1. US Electronic Product Stewardship
Heather S. Bowman
Electronic Industries Alliance
Director Environmental Affairs and Deputy General Counsel
APEX
February 24, 2004

2. Presentation Overview
Electronic Industries Alliance
Elements of Global Regulations driving Electronics Product Stewardship in the United States
United States Environmental Laws
2004 Legislation – Electronics Recycling
Voluntary Initiatives
Questions/For More Information

3. Standards & Technology
Electronic Industries Alliance
Public Policy
Standards & Technology
Meetings & Networking
2,500 Members
80% of a $430 billion industry
Unique alliance structure
Environmental Issues Council

4. Electronic Industries Alliance “The Whole is Greater Than the Sum of the Individual Parts”
Telecommunications Industry Association (TIA)
(JEDEC)
NSTEP National Science & Technology Education Partnership (Foundation)
Affiliates
Consumer Electronics Association (CEA)
Government Electronics & Information Technology Association (GEIA)
Electronic Components, Assemblies & Materials Association (ECA)
Electronic Representative Association (ERA)
Internet Security Alliance (ISAlliance)
National Association of Relay Manufactures (NARM)

5. Examples of Regulatory Elements
Require Life Cycle Assessments when Products are Designed
Ban Certain Chemicals from Use in Products
Require Consumer Notification and/or Product Labeling at point of sale
Require Electronic Products to Achieve Certain Energy Efficiency During Use
Require Collection and Proper EOL Management
* Europe and parts of Asia in lead; Americas moving forward

6. US Recycling Legislation
Federal Level – US EPA CRT Rule, Thompson legislation, Appropriations language
Maine, Minnesota, Massachusetts, California and Washington all ban CRTs from landfill – either by law or regulation
In September 2003, California Enacted First State Law Establishing a System for Electronics Recycling
SB20 will Impose Fee ($6-$10) on Sale of CRT/Display Products starting in July 2004
Implement EU RoHS directive for covered products in 2007
Working with DTSC and CIWMB to implement fairly

7. Scope of CA SB 20 Scope of Products, per SB 20 definition
Currently only CRTs (TVs, Computer Monitors)
Others, Flat Panel Screens, other Video Display Devices greater than 4” diagonally, subjected to testing
SB 20 RoHS provision references this scope of “covered electronic devices”
Regulations cannot go beyond requirements in other parts of SB 20, i.e. different product scope, etc
Regulations also cannot prohibit product allowed in EU
Chemicals Banned by SB 20 (“presence of certain heavy metals”)
Lead
Mercury
Cadmium
Hexavalent chromium

8. Relevant EU RoHS Exemptions
Mercury in compact fluorescent lamps not exceeding 5 mg per lamp.
Mercury in straight fluorescent lamps for general purposes not exceeding: - halophosphate 10 mg;- triphosphate with normal lifetime 5 mg, long lifetime 8 mg
Mercury in straight fluorescent lamps for special purposes.
Mercury in other lamps not specifically mentioned in this Annex.

9. Relevant EU RoHS Exemptions
Lead in glass of cathode ray tubes, electronic components and fluorescent tubes.
Lead as an alloying element in steel containing up to 0,35% lead by weight, aluminum containing up to 0,4% lead by weight and as a copper alloy containing up to 4% lead by weight.
Lead in high melting temperature type solders (i.e. tin-lead solder alloys containing more than 85% lead), and any lower melting temperature solder required to be used with high melting temperature solder to complete a viable electrical connection
Yellow text addition suggested to the EU TAC in May 2003
Cadmium plating except for applications banned under Directive 91/338/EEC 1.

10. Need Harmonization
SB 20 references RoHS directive as it stood on January 27, 2003
DTSC can implement regulations to track the evolving EU changes
Need ability to evolve regulations after 2007
Industry is also learning more and more as we prepare to comply with the law, so we continue to share information with the TAC (and the Commission) so its decisions are based on the latest scientific and technical evidence available.
In order to ensure harmonization and the ability for companies to market products globally, high tech industry has requested and continues to advocate for IDENTICAL IMPLEMENTATION of RoHS requirements.

11. 2004 US State Legislation
Total of 52 bills introduced (several in some states)
Full Producer Responsibility
MD, MA, MN, NY (cell phones), PA, RI, VT, WI
Advanced Recovery Fee
CA, CT, HI, IL, MD, NE, SC, TN
Landfill Ban or Study Committee
ID (Res), MI, NM, NY, RI, WA (amend)
Combination of ARF/Partial Cost Internalization
Maine – DEP recommendation after Advisory Committee Meetings over summer

12. US Legislation Concerns
Level Playing Field
Enforcement
Consumer reaction
Use of funds and true costs
Consumers
Company
Government
Design Restrictions: Harmonization with EU, China

13. EIA Consumer Education Initiative (www.eiae.org)
Industry Initiatives
EIA Consumer Education Initiative (
Provides Consumers with Recycling and Reuse Opportunities for Electronics
Manufacturers individual voluntary programs listed
EIA Track (
International Regulatory Tracking Database for Electronics Industry
EIA Material Declaration Guide
Industry Supply Chain Procurement Tool to Ensure Global Sale - US, Europe, Japan

14. Conclusions
Diversity in approaches, the book is not closed, wait to evaluate how any of the laws will apply in practice
Jurisdictions differ on elements of product stewardship bills, however many common elements:
Landfill bans
Fees (point of sale or point of disposal)
Chemical bans
Producer responsibly
Voluntary / Market driven
Over next 5 years anticipate jurisdictions without take back laws may see pressure to enact

15. Heather Bowman For More Information: Director of Environmental Affairs
Deputy General Counsel
Electronic Industries Alliance
2500 Wilson Blvd
Arlington, VA 22201
Tel: (703)
Fax: (703)