Between WEEE, RoHS, REACH and other environmental directives, regulatory compliance labels for handling and disposing of certain products is less intuitive than it seems.
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 and electrical 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. Let’s take a look at three of the more common regulatory directives internationally – WEEE, RoHS and Reach – for a primer on what they mean for your labels and the symbols you use.
Short for Waste Electrical and Electronic Equipment, the WEEE Directive (2012/19/EU) was established in 2002, with a number of minor revisions since then. It requires producers of electrical and electronic equipment who sell their products in the EU to operate a recycling program. Its stated purpose is to better protect the ongoing health and sustainability of the environment by informing users that devices may contain harmful contaminants, which can adversely affect the plants and animals if improperly disposed. They include, but aren’t limited to, the following:
- Small and large household appliances
- Telecommunications equipment
- Medical devices
- Lighting equipment
- Automatic dispensers
In the first years of its implementation, the directive exempted industrial products, focusing mainly on waste consumer electrical equipment and electronics. As of August 2018, the directive’s transition period ended and all waste electrical and electronic equipment now fall under it, with the exception of several specific classes of product that are exempt. Exclusions include filament bulbs, non-road mobile machinery for professional use, large-scale stationary industrial tools and active implantable medical devices.
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. See Figure 1. 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. Substances banned under RoHS are lead, mercury, hexavalent chromium, polybrominated biphenyls, polybrominated diphenyl ethers, cadmium and four different phthalates. Manufactured equipment can’t contain more than the specified RoHS limits of these substances.
Any manufacturer that sells to EU member countries must abide by the mandate, including resellers. RoHS has received a number of updates since its original implementation to both better protect the environment and make compliance more manageable. 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. See Figure 2.
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 quite extensive. This SVHC distinction is applied to chemicals that are carcinogenic, mutagenic, toxic for reproduction, or persistent, bio-accumulative and toxic.
Regulation experts point out that REACH took several years to go into effect, a directive that is hundreds of pages in length. It may come as no surprise, then, that REACH compliance is fairly extensive as well. For example, the overarching REACH requirement is for manufacturers to inform users or resellers of the products 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.
As noted by ECHA, businesses throughout the supply chain may be subject to REACH aside from the manufacturer. They include importers, downstream users and some exporters. While there are no specific symbol requirements under REACH, your product safety labels and how they’re manufactured are part of your REACH 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.
Stay tuned for more related to compliance labeling and symbol use in an upcoming On Your Mark column.
Erin Earley, head of communications at Clarion Safety Systems, shares her company’s passion for safer products and workplaces. She’s written extensively about best practices for product safety labels and facility safety signs. Clarion is a member of the ANSI Z535 Committee for Safety Signs and Colors, the U.S. ANSI TAG to ISO/TC 145, and the
U.S. ANSI TAG to ISO 45001. Erin can be reached at firstname.lastname@example.org.