Ten steps to compliance

Alasdair Denton Miller of Flextronics Europe gives practical advice for implementing green product design principles in the face of the RoHS and WEEE directives

The RoHS and WEEE directives will impact every electrical and electronic equipment manufacturer and importer selling products in Europe. Preparation must begin now. Aimed at reducing electrical and electronic equipment waste that could harm the environment, the directives require OEMs to make fundamental and stringent changes to their production processes and product lifecycles. Flextronics suggests the following ten practical steps on moving forward:

1 Review the directives carefully: Download the directives from the DTI website (www.dti.gov.uk). If you don’t already have one, create a team that will consider how the regulations will impact your business, from product design, operations and logistics to product end-of-life.

2 Match the requirements to your own operations: Consider your products, production processes and sales channels. Determine how your company will be classified under the legislation. If you are manufacturing or importing products under your own brand name, you will be classified as a “Producer”, meaning you will be financially responsible for end of life treatment of your products. Plan accordingly.

3 Establish/revise procedures and instructions for design and manufacturing: Introduce the requirements into procedures or establish new ones where appropriate. Adopt the Design for Environment guidelines for product design groups and the implementation of green procurement and manufacturing.

4 Communicate the requirements within the organisation: Disseminate information to appropriate personnel and ensure that everyone is aware of what the legislation says, why it must be implemented and how it affects them.

5 Clarify ownership of responsibilities with customers: Ensure that you understand exactly what the customer’s requirements are, and make sure there are no grey areas when documenting who is responsible for what. Be aware that meeting the directives may introduce additional cost. In dealing with customer-supplied bills of materials (BoMs), ensure that the customer is also aware of the directives and that any BoMs supplied to you list compliant components.

6 Communicate requirements to suppliers: Ensure suppliers are aware of the requirements. Many will not, particularly non-European suppliers. Some suppliers may not or will not provide compliant components, meaning you must identify and qualify new suppliers. Where compliant components are not available product redesign will be necessary.

7 Establish procedures for records that verify compliance: You must be able to prove that you have audited your supply base and provide documentation. Have a plan for proving products’ compliance. Determine how you will discharge your recycling obligations: will you do this yourselves or join an industry scheme? How will you prove that you have?

8 Invest in necessary equipment and training: New equipment may be required or existing equipment may need to be upgraded. Equipment operating procedures and profiles will need to be changed. Ensure that any equipment issues are identified and that budget is allocated. Train staff to ensure they understand your compliance strategy.

9 Monitor and audit activities: Internal audits should be performed on a regular basis. Your supply chain should also be audited regularly to monitor compliance and change.

10 Review procedures, programmes and records on a regular basis: Improve efficiency and the degree of compliance. Over time, costs will come down as the requirements become ingrained in your operation. And you will be running a more efficient, environmentally friendly business!

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