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US Electronic Product Stewardship. Heather S. Bowman Electronic Industries Alliance Director Environmental Affairs and Deputy General Counsel APEX February 24, 2004. Presentation Overview. Electronic Industries Alliance

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US Electronic Product Stewardship

Heather S. Bowman

Electronic Industries Alliance

Director Environmental Affairs and Deputy General Counsel


February 24, 2004

presentation overview
Presentation Overview
  • Electronic Industries Alliance
  • Elements of Global Regulations driving Electronics Product Stewardship in the United States
  • United States Environmental Laws
  • 2004 Legislation – Electronics Recycling
  • Voluntary Initiatives
  • Questions/For More Information

Electronic Industries Alliance

Public Policy

Standards & Technology

Meetings & Networking

  • 2,500 Members
  • 80% of a $430 billion industry
  • Unique alliance structure
  • Environmental Issues Council

Consumer Electronics Association (CEA)

Telecommunications Industry Association (TIA)

Government Electronics & Information Technology Association (GEIA)


Electronic Components, Assemblies & Materials Association (ECA)

NSTEP National Science & Technology Education Partnership (Foundation)


Electronic Representative Association (ERA)

Internet Security Alliance (ISAlliance)

National Association of Relay Manufactures (NARM)

Electronic Industries Alliance“The Whole is Greater Than the Sum of the Individual Parts”

examples of regulatory elements
Examples of Regulatory Elements
  • Require Life Cycle Assessments when Products are Designed
  • Ban Certain Chemicals from Use in Products
  • Require Consumer Notification and/or Product Labeling at point of sale
  • Require Electronic Products to Achieve Certain Energy Efficiency During Use
  • Require Collection and Proper EOL Management

* Europe and parts of Asia in lead; Americas moving forward

us recycling legislation
US Recycling Legislation
  • Federal Level – US EPA CRT Rule, Thompson legislation, Appropriations language
  • Maine, Minnesota, Massachusetts, California and Washington all ban CRTs from landfill – either by law or regulation
  • In September 2003, California Enacted First State Law Establishing a System for Electronics Recycling
    • SB20 will Impose Fee ($6-$10) on Sale of CRT/Display Products starting in July 2004
    • Implement EU RoHS directive for covered products in 2007
    • Working with DTSC and CIWMB to implement fairly
scope of ca sb 20
Scope of CA SB 20
  • Scope of Products, per SB 20 definition
    • Currently only CRTs (TVs, Computer Monitors)
    • Others, Flat Panel Screens, other Video Display Devices greater than 4” diagonally, subjected to testing
  • SB 20 RoHS provision references this scope of “covered electronic devices”
    • Regulations cannot go beyond requirements in other parts of SB 20, i.e. different product scope, etc
    • Regulations also cannot prohibit product allowed in EU
  • Chemicals Banned by SB 20 (“presence of certain heavy metals”)
    • Lead
    • Mercury
    • Cadmium
    • Hexavalent chromium
relevant eu rohs exemptions
Relevant EU RoHS Exemptions
  • Mercury in compact fluorescent lamps not exceeding 5 mg per lamp.
  • Mercury in straight fluorescent lamps for general purposes not exceeding: - halophosphate 10 mg;- triphosphate with normal lifetime 5 mg, long lifetime 8 mg
  • Mercury in straight fluorescent lamps for special purposes.
  • Mercury in other lamps not specifically mentioned in this Annex.
relevant eu rohs exemptions9
Relevant EU RoHS Exemptions
  • Lead in glass of cathode ray tubes, electronic components and fluorescent tubes.
  • Lead as an alloying element in steel containing up to 0,35% lead by weight, aluminum containing up to 0,4% lead by weight and as a copper alloy containing up to 4% lead by weight.
  • Lead in high melting temperature type solders (i.e. tin-lead solder alloys containing more than 85% lead), and any lower melting temperature solder required to be used with high melting temperature solder to complete a viable electrical connection
    • Yellow text addition suggested to the EU TAC in May 2003
  • Cadmium plating except for applications banned under Directive 91/338/EEC 1.
need harmonization
Need Harmonization
  • SB 20 references RoHS directive as it stood on January 27, 2003
  • DTSC can implement regulations to track the evolving EU changes
    • Need ability to evolve regulations after 2007
  • Industry is also learning more and more as we prepare to comply with the law, so we continue to share information with the TAC (and the Commission) so its decisions are based on the latest scientific and technical evidence available.
  • In order to ensure harmonization and the ability for companies to market products globally, high tech industry has requested and continues to advocate for IDENTICAL IMPLEMENTATION of RoHS requirements.
2004 us state legislation
2004 US State Legislation
  • Total of 52 bills introduced (several in some states)
    • Full Producer Responsibility
      • MD, MA, MN, NY (cell phones), PA, RI, VT, WI
    • Advanced Recovery Fee
      • CA, CT, HI, IL, MD, NE, SC, TN
    • Landfill Ban or Study Committee
      • ID (Res), MI, NM, NY, RI, WA (amend)
    • Combination of ARF/Partial Cost Internalization
      • Maine – DEP recommendation after Advisory Committee Meetings over summer
us legislation concerns
US Legislation Concerns
  • Level Playing Field
  • Enforcement
  • Consumer reaction
  • Use of funds and true costs
    • Consumers
    • Company
    • Government
  • Design Restrictions: Harmonization with EU, China
industry initiatives
Industry Initiatives
  • EIA Consumer Education Initiative (
    • Provides Consumers with Recycling and Reuse Opportunities for Electronics
    • Manufacturers individual voluntary programs listed
  • EIA Track (
    • International Regulatory Tracking Database for Electronics Industry
  • EIA Material Declaration Guide
    • Industry Supply Chain Procurement Tool to Ensure Global Sale - US, Europe, Japan
  • Diversity in approaches, the book is not closed, wait to evaluate how any of the laws will apply in practice
  • Jurisdictions differ on elements of product stewardship bills, however many common elements:
    • Landfill bans
    • Fees (point of sale or point of disposal)
    • Chemical bans
    • Producer responsibly
    • Voluntary / Market driven
  • Over next 5 years anticipate jurisdictions without take back laws may see pressure to enact
for more information
For More Information:

Heather Bowman

Director of Environmental Affairs

Deputy General Counsel

Electronic Industries Alliance

2500 Wilson Blvd

Arlington, VA 22201

Tel: (703) 907-7576

Fax: (703) 907-7501