Data gaps in RoHS part EC DG Enterprise

1
Data gaps in RoHS partEC DG Enterprise
Industry

• 3 July 2007
• Sarah Bogaert ARCADIS ECOLAS

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Goals of the RoHS study

• Analysis of economic and environmental impacts of
  RoHS
• Cost-Benefit Analysis
• General quantified information on all product
  groups
• Quantification of B/C per product group
• Qualitative description of inefficiencies
• Impact on internal market
• Impact on innovation
• Impact on products and sectors not covered by ban
• Potential synergies and conflicts with other
  policy objectives
• Comparison of EU approach with other approaches
• Recommendations for revision to improve
  cost-effectiveness

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Gaps in RoHS due to low response

• Lack of representativeness per product group
• Refrigerators (1)
• PC laptop, incl. spare parts (2)
• Printers copiers (4)
• Cellphones (1)
• Television sets (1)
• Clocks watches (1)
• Fluorescent lamps (straight and compact) (0)
• Lawn mowers gardening equipment (0)
• Video games handheld video games (0)
• Dispensers for hot and cold beverages (0)
• Lack of representativeness in activities
• Mainly assemblers
• 4 component producers
• Lack of representativeness in company size not
  1 SME
• Lack of economic indicators e.g. turnover
• Often difficult interpretation (can be solved
  through individual contacts)

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Reasons for low response?

• Its no use crying over spilt milk I fully
  comply and do not want to spend any more time
• Questionnaire was too detailed
• Questionnaire was too large
• Questionnaire came at a bad time
• May many holidays
• Consultation fatigue
• Confidentiality problems

5
Solutions for low response

• Questionnaire was too detailed
• Questionnaire was too large
• Confidentiality problems non-disclosure
  agreement

New call to MS companies in relevant product
groups
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Gaps in RoHS - Analysis of costs in MS

• Estimation of total direct resource costs of RoHS
  indicate share of
• Communication
• Monitoring and review
• Exemption procedure
• Enforcement
• Please...
• Differentiate between
• Personnel costs ( FTEs, x of FTE)
• Resource costs
• Indicate one-time or recurring cost
• Specify years to which costs refer

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Gaps in RoHS - Analysis of costs in companies

• Estimation of total compliance costs indicate
  share of
• Training or information measures
• Collecting and reviewing information
• Exemption procedures
• Qualitative or quantitative information on
  (temporary) monetary losses/gains of e.g.
• ?? sales volumes
• discontinuation of non-compliant products
• delayed introduction of products
• Please...
• Differentiate between
• Personnel costs ( FTEs, x of FTE)
• Resource costs
• Indicate one-time or recurring cost
• Specify years to which costs refer

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Gaps in RoHS - Analysis of costs in companies

• Technical costs of phase-out of RoHS substance
• If possible broken down by
• Capital expenditure
• Operating expenditure
• RD expenditure
• Indicate to wich substance cost refers
• Indicate one-time or recurring cost
• Specify years to which costs refer
• Additional staff time dedicated to RoHS not yet
  included FTEs, x of FTE (specify activities)
• General information product groups, activity,
  size, turnover

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Gaps in RoHS Sector profile

• What information is available
• Eurostat PRODCOM NACE DL 30 to 33 Manufacture
  of electrical and optical equipment
• companies per MS distributed by size
• Not all MS participate every year
• No complete coverage e.g. medical devices not in
  RoHS study, video games/lawn mowers not in
  PRODCOM
• Eurostat Engineering industry NACE DL 29.1-5,
  29.71, 31
• Economic indicators per MS e.g. companies,
  production, value added, RD intensity

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Gaps in RoHS Sector profile

• Economic indicators needed per product group
• companies in EU27 by size
• Economic profile
• Turnover
• Value added
• RD expenditure
• Etc.

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Analysis of environmental benefits

• Methodology
• (1) Quantity of substances in product per product
  group
• (2) Product volumes brought on the market per
  product group
• (1)(2) estimated total presence of hazardous
  substances
• Quantification of environmental impact based on
  life-cycle assessment and dose-response
  relationships
• Monetization of environmental and health impact
  based on benefit transfer

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Gaps in RoHS - Analysis of env. benefits

• Historic evolution of quantities of Pb, Hg, Cd,
  Cr, flame retardants (PBB, PBDE) per product/kg
  for each product group
• Emission factors per phase in the life cycle, per
  product, per environmental compartment
• LCA functional units on PBB, PBDE

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Gaps in WEEE Stakeholder consultation

• Individual Companies Only 10 responses. Need
• Cellphones, clocks and watches, lamps,
  lawn-mowers, dispensers
• SMEs
• Examples of innovations made and associated costs
• RD costs associated with design for recycling
  opportunity costs
• Effects on volume of sales?
• National Authorities Only 3 responses. Need
• Lithuania, Ireland
• Indications of competition effects at national
  level
• Current estimates of free-riders

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Gaps in WEEE Stakeholder consultation

• Trade Associations 6 responses
• Majority of company members are large firms SMEs
  representation?
• Examples of difficulties experienced by companies
  registering in more than one MS
• Producer Responsibility Schemes 3 responses
• Consumer Organisation 1 response
• Recycling company 1 response

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All information welcome by end of July

• RoHS ARCADIS Ecolas Ltd.
• Sarah Bogaert
• Fonteinstraat, 1A
• B-3000 Leuven, Belgium
• http//www.arcadisecolas.com
• sbogaert_at_arcadisecolas.be
• WEEE Risk Policy Analysts Ltd.
• Dave Fleet Rocio Salado
• Farthing Green House
• 1 Beccles Road, Loddon, Norfolk
• NR14 6LT, United Kingdom
• http//www.rpaltd.co.uk
• dave_at_rpaltd.co.uk and rocio_at_rpaltd.co.uk