Is industry prepared for Indian RoHS directive?

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Guest Column

India has finally enacted the E-Waste (Management and Handling) Rules, 2011, which cover both the restriction of hazardous materials in electronic and electrical equipment, and also impose responsibility on producers, collection centres, consumers, dismantlers and recyclers.

WEEE (Waste Electronic and Electrical Equipment) related provisions will come into force on May 1, 2012, and RoHS related provisions will be implemented on May 12, 2013.

The European Union (EU) was the first to introduce Directive 2002/95/EC of the European Parliament and of the council on the ‘Restriction of the use of certain Hazardous Substances (RoHS)’ in electrical and electronic equipment to protect human health and ensure the environmentally sound recovery and disposal of waste EEE. This was made compulsory in EU countries in 2006.

Why are directives essential?

The EU had done a detailed study of the various materials used by the EEE industries in their products and it found certain substances hazardous to health, which could cause diseases like cancer, brain fever, kidney failure, etc. These hazardous elements can also affect the environment after the products are disposed of. For example, when over 100 workers in two Chinese battery factories fell ill in July 2004, their medical reports stated “…excessive levels of cadmium in the blood.”

Today, considering its importance, most of the leading manufacturing countries have implemented this directive. Some countries have introduced their own RoHS directives by slightly modifying the EU-RoHS. For example, Japan’s J-Moss, Korea’s Korea-RoHS, China’s China-RoHS, and America’s US-RoHS are all operative in their respective countries.

Indian scenario

In India, although our directives are similar to EU-RoHS, there is no enforcement on its implementation, and only export oriented companies and some of the multinationals (depending on their global policies) ensure that their products meet RoHS directives.

It is high time that such a directive is seriously implemented for local suppliers in India, too, because the electronic waste (which includes computers, televisions, refrigerators, washing machines, etc) generated in Mumbai alone was over 19,000 tonnes in 2009. This does not include the waste generated by other products like plastics and automobiles. From this, the importance and immediate need to control the use of hazardous substances in products is understandable. Also, failing to comply with RoHS could result in hefty fines, an increase in the cost of the recycling and re-export of material, or the banning of a product from being exported. The director, manager or executive officer of the corporate body will be regarded as having committed the offence. There can be indirect consequences also, like losing market competitiveness or future business opportunities, a delay in deliveries and, most importantly, the damage to a firm’s reputation.

In May 2010, the Ministry of Environment and Forests, Government of India, proposed a draft notification of its E-waste (Management and Handling) Rules 2010, with the aim to put in place an effective mechanism to regulate the generation, collection, storage, transportation, import and export of EEE. This was to ensure environmentally sound recycling, treatment and disposal of electronic waste. Specifically, the legislation included a chapter that dealt with the reduction of the use of hazardous substances in the manufacture of EEE.

After taking into consideration the comments on the draft from (IPC) and the Indian Printed Circuits Association (IPCA), the E-Waste (Management and Handling) Rules 2011 have now been published and will be effective from May 1, 2012. These include two primary areas—WEEE and RoHS.

India’s version limits the use of 20 substances in electronics products for sale in India. It also bans substances, including some flame retardants that currently have no viable alternatives.

Similar to the EU legislation, the Indian government will require manufacturers and importers to supply only RoHS-compliant products and to provide written documentation supporting compliance. This aspect has resulted in an ongoing struggle in the electronics supply chain because documenting compliance often requires the disclosure of information that component makers regard as proprietary.

Testing procedures for compliance

Considering the level of liabilities and the amount of penalties manufacturers have to pay in case the products exported fail to meet RoHS criteria, it has become important for companies to take extra precautions by testing incoming materials, components and final products either at commercial laboratories or by setting up inhouse testing facilities.

This is not an easy exercise as, typically, a company will be dealing with innumerable materials and components. For example, a refrigerator has 170+ components and the vendors for each of them would be different. To make RoHS compliance easy and convenient, instrumentation companies have introduced various testing instruments. Shimadzu Corporation of Japan was one of the first companies to have introduced a set of instruments to test RoHS elements in different types of materials.

The testing of components and materials involves two phases—screening and precision testing. As the techniques used need lengthy sample preparation and skilled manpower, manufacturing industries prefer easy, quick and almost sample-preparation free screening analysis by procuring instruments like the energy dispersive X-ray spectrometer (EDXRF) for their laboratories. They define a grey zone, typically plus or minus 25 per cent of the permissible limit, as the pass and fail criteria—below 25 per cent is considered a ‘pass’, while above 25 per cent is a ‘fail’. Anything that shows up within the 25 per cent band either fails or goes for precision analysis.

The samples which fall within this 25 per cent band are rechecked by using precision techniques at commercial labs. This reduces the dependence on outside laboratories and hence, works out faster and cheaper for industries. At the same time they are assured that their products are totally free from hazardous substances.

Instruments required for testing

The energy dispersive X-ray spectrometer (EDXRF) is the most popular and preferred instrument to test for all hazardous elements as per WEEE, RoHS, ELV and En71 directives.

It can test solids, powders, liquids and thin film samples without sample preparation. Analysis of all the elements can be done between a few seconds to a few minutes. The machine is calibrated by using certified reference materials and the reference materials for different types of samples like PVC, PE, copper, solders, zinc, ferrous oxides, etc. The results produced by the EDXRF are accepted by third party agencies like ISO, NABL, etc.

EDXRF can be used to analyse other elements as well, like aluminium (13) to Uranium (92) on the periodic table. During the analysis for hazardous elements, other elements present in the samples are also analysed and displayed within 100 seconds.

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Two directives—WEEE and RoHS

The EU took the first initiative and introduced these directives, which help manufacturers by offering various options to replace the use of hazardous substances. However, some hazardous substances have been exempted from these regulations due to non-availability of alternates.

Waste Electrical and Electronic Equipment (WEEE) promotes the reuse, recycling and recovery of waste from electrical and electronic equipment.

The Restriction on use of Hazardous Substances (RoHS) helps to reduce the use of heavy elements by replacing them with alternate non-hazardous chemicals.

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Alternate materials to replace use of hazardous elements

EU directives suggest alternate materials that can replace the use of hazardous elements. Some of them are:

• Lead free solders
• Aluminium ion vapour deposition systems; the Zn/Ni, Zn/Co, Sn/Ni, Sn/Zn bath instead of cadmium in electroplating process
• SnO in place of CdO in relays
• Mercury fluorescent lamps can be replaced by sodium vapour or sulphur lamps
• Cr6+ coating can be replaced by Cr3+ (trivalent chromium) or Ni or Ni/Co alloys
• PBB and PBDE can be replaced by tetra-bromobisphenol A (TBBPA) or non-halogenated flame retardants

Zn (zinc); Ni (nickle); Co (cobalt); Sn (tin); SnO (tin onide); Cr3+ (trivalent chromium)

Considering that in some of the applications, it is practically difficult to replace the above elements, the directives also include some exemptions. Exemption requests from companies and organisations are continually evaluated. The following are some examples of exemptions:

• Lead in the glass of cathode ray tubes, in copper alloys (<4 per cent), in high melting temperature type solders; lead in solders for network infrastructure equipment in electronic ceramic parts (that is, piezoelectric components)
• Mercury in some lighting applications
• Cadmium in plating
• Hexavalent chromium in absorption refrigerators

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List of hazardous elements and their maximum permissible limits (in homogeneous material)