WEEE: the other directive.

The WEEE deadline is now two months away. Are you WEEE-compliant? Do you know what WEEE (Waste from Electrical and Electronic Equipment) is? The EU's WEEE deadline of August 13, 2005 is sneaking up quickly. It snuck up so fast that most of the countries in the EU--everyone but Greece, Belgium and the Czech Republic--missed their own 2004 deadlines for writing the WEEE requirements into national laws. But governments can be late in the WEEE compliance game. If your company is late, you may be fined or even banned from importing into the EU.

WEEE, also known as the recycling rule, hasn't struck fear in the hearts of strong men the way RollS (Restrictions of Hazardous Substances) has. Much of the power behind RollS may derive from its uncertain pronunciation. I've heard "Ross," "Roce" and "Rohahs," with the last being the apparent frontrunner. WEEE has an almost playful connotation, reminiscent of an exclamation we uttered when riding bicycles down steep hills as children.

But WEEE is no joke. WEEE requires all companies selling electrical and electronics products bearing their trade names in the EU to arrange and pay for those products' collection, treatment, recycling, recovery and disposal. If your name is on it, you're responsible for it until the end of its life. Or its end-of-life situation, as some procurement managers refer to it.

WEEE mandates that companies post recycling markings (a crossed-out trash can) on their products and provide reuse centers and treatment and recycling facilities with documentation showing the location of hazardous materials in their products. This information must be made available to recyclers within 12 month's of a product's release.

What's hazardous, you ask? According to Annex II of WEEE, the following items must be separated from waste products for special processing: printed circuit assemblies greater than 10 [cm.sup.2], batteries, components containing mercury, LCDs greater than 100 [cm.sup.2], cathode ray tubes, capacitors, brominated plastics, external electric cables and refractory ceramic fibers, as well as some slam-dunk hazards, such as radioactive and asbestos-containing materials.

This will all be managed and funded by the private sector.

The RoHS directive has technologists working overtime trying to create the best lead-free solders and surface finishes. But while it's not as technically complex as RollS, WEEE has the potential to be an administrative nightmare. OEMs are auditing their suppliers; many have set up "compliance risk management roadmaps" and become experts on each product's "theoretical recyclability."

To sell product in the EU, you'll have to register with the country you're selling to. But myriad questions remain. Can there be more than one "producer" of a product? Should your company achieve compliance individually, or should you join other companies for collective compliance? If you import into, say, Germany, but your products are shipped throughout the EU, must you also register in each of those countries?

Exemptions so far include military, large-scale stationary industrial tools, implanted medical devices, and electrical and electronic equipment that's part of another piece of equipment. But doesn't that last exemption cover most electronic parts?

There aren't many definitive answers coming out of the EU regarding WEEE, or RoHS for that matter. But the UK's Department for Productivity, Trade and Industry (still known as DTI) has released draft documents explaining how the government will administer the regulations, and guidance on how producers can support compliance.

All of the EU member states will eventually draft WEEE legislation and provide compliance guidelines, and then the fun will really begin. In the meantime, keep reading our monthly iNEMI column "Countdown to Lead-Free," running through the July 2006 Rolls deadline.