- 06 January 2006 -
Review & Forecast: Environmental Compliance Changes Approach to Business
By Mike Barnstead, Marketing Manager, MacDermid, Inc.
Looking back on the past few years, I see a surface finishing industry in flux. The continued migration of business to offshore locations and the resulting erosion of the American manufacturing base have left the industry with numerous plant closures and significant excess capacity. Rising costs for energy and raw materials are compounding the problem by reducing profitability at all levels of the industry.
State of the Industry: Where Do We Stand? |
|
|
However, I believe the biggest long-term impact will come from another direction. Driven both by governmental legislation and by our own re-evaluation of obligations as good corporate citizens, our increased focus on environmental compliance will have the most significant impact on the way we approach our business. Among the most influential environmental drivers are the RoHS, WEEE, and ELV directives.
The restriction of the use of certain hazardous substances (RoHS, 2002/95/EC) and waste electrical and electronic equipment (WEEE, 2002/96/EC) directives are intended to promote the reuse, recycling and recovery of electrical components. RoHS restricts six substances. WEEE does not specifically ban materials, but closely follows RoHS guidelines. The six RoHS restricted materials are lead, cadmium, mercury, hexavalent chrome, and polybrominated biphenyl (PBB) or polybrominated diphenyl ether (PBDE) flame retardants.
The scope of goods impacted by RoHS and WEEE are:
- Large and small household appliances;
- toys, consumer, IT, leisure, lighting, sports, and telecommunications equipment;
- electrical and electronic tools (with the exception of large-scale stationary industrial tools);
- medical devices (with the exception of all implanted and infected products) (not regulated under RoHS);
- and automatic dispensers.
The maximum concentration values for the six substances will likely be 0.1 weight percent (1,000 parts per million) of lead, mercury, hexavalent chromium, PBB and PBDE and 0.01 weight percent (100 ppm) cadmium in homogeneous materials. A homogeneous material is defined as a single substance, such as one metal part.
 |
New European directives are leading to the creation of more compliant technologies. Pictured are lead- and cadmium-free electroless nickel plated parts made from MacDermid Niklad ELV, an environmentally compliant high phosphorus nickel alloy coating system. |
The RoHS compliance date is July 1. The timing of the WEEE directive will differ between EU member states, as the original enactment date of August 2005 was missed. The WEEE enactment date for EU member states is estimated to occur from the middle to the end of 2006.
End of Life Vehicle (ELV) directives have been enacted by several countries, but arguably the European Union ELV Directive (2000/53/EC) has the most profound impact on our industry. This directive is aimed at waste minimization through recycling, thereby eliminating hazardous waste from landfills. The enactment date for this legislation is July 2007, but several automotive OEMs have adopted their own enactment dates before then. The materials impacted by the ELV Directive 2000/53/EC are cited in Annex II of the directive. The original Annex II dated June 2002 stated, “...lead, cadmium, hexavalent chromium and mercury must not be intentionally introduced or deliberately utilized in the formulation of a material or component…” In September 2005, the verbiage of Annex II was revised to omit the phrase “intentionally introduced.” The revised Annex II (9/20/05) reads, “a maximum concentration value up to 0.1% by weight and per homogeneous material, for lead, hexavalent chromium and mercury and up to 0.01% by weight per homogeneous material for cadmium shall be tolerated.”
Should this revision change the strategy of a metal finisher in seeking ELV compliant technology? Well, in a word, no. Hexavalent-based passivation processes for aluminum, zinc and zinc alloy are not impacted by the change, since they contain more than the 1,000 ppm limit of hexavalent chrome and, therefore, are not ELV compliant, even under the revision.
Looking at electroless nickel, deposits from cadmium brightened systems contain in excess of the allowed 100 ppm of cadmium, so an ELV compliant process would be necessary. Most existing lead stabilized high phos systems contain no cadmium and provide a deposit below the 1,000 ppm limit for lead.
Under the revised Annex II, these existing systems are now ELV compliant. The big question becomes, “for how long?” Now that viable technologies exist which contain no lead or cadmium, it is very likely that future legislation and OEM specifications will focus on the total elimination of lead and cadmium from all electroless nickel plating. With ELV compliant systems available, the time to change to ELV compliant systems is now.
Review & Forecast compiled by Greg Valero, Editor and Publisher.
