RoHS: Europe's Initiative to Control Technological Waste

By Jennifer Manning

[Apr 8, 2007]

Anyone who has bought a cell phone, a digital music player, a computer, or other electronic product knows the problem - the technology changes so quickly that your purchase is often outdated within months. This is a source not only of mounting frustrations and expense, but also of mounting hazardous technological waste.

What will be done with the debris of the information age? The European Union (EU) member states have already taken the problem under advisement, and are taking action and holding manufacturers responsible for the hazardous materials in their products. They passed a directive called RoHS, which is a cause for both celebration and consternation.

What is RoHS?

In January 2003, the European Parliament and the Council of the European Union agreed to Directive 2002/05/EC, otherwise known as the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Directive, or RoHS. RoHS directly speaks to the growing problem of discarded electrical and electronic equipment, or EEE; more specifically, to their components and byproducts that can biodegrade or otherwise leach hazardous materials into the environment.

RoHS even takes into account the fact that technology has a high turnover rate: The 2003 issuance stated that "Before 13 February 2005, the Commission shall review the measures provided for in this Directive to take into account, as necessary, new scientific evidence" (Official Journal of the European Union, 2003). As a result of that review, as of June 1, 2006, all products on the European marketplace were required to be RoHS compliant.

The scope of RoHS is broad and takes into consideration electronics that are often largely ignored by the hazardous waste community - everything from toys to high-end computers. According to Britain's National Weights and Measures Laboratory (NWML), the directive includes items such as large household products (e.g., washing machines, microwaves); small household products (e.g., vacuum cleaners, toasters); IT and telecommunications equipment (e.g., laptop computers, mobile phones); consumer equipment (e.g., video cameras); electrical and electronic tools (e.g., drills); and toys, leisure, and sports equipment (e.g., electric trains, video games) (RoHS website, accessed April 23, 2007).

What Hazmats Does RoHS Regulate?

The EU identified six contaminants that can occur in EEE and that were restricted after July 1, 2006:

  • Lead
  • Mercury
  • Cadmium
  • Hexavalent chromium
  • Polybrominated biphenyls (PBBs)
  • Polybrominated diphenyl ethers (PBDEs)

While lead and mercury, for example, are already well established in the hazmats lexicon, some of the other materials are less well known and are not approached with the same care in the US as they are abroad.

A case in point are PBBs. Typically used as flame retardants, they have minimal government oversight despite what could be considered an environmental near-catastrophe: in 1973 and 1974, cattle on several farms in Michigan were accidentally given PBB-contaminated food (G.F. Fries, 1985). PBBs appear to be highly mobile; after the accident they were disposed of in a landfill, from which they spread throughout the state's groundwater. During Phase I investigations, "test wells show[ed] traces of PBBs in the aquifer in all directions" (B.P. Shah, 1978).

Because of the mobility of PBBs, this poisoning event " led to widespread livestock contamination and ultimately to contamination of virtually every human residing in the State at that time" (J.N. Miceli et al., 1985). In addition to cattle, other animals were contaminated and ultimately destroyed.

It sometimes happens that environmental disasters teach the most about contaminants and their effects; as a result of the Michigan event, there is evidence for endocrinological impacts of PBBs, and studies in animal models show impact to the nervous and immune systems, kidneys, liver, and other bodily systems.

However, despite this accident and the evidence for harm from PBBs, the Centers for Disease Control/Department of Health and Human Services says that "At present, there are no current guidelines or recommendations for protecting human health from exposure to PBBs" (Agency for Toxic Substances and Disease Registry [ATSDR], 2007).

While the US may be standing down, Europe is leading the charge in assessing the damage done by common materials such as the six identified in RoHS. However, the level to which RoHS is policed varies, and the level of adherence by manufacturers varies - largely because compliance can have a costly impact on businesses.

What is the Impact of RoHS on Business and Technology?

It is up to each of the EU member states to enforce RoHS as it sees fit; because it is a directive, RoHS does not lay down the law. While this gives freedom to member states, it can cause a bind for manufacturers who must research and comply with multiple guidelines.

