The U.S.-based IPC (Association Connecting Electronics Industries) and the Indian Printed Circuits Association have submitted comments in response to the Indian Government's Ministry of Environment and Forests draft notification of electronics scrap rules for this year.
In its comments, IPC focused on the concern it has on the impact that the proposed Chapter V, Reduction in the use of hazardous substances in the manufacture of electrical and electronic equipment will have on the global and Indian electronics industry. Further, the IPC comments that the policy still fails to accomplish the Ministry's goal of environmentally sound management of electrical and electronic equipment scrap.
In its comments, IPC explains that the simultaneous restriction of the 20 substances identified in Chapter V, Schedule III of the proposed draft regulation will not contribute to the environmentally sound disposal of electronic products and proposes that a scientific evaluation of substances be conducted in order to ensure that alternatives provide a benefit to human health and the environment.
“IPC urges the Ministry to implement a scientifically-based methodology for restricting substances that includes a full life-cycle assessment of the substances and possible alternatives in order to accomplish the goal of maximum human health and environmental protection,” says Fern Abrams, IPC director of government relations and environmental policy.
The IPC claims that several substances included in Schedule III have been proven to be safe for human health and the environment and should not be restricted under the Ministry's proposal.
Noting a study of lead-free solder conducted by the EPA, IPC warns of the environmental trade-offs when restricting substances and blindly substituting one for another. Following the European Union's restriction of the use of lead in electronics under the RoHS Directive, the EPA study evaluated the environmental impacts of tin-lead solder versus lead-free alternative solders and found that the increased energy use associated with the higher operating temperatures required for manufacturing lead-free soldered electronics would cause greater negative impacts on the environmental than tin-lead soldered electronics.
“There should be clear and compelling evidence that potential alternatives are available, are reliable and are preferable from a life cycle perspective,” Abrams adds. “Until life cycle assessments are conducted proving that the environmental and human health impacts across the alternative's life cycle are better than the substances being replaced, the Ministry should not restrict any substances.”
The IPC, with around 2,700 members, is involved in all facets of the electronics industry, including design, printed board manufacturing, electronics assembly and test.
To view the IPC's comments, click here -- Comments