ROHS Directive

ROHS is an acronym for “Restriction of Hazardous Substances.” It has a direct impact on the entire electronics industry as well as many electrical products. The directive originated in the EU in 2002. Its focus is on restricting six substances which are hazardous in nature and are commonly found in electronic devices. It is mandated that beginning July 1,2006, all applicable products in the EU must pass ROHS compliance. The ROHS 3 directive added four more substances to the original list. ROHS 3 is effective beginning July 22, 2019.

In order to be ROHS compliant in the year 2020, a business that sells electrical or electronic products, equipment, cables, subassemblies, components or spare parts to ROHS countries or to any other entity such as resellers, distributors or integrators who in turn sell products to such countries is impacted if they use any of the ten listed substances.

The EU ROHS specifies maximum limits for the following substances, which are restricted (ppm: Parts per million):

  • • Cadmium < 100 ppm
  • • Lead < 1,000 ppm
  • • Mercury < 1,000 ppm
  • • Hexavalent Chromium < 1,000 ppm
  • • Polybrominated Biphenyls < 1,000 ppm
  • • Polybrominated Diphenyl Ethers < 1,000 ppm
  • • Bis (2 -Ethylhexyl) phthalate < 1.000 ppm
  • • Benzyl butyl phthalate < 1,000 ppm
  • • Dibutyl phthalate < 1,000 ppm
  • • Diisobutyl phthalate < 1,000 ppm.

R2 Standard

The R2 standard deals with safely disposing waste electronics. It was developed and is certified by SERI which is the housing body and ANSI-accredited standards development organization for the same.

The R2 standard exists due to a collaborative partnership between public, private and nonprofit sectors. R2 stands for “Responsible Recycling” practices for use in accredited certification programs. It is the results of the US Environment Protection Agency’s (EPA) push to convene a multistakeholder process to create a voluntary, market-based mechanism to ensure best practices in electronic recycling (

The standard was developed as the result of a transparent, balanced and consensus- based process. Different stakeholders were included in the group including representatives from the following:

  • • US EPA.
  • • Regulators from various state agencies.
  • • Electronics recyclers, refurbishers and representatives from their respective trade organizations.
  • • Original equipment manufacturers (OEMs) and customers of electronics recycling services.
  • • Non-government organizations.

Electronics recyclers can gain R2 certification. Certified electronics recyclers have demonstrated through audits and otherwise that they continually meet specific high environmental standards. They have also demonstrated that they can safely manage used electronics. The benefits of gaining R2 certification are as follows:

  • • Reduction of environmental and human health impact occurring as a result of improper recycling.
  • • Providing increased access to quality reusable and refurbished equipment to potential customers.
  • • Reduction of energy use and environmental impact associated with mining and processing of virgin materials, thereby conserving natural resources that are limited (

E Stewards Standard

The e stewards standard is a company-level certification based on a standard that was developed by the US EPA and industry partners. The certification applies to electronics recyclers, asset recovery companies, refiners, processors and other entities in the electronics industry. The standard requires the following (

  • • Secure data: All stored data from electronic devices must be destroyed.
  • • Best recycling practices: Toxic electronic waste should be managed in keeping with the best available practices in order to protect workers and the environment.
  • • Ethical labor: All child labor, coerced labor and prison labor are banned.
  • • Toxic materials should be responsibly managed downstream: Recyclers that are e stewards certified should track all toxic materials downstream and ensure that they are properly managed.
  • • Legal and responsible exports: Based on international law (Basel Convention), export of toxic electronic waste to developing countries is not allowed.
  • • Organization-wide conformance: All facilities and operations belonging to the company in each country should be in conformance with the certification.

Environmental Laws in China

BBC reports as of July 2019 that Shanghai has become the first Chinese city to make it mandatory for residents to sort and recycle household trash ( world-asia-china-48847062). Noncompliance is likely to incur heavy fines and detrimentally impact residents’ credit rating. The most populous city in the world with more than 24 million residents currently recycles about 10% of its waste. According to official statistics, 3,300 tons of recyclables are collected every day. According to

Xinhua News Agency, Shanghai produces nine million tons of trash every year. The new legislation requires trash to be divided into the follow'ing four categories:

  • • Recyclable goods such as cans and bottles.
  • • Harmful waste such as batteries and medicine.
  • • Kitchen waste including food.
  • • Other waste.

Entities including individuals and organizations who are found to not be in compliance w'ith this law will be subjected to substantial fines. For example, non-complying individuals can be fined up to 200 yuan whereas organizations could be fined up to 50,000 yuan.

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