Understanding WEEE, RoHS, REACH and Other Environmental Directives
The U.S. economy is largely consumer driven, as more than two-thirds of gross domestic product is represented by everyday Americans buying services and physical products – the latter, in particular. But in order for these products to reach consumers – whether within the States or overseas – they have to pass regulatory muster. Europe, China and an increasing number of regions around the world now require markings on products and component parts to alert people to the existence of potentially harmful substances or elements that could cause a health or environmental hazard.
That means that many manufacturers selling industrial products overseas and into the European Union (EU) market have a need to understand the various environmental protection directives in place. These effect the labels and symbols you use on your products.
Here are three of the more common regulatory directives internationally – WEEE, RoHS and Reach – for a primer on what they mean for your regulatory labels.
Short for Waste Electrical and Electronic Equipment, the WEEE Directive (2012/19/EU) was established in 2002. A number of minor revisions have been made since then. It requires producers of electrical and electronic equipment who sell their products in the EU to operate a recycling program. Its purpose is to better protect the health and sustainability of the environment by informing users that devices may contain harmful contaminants (which can adversely affect plants and animals if improperly disposed) including:
- Small and large household appliances
- Telecommunications equipment
- Medical devices
- Lighting equipment
- Automatic dispensers
Compliance with WEEE is multi-pronged. For example, products included under the WEEE Directive must bear the WEEE mark, a symbol of a crossed-out trash can. Manufacturers must also register with the national authority in the countries where the products are sold.
The Restriction of Hazardous Substances, RoHS, otherwise known as Directive 2002/95/EC (which has evolved to RoHS 2 and RoHS 3 in subsequent years) is similar to WEEE, in that it is applicable to products sold in the European Union. It also applies to certain types of electrical and electronic equipment.
But RoHS is slightly more specific, effectively banning products from containing certain types of chemicals. Under RoHS, manufactured equipment can't contain more than the specified RoHS limits of these substances:
- Hexavalent chromium
- Polybrominated biphenyls
- Polybrominated diphenyl ethers
- Phthalates (four different types)
As RoHS is a CE-marking directive, manufacturers should ensure that the "CE" symbol is affixed to their electronic products; the CE marking is a declaration of the manufacturer that its product complies with the relevant, legal European product requirements.
Officially going into effect approximately a year following RoHS, in June of 2007, Registration, Evaluation, Authorization and Restriction of Chemicals, or REACH, keys in on chemicals and applies to manufacturers that mass produce them. Specifically, if companies sell products in the EU in amounts of 1 ton or more and those products contain certain chemicals, they must first register with the European Chemicals Agency (ECHA). The list of chemicals deemed to be “substances of very high concern” (SVHC) is extensive. This SVHC distinction is applied to chemicals that are carcinogenic, mutagenic, toxic for reproduction, or persistent, bio-accumulative and toxic.
The overarching REACH requirement is for manufacturers to inform product users or resellers of the chemicals that were used in development. If some of the products contain chemicals cited on the SVHC list, the products must be registered and authorized by ECHA. How much of a certain product is sold determines how long manufacturers have to get them registered. The less they sell in terms of tonnage, the longer they have to comply.
While there are no specific symbol requirements under REACH, your product safety labels, their materials, and how they’re manufactured are part of your compliance process; you’ll want to ensure that your product safety labels are in compliance with REACH to eliminate fees and issues with ECHA and the EU.
Directive Symbols and Labeling
For a more in-depth look at regulatory compliance labeling, including current updates to the directives, and the on-product symbols to be used, read my latest article in INCompliance Magazine.
And for questions and considerations regarding your product’s labels, keep in mind that Clarion Safety is your product safety and compliance protocol headquarters – our team is standing by and ready to help!
Erin Earley is head of communications at Clarion Safety. She has been writing about best practices for visual safety communication for nearly a decade, including through an ongoing column in INCompliance Magazine, covering on-product warnings and symbol design for its electrical engineering audience.