Max Robinson
In the area of environmental matters, it's been demonstrated over and over that after Europe introduces environmental regulation, similar action occurs in the United States. First, this action usually occurs in California, then in several additional states, and ultimately federal legislation is enacted. In the case of WEEE and RoHS, the process will receive compelling impetus from economic forces. Indeed, the continued business success of many manufacturing concerns will be influenced not just by compliance, but by proactive work in meeting the requirements. The entire process will be market-driven.


As early as 1998, the European Union (EU) sought to limit the alarmingly large amounts of hazardous wastes that were being delivered to landfill sites. Statistical projections indicated that the volume of such waste would likely grow three to five times faster than other municipal waste. These projections revealed a massive, growing source of environmental contamination.

To address the problem, the member countries of the EU decided to create the Waste Electrical and Electronics Equipment (WEEE) directive. This directive requires manufacturers to work with local government agencies to ensure that electrical and electronic waste is disposed of in an environmentally responsible manner.

Specifically, the purpose of WEEE is to:

  • Improve manufacturers' designs in order to reduce the creation of waste.

  • Make manufacturers responsible for certain phases of waste management.

  • Separate the collection of electronic waste (from other types of waste).

  • Create systems to improve the treatment and recycling of electrical and electronic waste.


    The subsequent RoHS directive in Europe applies to the design, manufacturing, and delivery of products containing certain materials harmful to the environment. RoHS is an acronym that stands for "restriction of use of hazardous substances in electrical and electronic equipment."

    RoHS now affects every manufacturer that sells products containing electrical or electronic components in Europe. The RoHS directive (often pronounced "ro-huss") bans the marketing after July 1, 2006 of any electrical or electronic equipment that contains lead, cadmium, mercury, hexavalent chromium, or the flame retardants polybrominated biphenyl (PBB) and polybrominated dyphenyl ether (PBDE).

    Catalogs from a number of leading suppliers of electronic components indicate RoHS status clearly, item by item. "Item not RoHS compliant-contains Pb" alerts purchasers to find a substitute for a lead-containing component.

    One way of differentiating between WEEE and RoHS is to recognize that RoHS is more related to product technology, starting with design, involving manufacturing, and ending with quality assurance practices and delivery to the customer. WEEE, on the other hand, deals with disposal of the product or failed components replaced during service. WEEE is therefore more concerned with the business and operations of waste handling by authorities (nevertheless, manufacturers are charged with a good deal of responsibility for helping authorities dispose of the waste in an environmentally safe manner).


    Already, California has passed legislation paralleling the WEEE and RoHS directives of the European Union. Other states, including New Jersey, Wisconsin, and Washington, have either enacted or have pending legislation along the same lines. If the future is consistent with history, federal legislation will eventually follow. But as early as Jan. 1, 2007, markets here in the U.S. will likely become restricted by state laws. And if a manufacturer wants to sell products in global markets that include China, the scope and exemptions are currently being finalized there, also.

    Under WEEE laws, manufacturers will have to work with local authorities to accommodate the disposal of listed products.

    The state of California already has in place legislation that mirrors the European regulation. If environmental legislative history has proven anything, it is that as California goes, so goes the nation. One has only to remember the regulation of automobile emissions, oil waste handling, and refrigerant control. In each of those areas, and others, California's initiatives presaged the enactment of national regulations and legislation.

    For many products, WEEE and RoHS have profound implications throughout the life cycle - in design, manufacturing, use, and disposal.


    Refrigerators and freezers are in RoHS Category 1, and are considered "finished products with direct function." The European directive requires that those products be RoHS compliant by July 1, 2006. California's legislation allowing only RoHS-friendly products is effective Jan. 1, 2007. Effective dates have not been decided for legislation in New Jersey, Wisconsin, and Washington.

    Refrigeration racks and display equipment are currently exempt because they fall into the classification "part of a fixed installation." We should probably underscore the word currently.

    Likewise, residential central air conditioning equipment falls under the fixed installation exemption.


    Customers have begun to ask for products, even in the exempt categories, that are already RoHS compliant.


    Manufacturers who supply components for affected products have been working for some time to ensure compliance. For instance, advances have been made in lead-free soldering. Companies have instituted lead-free soldering, avoided use of cadmium in plating and in other applications, and found acceptable substitutes for materials containing hexavalent chromium.

    Every Danfoss factory, for example, is certified under ISO 14001, one of whose requirements is that the company have a functioning environmental management system and seek to self-regulate its environmental impact. Even before becoming ISO 14001 compliant, the company had been working to eliminate toxic materials and waste for many years. Because of these initiatives, many Danfoss products were already in compliance when the RoHS directive was signed.

    Already Danfoss appliance compressors are entirely RoHS compliant. And even though the July 1, 2006 enforcement date does not apply to Danfoss control products and adjustable frequency drives for motor control, those products are already compliant.

    Sidebar: Product Classifications

    The 10 RoHS product classifications are:

    1. Large household appliances

    2. Small household appliances

    3. IT and telecommunications equipment

    4. Lighting equipment

    5. Consumer equipment

    6. Electrical and electronic tools

    7. Toys, leisure, and sports equipment

    8. Medical equipment

    9. Monitoring and adjusting devices

    10. Automatic dispensers

    Max Robinson is principal writer and editor for Technical Communications at Danfoss Inc., Air Conditioning & Refrigeration Division. For more information, visit

    More information about WEEE and RoHS can be found at

    The proceedings and presentations given at the October 2005 NIST (National Institute of Standards and Technology) RoHS conference are found at

    Publication date: 05/15/2006