As noted in last month’s column, the Circular Electronics Partnership (CEP) introduced itself to the world through a webinar held on March 18. Its website provides access to its public roadmap, which covers key goals through 2030.
The webinar was led by Accenture, which I find to be a curious choice since this is a management consulting firm with no clear history or expertise in electronic design or manufacture, or in the myriad issues surrounding e-waste. Perhaps their involvement is to lend some circularity credibility to the effort, as they have recently produced reports for the chemical industry and the World Economic Forum. We will have to wait and see what their actual role is.
My focus for this month’s column is on “Design for circularity,” which is one of the six pathways defined by the group in the roadmap. In this pathway they are focused on:
- Industry-wide standards, which, today, are certainly lacking. In the webinar they pointed out that CENELEC has developed some relevant standards but the fact is that those are designed to support European Union regulatory requirements. The rationale for CENELEC’s standard development is significantly difference from the US (and most — but not all — other markets): the American approach, as described by the American National Standards Institute (ANSI), is on voluntary industry standards as a primary approach. CENELEC developed this set of standards for the European Commission specifying implementation or measurement requirements and methods for the purpose of implementing regulations. Voluntary standards can end up supporting or even being regulatory requirements, but standards based on regulations run the risk of enforcing inefficient or inadequately scoped requirements on industry. On the other hand, ISO TC 323 and IEC TC 111 are also developing relevant circularity-related standards, which are voluntary. CEP are optimistic to imagine that an international standards body can “define circular electronic products and services” by 2023.
- Harmonizing circularity criteria of eco-labels by 2027. Is there an aspect of sustainability that does not relate to circularity? Most criteria in the eco-labels (see my past two columns) can be directly or indirectly related to a product’s circularity. Ultimately does that mean no differentiation and no reason for existence for all but one eco-label? Yes the proliferation is frustrating to a manufacturer but how does this get accomplished with every eco-label remaining whole? Maybe that’s the point — they don’t all survive.
- Tools and training for circular electronics design by 2023. Some basic guidelines exist and, with concerted effort, they can — and must — be expanded. In this section of the roadmap document, however, they discuss how designers “are required to balance a range of different requirements,” one of which is product safety… and “inflammability” is the example. The fact is that product safety is non-negotiable. So this example is a red herring I have seen many times before.
Product safety requirements defined in standards like IEC 62368-1 must be met, but they can be met in any number of ways, including “electrically-caused fire” mitigation and/or resistance (not “inflammability”). Product safety represents a set of design constraints, as noted in a previous column. Circularity is another set of design constraints.
Designers are paid to identify solution options that meet all constraints defined in the PRD (product requirements document) or enable management to intelligently decide which constraints to relax or address in an alternative manner. Circularity is simply the newest product design constraint. Flame retardant suppliers will often present “product safety” versus the use of toxic chemical substances they sell to meet flammability requirements as a choice to be made, when of course this is simply a false dilemma and a marketing ploy.
To continue with the “design for circularity” pathway, other focus areas include:
- Create an enabling environment for the sale of circular products and services by 2027. This correctly identifies the failure by governments to implement approaches to solving the recycling problem that drive corrective actions by electronics manufacturers. E-waste regulations like WEEE focus on administrative issues like e-waste collection. They almost universally fail to require, or at least properly incentivize, design changes that would reduce the amount of e-waste or make it more recyclable and valuable. Yes, some incentives could, perhaps, be defined, such as reducing producer responsibility-related payments to the government based on product design features that markedly reduce e-waste or result in more recyclable materials. But expecting governments to reduce taxes and fees for a multi-trillion dollar industry and enormous corporation is a curious approach. I hate to say it, but the stick often works better than the carrot with the electronics industry in this space. We will come back to this in a future column.
- Set up an industry repository for circular electronics by 2027. The roadmap says “[t]his can include standards references and definitions on circular electronics products and services, eco-design policies and regulation for different regions, best practices of design for circularity in the industry, case studies, etc.” This is a relative slam-dunk but requires extensive ongoing management and maintenance due to the ever-increasing volume of “eco-design policies and regulation for different regions”. Organization, translation into useful and immediately understandable language, and useful keywording is key to making such a repository of any use to already overextended engineers. And of course, there are already companies that provide key aspects of this rather useful service.
This is a noble — but incomplete — set of goals. We’ll come back to some of them in future columns because there’s more to say and limited space here to say it. There are also five more pathways defined, aspects of which deserve review. Let me know what you think.
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