What is the Legislation?

Are there exemptions?

WEEE Directive

The Waste Electrical & Electronic Equipment (WEEE) Directive became European law on 13th February 2003, and states that all member states must implement the Directive by 13th August 2004.

The start date in the UK for when producers will have to meet recovery, recycling, and re-use targets as set out in the Directive is still undetermined and has been postponed until 2007 subject to Government review.

Historic waste, ie that which has no traceable provenance to a supplier and was in service prior to the legislation coming into effect is the responsibility of the end user.

The WEEE Directive encourages and sets criteria for the collection, treatment, recycling and recovery of WEEE.

WEEE targets within the IT and telecommunications sector are:

Re-Use	65% by average appliance weighed	Modular and component re-use as spares for legacy infrastructures.
Recycling	65% by average appliance weighed	Recycling to precious metals, base metals, plastic, glass, etc. at specialist recycling plants.
Recovery	75% by average appliance weighed	Energy produced by burning non-recyclable scrap.

Download the WEEE Directives here (2002/96/EC), (2003/108/EC).

RoHS Directive

The Restriction on Hazardous Substances Directive (RoHS) also became law on 13th February 2003, and as with the WEEE Directive, should be implemented by all member states by 13th August 2004.

The RoHS Directive states that by July 2006, new products must not contain more than the maximum permitted by weight of these substances:-

Substance	Level by Weight
Lead	0.1%
Mercury	0.1%
Cadmium	0.01%
Hexavalent Chromium	0.1%
Polybrominated biphenyls (PBBs)	0.1%
Polybrominated diphenyl ethers (PBDEs)	0.1%

		Download the RoHS Directive here (2002/95/EC).
		Download the latest UK Government Guidance Notes on the RoHS Regulations.
		Download the Chronos Statement on WEEE and RoHS

Exemptions for Industrial use Equipment

Extracts (in italics) from the Nov 2005 UK Government Guidance Notes on the RoHS Regulations

Requirements (on Page 4) states that “Certain applications (listed in Annex C) are exempt and there is also an exemption for spare parts for the repair of equipment put on the market before 1 July 2006.”

Annex C Section 8 (Page 18). Lead in solders for servers, storage and storage array systems, network infrastructure equipment for switching, signaling, transmission as well as network management for telecommunication.

For the purpose of the RoHS Regulations, ‘network infrastructure equipment for telecommunication purposes’ is viewed by the Department as equipment meeting one of the two following criteria:

Any system used for routing, switching, signalling, transmission, or network management or network security; or

Any system which can simultaneously enable more than one end user terminating equipment to connect to a network.

It is also any such system in a network, except for end user terminating equipment such as voice terminals and facsimile machines.

This would include all servers, power suppliers, display devices and similar electronic units that are incorporated into network infrastructure equipment. It would also include all cables and cable assemblies, and all connectors and connector assemblies used to provide interconnections for network infrastructure equipment but is not intended to include desktop or notebook computers, telephones, fax machines or consumer – type modems or switches etc.

It is our opinion that the majority of professional network infrastructure equipment provided by Chronos Technology Ltd including specifically Symmetricom synchronisation equipment, Chronos SyncWatch and DPS Telecom remote monitoring equipment falls within the “exemptions” defined in Annex C.

Also many of our RF & Microwave components will find their way into applications which fall within Annex C, however there is a big danger that over-zealous adherence to these blanket regulations will cause unnecessary redesign of professional industrial equipment. Many older components will be unable to be redesigned to be lead free, so a careful analysis of the Decision Tree in Annex B of the dti guidelines needs to take place to ensure redesign effort and energy is not wasted unnecessarily.