What the EU’s waste framework directive means for electronics recyclers around the world

Europe leads the way in the collection and recycling of waste electrical and electronic equipment (WEEE) as well as setting standards for the reduction of toxic substance content in EEE. These efforts are good news for recyclers everywhere. The latest addition to these efforts is the EU’s SCIP (Substances Contained In Products) database, which provides more visibility into the chemicals the WEEE recycling stream contains. But first, to set the stage, these are some of the related milestones from the past two decades.

Origins of WEEE recycling

The Waste Electrical and Electronic Equipment Directive, effective since 2003, requires the collection of end-of-life equipment in EU member states, thus ensuring incoming WEEE material streams for recycling operations. WEEE was revised in 2014 with provisions for the treatment of items including batteries, PWBs (printed wiring board) and cables. The revisions also (1) required financing to enable free collection of WEEE from consumers; (2) using the crossed-out wheelie bin label to help with separation of WEEE from other household waste; and (3) required target recycling rates, metrics and reporting.

A significant complicating factor in any recycling regime is dealing with hazardous substances. Toxic substance reduction took a major step in 2006 with the EU’s RoHS (Restriction of Hazardous Substances) directive, which limited the use of four heavy metals—lead, cadmium, mercury and hexavalent chromium—as well as two families of brominated flame retardants in EEE. These substance restrictions later were expanded in 2019 to cover four phthalates used as plasticizers and softening agents. These regulations helped improve but not eliminate health and safety precautions within recycling operations. In addition, they largely have been adopted by global electronics manufacturers, so the benefits should apply to many other regions as well.

The “Ecodesign Directive” of 2009 laid out a framework to accomplish reuse of operational equipment first, followed by recycling and recovery of materials and/or energy. One of the main themes of the directive was for designers of EEE goods to consider the entire life cycle of the product, including how it could be properly treated at the end of its useful life. In addition to binding requirements in the Ecodesign Directive, a number of voluntary certifications and eco-label programs were adopted widely, such as the Electronic Product Environmental Assessment Tool, or EPEAT, administered by the Global Electronics Council. Programs such as these have improved the environmental performance of high-volume products and made these features more transparent to the user. The products covered by EPEAT at this time are computers and displays, imaging equipment, mobile phones, photovoltaic modules and inverters, servers and televisions.

For a manufacturer to receive EPEAT certification, a points system is used to score the product in different categories ranking environmental considerations:

• reduction or elimination of environmentally sensitive materials;
• materials selection in general;
• design for end of life; and
• end-of-life management by the manufacturer.

Because avoiding toxic substances is a requirement to receive EPEAT certification, certification is not always possible with today’s limited choices of certain components and materials. While many high-volume products are covered by EPEAT, clearly many other equipment categories are not. Other types of eco-labels and environmental product declarations continue to develop for other kinds of products. The important message is that all these incentives are in the best interest of recyclers because they help improve the recyclability of products and control hazardous substance content.

Responsible manufacturers work to select components and materials with minimal environmental impact, obtaining environmental product certifications and declarations where possible and if applicable. More generally, manufacturers attempt to communicate their commitment to recognize and publicly track progress through their own sustainability, corporate citizenship and product stewardship programs. As part of these efforts, manufacturers might impose strict supplier requirements covering the same concerns.

Circular economy

Building on these regulations and product certifications, the EU Waste Framework Directive, revised in 2008, put product life cycle stages together in a unified strategy and prioritized them: waste prevention, preparing for reuse, recycling, recovery and disposal.

Waste prevention in the design of EEE is the best approach to the extent that it can be achieved. Reuse of a functional product or its parts should be considered next. Finally, recycling and recovery are the next best approaches to minimize actual waste. A circular economy works toward efficient, closed-loop material recovery, not unlike nature, which reuses matter over and over for sustaining new life.

To help best achieve the framework’s goals, in the 2018 update to the Waste Framework Directive, a public database was established for reporting substances of very high concern (SVHC). The database, which contains a list of some 211 substances as of January 2021, is required by the EU REACH (Registration, Evaluation, Authorization and Restriction of Chemicals) directive. REACH requires manufacturers of all types of articles placed on the EU market to provide free notifications of such substances when present in articles at greater than 0.1 percent, along with safe use information. This new database, called SCIP (Substances of Concern In Products), went live for manufacturer reporting in January. Literally millions of articles with SVHC already have been reported to SCIP, which includes all types of products, only some of which are EEE. According to ECHA’s “Understanding WFD” page, https://echa.europa.eu/understanding-wfd, the SCIP database has three main objectives (highlights have been added):

1. “Decrease the generation of waste containing hazardous substances by supporting the substitution of substances of concern in articles placed on the EU market.
2. Make information available to further improve waste treatment operations.
3. Allow authorities to monitor the use of substances of concern in articles and initiate appropriate actions over the whole life cycle of articles, including at their waste stage.”

The SCIP database complements the existing communication and notification obligations for products containing REACH SVHC.

The new goals of SCIP are shown another way in this graphic published by ECHA:

In addition to “pushing for substitution” of hazardous substance in waste and generation of waste in general, an important base of the triangle is once again to improve waste treatment operations, that is, recycling of goods, including EEE.

What SCIP will mean

ECHA’s promised user-accessible SCIP database is still under development for rollout to the public some time in 2021. With the number of products containing SVHC already in the millions in the first month of the SCIP database’s operation, it is easy to imagine that finding useful information could be overwhelming.

Through the regulatory and voluntary product certification efforts mentioned above, many of the latest EEE products are now free of many SVHC. The EU regulations have greatly reduced the toxic substance content of EEE, for example, through the use of lead-free solder. It is anticipated that some general trends will be discoverable in the massive SCIP database that could take some time and experience to fully use. When the user-accessible SCIP database goes live, please consult it directly for more specific information.

As always, the best health and safety practices in recycling operations should be followed. Some examples of helpful standards and organizations include RIOS (Recycling Industry Operating Standard (RIOS), R2 (Responsible Recycling)  or the alliance between the two; and achieving certification under the ISO 14000 series of environmental management standards. These provide excellent and practical guidance to implement best practices.

Things are improving for companies involved in recycling EEE as the circular economy grows. The SCIP database also will allow regulators to piece together main categories of goods, which range from toys and clothing to high-tech electronics and everything in between. It is a bold new step with great prospects to help us all on this small planet.

Roger L. Franz is with TE Connectivity, a Swiss company that offers a broad range of connectivity and sensor solutions, proven in the harshest environments, that enable advancements in transportation, industrial applications, medical technology, energy, data communications and the home. He is based in Pennsylvania and can be contacted at roger.franz@te.com.