MODULE 5

Restrictions on use of Hazardous Substances (ROHS)

Hazardous substances in e-waste

E-waste contains several toxic additives or hazardous substances, such as, hazardous (highly
toxic), and non-hazardous; both types have potential negative environmental impacts. Hazardous
substances are – Beryllium (Be), Cadmium (Cd),
Chromium (Cr), Lead (Pb), Mercury (Hg), Brominated Flame Retardants (BFRs),
Chlorofluorocarbon (CFCs), Hydro chlorofluorocarbon (HCFCs), PVC (Poly Vinyl Chloride)
and phosphorus compounds. Many organic pollutants such as polyaromatic hydrocarbons
(PAHs), Poly Chlorinated Biphenyl, BFRs,

Poly Brominated Diphenyl Ethers (PBDEs), and polychlorinated dibenzo-p-dioxin furans

(PCDD/Fs)) are released into the environment during improper e-waste processing (Awasthi et
al. 2016: 259). A total of 50 tonne of mercury and 71 kt (kilo tonne) of BFR plastics are found in
globally undocumented flows of e-waste annually, which is largely released into the environment
and impacts the health of the exposed workers (Forti et al. 2020). Non-hazardous substances are
base metals (Copper, Selenium, and Zinc) and precious metals (Gold, Silver and Platinum).
EU legislation includes the following regulatory frameworks –

(i) RoHS Directive (2002/95/EC – RoHS1) by EU) in 2003 and subsequent amendments
in 2011 (2011/65/EU – RoHS2), 2017 (amending Annex II of RoHS2), and Directive (EU)
2015/863 – RoHS3
(ii) WEEE Directive (2002/96/EC), 2003 and WEEE 2 (Directive 2012/19/EU), 2014; and
(iii) The regulation on REACH (Registration, Evaluation, Authorization, and Restrictions of
Chemical Substances) (EC 1907/2006).

RoHS directives

The RoHS (Restriction of Hazardous Substances) directive restricts the use of certain hazardous
substances in electrical and electronic equipment (EEE) to protect the environment and human
health. It is an EU directive, but many countries and regions have adopted similar
regulations. The directive limits the presence of substances like lead, cadmium, mercury, and
others in EEE products sold in the EU.
This EU legislations (RoHS 1,2,3) restrict the use of hazardous substances in EEE, promoting
the collection and recycling and/or reuse of EEE, and consumers returning their used WEEE free
of charge.
The Directive on the RoHS (2002/95/EC) is companion legislation to the WEEE Directive.
Unlike the WEEE Directive, the RoHS Directive is enacted by Article 95 of the Treaty
establishing the European Community (Treaty Amsterdam 1997), which has much less flexibility
that those enacted by article 175 such as the WEEE Directive.
The RoHS Directive is set out in ten articles and an associated annex and should
be read in tandem with its sister legislation – the WEEE Directive.

• The RoHS1 required that any product in scope should not contain any of the six restricted
substances (Lead, Mercury, Cadmium, Hexavalent Chromium and Flame Retardants –
Poly Brominated Biphenyls (PBB) or PBDE) and its weight; the company (manufacturer,
importer, or distributor) placing the product on the EU market should maintain records to
show compliance; and these restricted substances need to be substituted by safer
alternatives.
• The RoHS2 requires additional compliance, that is, record keeping from everyone in the
supply chain at least for ten years (including a conformity assessment, CE marking,
maintenance of compliance throughout production, and self-reporting of non-
compliance).
• The RoHS3, or the Directive 2015/863, adds four additional restricted substances
(phthalates33) to the original list of six substances, as cited under the REACH regulation;
and adds Category 11 products.
Table 1.6 presents an overview of RoHS 1,2,3

RoHS compliance requirements in India

In India, RoHS compliance requires manufacturers of electrical and electronic equipment (EEE)
to restrict the use of hazardous substances like lead, mercury, cadmium, and others in their
products. This ensures the products are safe for human health and the environment. To achieve
 compliance, companies need to conduct product testing, document their findings, and obtain
necessary certifications.

