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For many electronics manufacturers who export their products to Europe, or make components that end up there, the looming European Directive deadlines present an opportunity to integrate processes that will assist compliance into their ISO 14001 Environmental Management System (EMS).  The Waste Electrical and Electronic Equipment (WEEE) Directive has an August 13, 2005 deadline to set up recycling programs in each of the 25 European Union (EU) countries to which you may export product. The Restriction on Hazardous Substances (RoHS) has a July 1, 2006 deadline to eliminate certain restricted substances, most notably lead from products.  While there are still many questions relative to these EU Directives, there is no indication that the deadlines will be extended.

• An ISO 14001 EMS provides a structured approach to dealing with these issues.  If you manufacture electronics, consider integrating compliance with the EU Directives into the following elements of your EMS.
   

• Environmental Aspects: Have you considered the environmental aspects of your products in light of the EU directives?  They could turn out to be significant, depending on the level of business you do with the EU.
   

• Legal & Other Requirements:  The EU Directives and methods to stay abreast with them should be part of your approach to compliance with applicable requirements.  They pose the potential to have a greater impact on your business than any federal or state regulation.
   

• Objectives & Targets:  For many electronics manufacturers the rush to eliminate restricted substances or set up recycling in the EU is a very real objective with a deadline that is a true target.
   

• Environmental Management Programs:  If you are running a project to eliminate a restricted substance, keeping track of its progress is critical to your business being able to operate in the EU marketplace.
   

• Structure & Responsibility:  Consider including and describing the roles of the design and production teams involved in eliminating restricted substances, and those groups that communicate with European Customers.
   

• Training and Awareness:  Since the EU Directives have the potential to greatly impact your business, a strong awareness from top management to all those involved in design and manufacturing must occur.  Training of key design staff will be essential.
   

• Communication:  Key customers may already be sending your company questionnaires related to restricted substances.   How have you been communicating with your suppliers? The procedures for efficiently responding to these questionnaires and communicating with your key vendors fit into this element.
   

• Operational Control: An opportunity to develop product design procedures that specifically target restricted substances.
   

• Monitoring and Measurement:  Although the actual testing or minimum acceptable concentrations levels have yet to be established for RoHS, testing and documenting substance content could play a very important role in compliance.
   

• Records:  Related product design records and data from vendors relative to hazardous material content all form the background necessary to determine compliance with the EU directives.

For more information on how CAPACCIO can help you incorporate RoHS and WEEE into your EMS please contact Lisa Wilk at lwilk@capaccio.com.

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