In Germany alone, for example, there are multiple layers of RoHS and EEE disposal implementation for everyone - consumers, manufacturers, etc. - to deal with. A spokesman for a German agency that reviews RoHS stated: "'If companies have difficulties becoming RoHS-compliant, they won't talk about it Most companies' component manufacturers stated simply that they were RoHS-compliant in early 2006, but declined to elaborate'" (Electronic News, 2006).

High-profile, high-production companies that have saturated the international market, such as Apple, have had to recall products from the European market. With regard to one of its most popular products, Apple says that "iPod's RoHS compliance came months ahead of the July 2006 deadline set by the European Union. Most of the materials covered by the RoHS directive, including mercury, cadmium, hexavalent chromium, and brominated flame retardants, were voluntarily eliminated from all Apple products years ago" (Apple website, accessed April 19, 2007).

However, not all of Apple's products met every RoHS requirement and some were withdrawn from the European market; according to one source, "these products include the iSight, AirPort Base Station With Modem, AirPort Base Station Power Over Ethernet & Antenna, iPod shuffle External Battery Pack and all versions of the eMac all-in-one desktop computer" (, accessed April 19, 2007).

As indicated by the problem Apple encountered, the multiple components of RoHS make it challenging for companies to be in full accord with the guidance.

Another international electronics firm, Nokia, spoke of this difficulty. As reported by Electronic News, Markus Terho, director of environmental affairs at Nokia, said, "'Technological implementation has been straightforward; the burden has been, and still is, that the legal requirements keep changing.'"

Also challenging to businesses is the actual cost of being in compliance. In the case of Nokia, Terho states that "We have tens of thousands of engineers and have hired more because of the rapid technology changes--all of whom spend time implementing changes. How much this extra work costs we have not calculated'" (Electronic News, 2007).

Most small businesses just are not able to attain this level of manpower. And since every part of every electronic device must be RoHS compliant - even a piece of wire is enough to keep merchandise off market - entire products must be redesigned, often at great cost. While this is of great difficulty to large producers, it can be crushing to small manufacturers. To cite just one example of how RoHS affects the electronics market: "For the most fortunate passive component manufacturers, the net effect of RoHS legislation was just to require them to change the tin/lead terminations on devices to a lead-free substitute Other components get off less lightly" (, April 2, 2007).

It should be no surprise, then, that the guidance designed to regulate industry is, in turn, spawning new industry; a spate of new companies has already started up to guide manufacturers and others affected by RoHS through the directive, helping to ensure compliance.

The EU is leading the way controlling the toxic waste of the information age, and is closely followed by India and China. Will the US follow? As the global technology market becomes increasingly so, and consumer awareness of health and environmental hazards grows, companies that do not utilize safe materials and dispose of hazardous ones properly may find themselves the last choice of consumers - no matter the cost.

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  • Agency for Toxic Substances and Disease Registry (ATSDR). ToxFAQs™ for Polybrominated Biphenyls (PBBs) (Bifenilos Polibromados). September 2004. Web page updated January 18, 2007.
  • BBC News. December 15, 2004. "PC ownership to 'double by 2010'." Website: Accessed April 16, 2007.
  • Electronic News. "Germany Closed Mouth on RoHS, Open Book on WEEE" by John F. Mason. May 25, 2006.
  • Electronic News. "Life with RoHS: How is the directive doing in Europe today?" by John F. Mason. 3/27/2007.
  • Fries, G.F. "The PBB episode in Michigan: an overall appraisal." Crit Rev Toxicol. 1985;16(2):105-56.
  • Miceli, J.N., D.C. Nolan, B. Marks, and M. Hariharan. "Persistence of polybrominated biphenyls (PBB) in human post-mortem tissue." Environ. Health Perspect. 1985; May; 60: 399-403.
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  • US Environmental Protection Agency (USEPA). "Polybrominated Diphenyl Ethers (PBDEs) Project Plan." March 2006.
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