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Regulatory Information

European Take Back Regulations

Extended Producer Responsibility (EPR) as defined by the OECD is "an environmental policy approach in which a producer's responsibility for a product is extended to the post-consumer stage of a product's life cycle." This concept has been extended to many products such as batteries, oil, and electronic products through "take-back" regulations. These regulations require manufacturers to collect used household electronics for recycling and/or recovery.


Restrictions of Hazardous Substances: RoHS (pronounced "rows"), originally published in 2002 (2002/95/EC), the Directive restricts the use of certain substances in electrical and electronic equipment. The Directive says: "Member states shall ensure that, from 1 July 2006, new electrical and electronic equipment put on the market does not contain lead (Pb), mercury (Hg), cadmium (Cd), hexavalent chromium (CrVI), polybrominated biphenyls (PBB) or polybrominated diphenyl ethers (PBDE)" (in sum, "Restricted Hazardous Substances"). This only affects a coating if (1) the coatings contain RoHS-listed substances and (2) the coatings are applied to electrical or electronic equipment.

In 2011, the Directive was recast (2011/65/EU). The revised Directive gradually extends the requirements to additional components and requires a review of the regulated substances to determine if additional restrictions are warranted. The applicability requirements for coatings noted above are unchanged.


"Waste Electrical and Electronic Equipment" comes from a Commission Decision of 18 August 2005 (2005/618/EC), also effective 1 July 2006, which amended the RoHS Directive to "tolerate" a maximum concentration value of 0.1% by weight in homogeneous materials for Pb, Hg, CrVI, PBB, and PBDE and 0.01% by weight of homogeneous materials for Cd. (See also Directive 2002/96/EC of 27 January 2003 on waste electrical and electronic equipment.) The current Directive remains in force until 15 August 2018 when revisions adopted in 2012 under 2012/19/EU on waste electrical and electronic equipment (WEEE) (Recast) come into force.

This directive requires the company placing the original electrical item on the market to establish a mechanism for collecting and recycling that item. Where an item was manufactured prior to the regulation coming into force, it is not clear who is responsible for recycling that item (e.g. if you buy a new washing machine, who is responsible for disposing of the old electrical item?). Each Member State is responsible for establishing mechanisms for collecting, transporting, and recycling of electronic items, with the costs and responsibilities shared between producers and municipalities. Small household appliances are one of ten (10) categories regulated under the 2005 Directive and which will continue to be regulated under the 2012 Recast Directive. This Directive does not apply to nonstick coatings; however it does apply to appliances that have nonstick coatings.

Norway PoHS

Norway has adopted regulations entitled Prohibition on Certain Hazardous Substances in Consumer Products. These regulations restrict the use of 18 substances in consumer products, and the only overlaps with the substances regulated in the EU RoHS regulations are lead and cadmium. The regulation applies to electronic and electrical equipment, but it does not apply to food-contact materials.

Turkey RoHS

Turkey's RoHS regulations became effective in June 2014. Manufacturers must submit a Conformity Declaration Form to the Turkish government annually and maintain records demonstrating compliance with the requirements for five years.


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