnforcementIf challenged, producers would show enforcement If challenged, producers would show enforcement authorities that have taken reasonable steps to complyauthorities that have taken reasonable steps to comply–– Material composition data may be audited by authoritiesMaterial composition data may be audited by authorities


Issue 3 – Compliance with RoHS (4)Issue 3 Issue 3 –– Compliance with RoHS (4)Compliance with RoHS (4)UK Implementation

Requirement to submit “technical documents” or “other information” showing that a particular product complies with substance ban within 28 from a request by GovernmentDocument retention requirement of 4 years

UK ImplementationUK ImplementationRequirement to submit “technical documents” or “other information” showing that a particular product complies with substance ban within 28 from a request by GovernmentDocument retention requirement of 4 years


Issue 3 – Compliance with RoHS (5)Issue 3 Issue 3 –– Compliance with RoHS (5)Compliance with RoHS (5)UK Implementation

Defense for producers to show that he took all “reasonable steps” and exercised all due diligence to avoid violating the substance banMust show that it was reasonable under the circumstances to rely on the information, having regard in particular– to the steps which he took and those which might

reasonably have been taken, for the purpose of verifying the information; and

– to whether he had any reason to disbelieve the information

UK ImplementationDefense for producers to show that he took all “reasonable steps” and exercised all due diligence to avoid violating the substance banMust show that it was reasonable under the circumstances to rely on the information, having regard in particular– to the steps which he took and those which might

reasonably have been taken, for the purpose of verifying the information; and

– to whether he had any reason to disbelieve the information


Issue 3 – Compliance with RoHS (6)Issue 3 Issue 3 –– Compliance with RoHS (6)Compliance with RoHS (6)Liability of component manufacturer?

If producer is not liable, “other person” may be held liable

Open IssuesWhat will become industry practiceWhether the UK DTI will consider industry practice reasonableWhether other Member States will follow UK approach

Liability of component manufacturer?If producer is not liable, “other person” may be held liable

Open IssuesWhat will become industry practiceWhether the UK DTI will consider industry practice reasonableWhether other Member States will follow UK approach


Issue 4 – Testing Procedures under RoHSIssue 4 Issue 4 –– Testing Procedures under RoHSTesting Procedures under RoHSEnsure uniform testing of EEE to determine RoHS compliance

Across supply chainAcross Member States

International Electrotechnical Commission (IEC)Advisory Group on Environmental Aspects– Working Group on RoHS Test Methods

Unclear how IEC work will feed into the Commission or TAC work

Ensure uniform testing of EEE to determine RoHS Ensure uniform testing of EEE to determine RoHS compliancecompliance

Across supply chainAcross supply chainAcross Member StatesAcross Member States

International Electrotechnical Commission (IEC)International Electrotechnical Commission (IEC)Advisory Group on Environmental AspectsAdvisory Group on Environmental Aspects–– Working Group on RoHS Test MethodsWorking Group on RoHS Test Methods

Unclear how IEC work will feed into the Unclear how IEC work will feed into the Commission or TAC workCommission or TAC work


Section SixSection Six

Final ThoughtsFinal Thoughts


WEEE and RoHS TimelineWEEE and RoHS TimelineWEEE and RoHS TimelineFebruary 13, 2003 Directives become effectiveAugust 13, 2004 Member States adopt

domestic lawsAugust 13, 2005 (1) collection systems must be

in place; (2) producers start financing; and (3) all products must be marked

July 1, 2006 Substance ban takes effectDecember 31, 2006 Member States must meet

4 kg target (2008 for some accession Member States)

February 13, 2003February 13, 2003 Directives become effectiveDirectives become effectiveAugust 13, 2004August 13, 2004 Member States adopt Member States adopt

domesticdomestic lawslawsAugust 13, 2005August 13, 2005 (1) collection systems must be (1) collection systems must be

inin place; (2) producers start place; (2) producers start financing; and (3) all products financing; and (3) all products must be markedmust be marked

July 1, 2006July 1, 2006 Substance ban takes effectSubstance ban takes effectDecember 31, 2006December 31, 2006 Member States must meet Member States must meet

4 kg4 kg target (2008 for some target (2008 for some accession Member States)accession Member States)


SummarySummarySummarySeveral open issues

Trend is toward self-certification

Each producer must conduct its own due diligence

Component manufacturers also must have a compliance program

Standards for data exchange and reporting are crucial building blocks in compliance strategy

Several open issuesSeveral open issues

Trend is toward selfTrend is toward self--certificationcertification

Each producer must conduct its own due diligenceEach producer must conduct its own due diligence

Component manufacturers also must have a Component manufacturers also must have a compliance programcompliance program

Standards for data exchange and reporting are Standards for data exchange and reporting are crucial building blocks in compliance strategycrucial building blocks in compliance strategy


Thank YouThank You

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