Key Requirements and Steps for RoHS Compliance in India:

• Restricted Substances:
RoHS restricts the use of certain hazardous substances, including lead, mercury, cadmium,
hexavalent chromium, polybrominated biphenyls (PBBs), and polybrominated diphenyl ethers
(PBDEs).
• Threshold Limits: The maximum permissible concentration of these substances in
homogeneous materials is 0.1% (1000 ppm) for most substances and 0.01% (100 ppm) for
cadmium.
• Declaration of Conformity:
Companies need to provide a Declaration of Conformity, stating that their products meet RoHS
requirements.
• Bill of Materials:
A detailed Bill of Materials (BOM) is required, listing all components and materials used in the
product.
• Product Testing:
Testing is essential to verify that the product's components and materials comply with RoHS
limits. This is typically done by accredited laboratories.
• Supplier Declarations:
Obtaining declarations from suppliers confirming that their components or materials meet
RoHS requirements is also crucial.
• Technical Documentation:
Comprehensive documentation, including design and technical drawings, material composition
reports, and quality control procedures, is necessary.
• RoHS Certification:
While RoHS compliance is not a mandatory certification in India, it is required for CE
marking, which is necessary for certain products sold in the European Union.
• Regular Audits and Assessments:
Manufacturers should conduct regular internal audits and assessments to ensure ongoing
compliance.
• Record Keeping:
Maintaining detailed records of all compliance-related activities, including testing results and
documentation, is essential.
• Continuous Improvement:
Companies should implement a system for continual improvement of their RoHS compliance
procedures.

Products Covered: RoHS compliance generally applies to a wide range of electrical and
electronic equipment, including consumer electronics, lighting, and other products. Some
products, like those for national security, outer space, or medical implants, may be exempt.

Benefits of RoHS Compliance:

• Market Access:
RoHS compliance is often a prerequisite for exporting products to markets that require it, such
as the European Union.
• Consumer Safety:
It ensures that products are safer for consumers by reducing exposure to hazardous substances.
• Environmental Protection:
By restricting hazardous substances, RoHS helps to protect the environment from pollution.
• Improved Design:
RoHS compliance can encourage manufacturers to improve product design and use safer
materials.
• Reduced Waste:
By promoting safer products, RoHS can also help to reduce the amount of hazardous waste
generated.

E-Waste Recycling

E-Waste Recycling Operations.

E-waste recycling chain comprises of four main steps:

1. Collection
2. Pre-processing (sorting – classification, separation/manual dismantling or disassembly, de-
pollution.
3. End-processing that includes physical and chemical processing.
4. Refining process.
 • The first stage of recycling is collection from consumers once the EEE have reached their
EoL.
• During second stage, de-pollution process includes one or several shredding processes
aimed at reducing the size of devices and elimination of potentially hazardous
components.
• Once reduced in size, the shredded components in e-waste undergo mechanical sorting,
where different sorting technologies are applied.
• During the third stage – physical recycling, usually – size reduction takes place through
disassembling, dismantling, chopping, shredding, crushing [Link] of the approach
and the chosen technology, in the pre-processing stage four groups of materials are
extracted:
• Hazardous materials (e.g., batteries)
• Valuable components, which could be reused/resold in the market after dismantling.
• Valuable recyclable materials (copper, aluminium, plastics) that will be sold for further
material recovery.
• Residues – non-hazardous materials (ceramics, some plastics etc.), that are not suitable
for recycling. This fraction is likely to be disposed of in landfills or incinerated.

Mainly three kinds of substances are released during recycling:

• The substances used in manufacturing of electrical and electronic equipment.

• Those substance are used in recycling process.
• By-products, which are formed during the transformation of primary constituents.
 • The by-products are: fly ashes, fine particles, fumes, waste water, etc; of them, fly ashes,
fine particles, and fumes are transported to other places via air while waste water
becomes leachate/ effluent and contaminate surface and the sediments contaminate
ground waste.

Process Of Recycling and Risks Involved in It.

