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September 2004

Can Recycled BFR Plastics Be Used in New Plastic Housings?
by Michele Raymond

Will Europe’s new material restrictions on electronics hamper U.S. electronics recyclers? That depends who you ask.

While there’s a lot of pressure for local government to start collecting and recycling electronics waste – and for manufacturers to pay at some point – there hasn’t been much discussion of what products the old e-waste materials can go into.

Besides the fact that most electronics are now made in Asia to begin with, the European Union is also restricting what materials can be used in new electronics.

The Restrictions on Hazardous Substances (RoHS) directive bans lead, cadmium, mercury chromium VI and at least two brominated flame retardants (BFRs) in new electronics as of July 2006, with some exemptions. This one directive will cost industry billions to comply with.

But what about recycled components? Can a recycler in the US mix BFR plastics with non-BFR plastics and use them for housings in a new TV that could be sold in Europe?

Initially, a key European Parliament member, Karl-Heinz Florenz, told us no. You’d need to separate out the BFR plastics. In fact, Matsushita Electric in Japan did develop a machine that could separate the BFR plastics from recovered materials.

However, a key European Commission committee has agreed on some clarification language that appears to contradict this – in some ways. While this agreement is not final, nor does it have the force of law, it could provide some hope for those that actually want to get those parts reused.

The language we were told by the EC was agreed July 20 at a Technical Adaptation Committee meeting states, “For purposes of this directive it should be noted that the maximum concentration values refer only to impurities which are unintentionally introduced. Unintentionally introduced shall mean ‘not deliberately utilized in the formation of a materials or component where its continued presence is desired in the final product to provide a specific characteristic, appearance or quality.” The use of recycled materials as feedstock for the manufacture of new products, where some portion of the recycled materials may contain amounts of the regulated materials, is to be considered as unintentionally introduced.”

At press time, no one was even sure that language made it into recommendations made to the Council of Ministers at the EC, because of vacations.

If this language is approved, it is not good for electronics designers, because they could not even use background levels of lead to avoid “whiskering” which leads to chip failures.

However, it does seem to imply that if you can’t sort the BFR plastics from the recycled e-waste stream, and the material finds its way into a European electronics housing or part, the part is still in compliance with RoHS.

This is just one, tiny sub-issue that electronics manufacturers must contend with to attempt compliance with the RoHS and WEEE (waste electronics takeback) directives in Europe. It’s a shame the EC has made the directives so broad – they affect anything with a battery or a cord. The breadth and complexity of the directives will make it nearly impossible for the European countries to effectively enforce.

More information can be found at www.raymond.com.

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