• If not properly managed, hazardous substances may pose significant human health and
environmental risks.
• Toxic substances can be found within the following types of emissions or outputs:
1. Leachates from dumping activities.
2. Particulate matter (coarse and fine particles) from dismantling activities.
3. Fly and bottom ashes from burning activities.
4. Fumes from mercury amalgamate “cooking,” de-soldering and other burning activities.
5. Wastewater from dismantling and shredding facilities.
6. Effluents from cyanide leaching and other leaching activities.
• Among them, most researchers have expressed concern about manual disassembly, and acid-
leaching operations for value of valuable components from wires and cables, CRTs, and PCB.
• A particular hazard associated with the disassembly stage is the possibility of accidental
release and spillage of hazardous substances upon breakage of the shell, such as mercury,
which is found within light sources as well as switches.
• The primary hazards of mechanical treatment methods are associated with the size reduction
and separation steps, which can generate dusts from plastics, metals, ceramics, and silica.
• Open-air storage raises concerns regarding the possibility of lead and other substances
leaching out into the environment.
• In addition, with lack of access to running water, toxins are transmitted orally via people’s
hands when eating.
• While breaking and removal of copper yoke CRTs, lead, barium, and other heavy metals
leach into groundwater.
• During PCB disordering and removing computer chips, air emission of these substances
remains in air for long time.
• While processing dismantled PCBs, that is, open-air burning to remove the metals, tin and
lead contaminate immediate environment including surface and ground waters, and
brominated dioxins, beryllium, cadmium, and mercury emissions take place.
• For treating chips and other gold-plated components, chemical stripping method (using nitric
and hydrochloric acid), along river banks Hydrocarbons, heavy metals, brominated
substances, etc. are discharged directly into river or left on the banks, which acidifies the river
destroying fish and flora.
3 main hazardous technologies for treating e-waste

Three most prevalent and hazardous technologies for treating e-waste adversely impact
environment and human health:

• Incineration

• Open-air burning

• Landfilling

Incineration: Incineration is a process of destroying waste through burning.

• The gases released during the burning and the residue ash are often toxic.
• Studies of municipal solid waste incineration plants have shown that copper, which is
present in PCBs and cables, acts as a catalyst for dioxin formation when flame retardants
are incinerated.
• These BFRs when exposed to low temperature (600–800°C) can generate extremely toxic
PBDDs and Polybrominated Furans.
• PVC is also found in e-waste in significant amounts, which is highly corrosive when
burnt and also induces the formation of dioxins which leads to loss of valuable elements
that can be recovered if sorted and processed separately.

Open air burning: Open burning is used mostly for waste disposal, at relatively low
temperature and this is far more polluting than controlled incineration process.

• Inhalation of open fire emissions can trigger asthma attacks, respiratory infections, and
cause other problems such as, chest pain, coughing, wheezing, and eye irritation.
• Chronic exposure to open fire emissions may lead to diseases such as emphysema (lung
condition that causes shortness of breath) and cancer.
• Open-air burning of PVC releases hydrogen chloride, which on inhalation mixes with
water in the lungs to form hydrochloric acid, which may lead to corrosion of the lung
tissues, and other respiratory complications.
• Often open fires burn with a lack of oxygen, forming carbon monoxide, which poisons
the blood when inhaled.
• The residual ash becomes airborne, and is dangerous if inhaled.

Landfilling: This is one of the most widely used methods of waste disposal.

• The leachate (cadmium, lead, and mercury) often contains heavy metals and other toxic
substances that contaminate groundwater resources.
• Even state-of-the-art landfills, which are sealed to prevent toxins from entering the
ground, are not completely tight in the long-term.
 • There are three major concerns regarding landfills and its impact on environment are – its
leach, vaporization effects, and its proneness to uncontrollable open fires and release of
toxic fumes.
• From the PCBs and CRT monitors, lead is found to leach from their glasses.
• The land filled BFR plastics or plastics containing Cadmium, both PBDE and Cadmium
may leach into soil and groundwater.
• Besides leaching, vaporization is also a concern in landfills – volatile compounds
(mercury or di-methylene mercury) are released through vaporization.

3 main group of substances that may be released during recycling and material recovery

There are three main groups of substances that may be released during recycling and material
recovery and which are of environmental concern:

1. Original constituents of equipment, such as lead and mercury.

2. Substances that may be added during some recovery processes, such as Cyanide.
3. Substances that may be formed by recycling processes, such as dioxins. Dioxins can be
released when PVC parts are incinerated at a low temperature.