Environment Issues
ISSUE BRIEF ~ May 2006

Issue/Background
AeA Member Impact
AeA Position
Status/Outlook
AeA Staff Contact

Issue/Background
The high-tech industry is committed to reducing the environmental impacts of our products throughout their lifecycle: from design, to use, to end-of-life. Many high-tech manufacturers have made significant investment in design for the environment (DfE) over the past several years in an effort to minimize the use of certain materials, as well as allow for the ease of recycling of the electronic products. Several companies have on-going company recycling programs or provide sponsorship and support to aid in the development of local recycling infrastructure.

AeA Member Impact
State-specific legislation and mandates have the potential to place California companies at a significant competitive disadvantage to their out-of-state counterparts, in terms of increasing the cost of the product both through the direct placement of a fee on said products or through costly compliance procedures that will need to be followed. Also, differing mandates in various jurisdictions complicates the manufacturing and distribution of the high tech industry’s products, which are often sold on a global scale.

AeA Position
Well intentioned environmental laws and regulations at the state level are increasingly impacting electronics manufacturers’ ability to sell their products globally. Examples of environmental laws and regulations governing high-tech products include substance restrictions, energy efficiency requirements, and product take-back and recycling requirements. In the 2006 legislative session, AeA has seen the introduction of several pieces of legislation that create costly new state programs that would discourage high-tech companies from building their business in the State of California.

Status/Outlook
AB 2202 (Saldana) would expand the product scope of the California Restriction on Hazardous Substances (RoHS) requirements from the current six products to the hundreds of thousands of products that are regulated by the European Union’s RoHS Directive. We believe California needs to take a step back before tying California’s law so tightly with the European directive over which the state has no control and no jurisdiction, and which has not yet gone into effect in the EU. AB 2202 will undoubtedly result in enforcement and consistency challenges in California both in managing the fluid and sometimes confusing scope of the RoHS Directive and in enforcing the law. Additionally, the truncated timeline proposed in AB 2202 is not feasible for products that are manufactured for California markets and have not undergone the redesign and supply chain restructuring of their EU counterparts. AeA is opposed to this bill.

AB 1970 (Levine), the Vampire Slayer Act of 2006, would require manufacturers to label their products’ packaging with energy consumption information, including the estimated energy consumption in “standby mode” and the estimated annual operational cost. Aside from the substantial cost and logistical challenges of having a California-only labeling requirement, this proposal is even more flawed in that there is not an industry standard test for products that would fall into the undefined category of “appliance”. AeA is opposed to this measure.

AeA Staff Contact
Joe Gregorich, Legislative Advocate at (916) 443-9059, x107 or joseph_gregorich@aeanet.org
 

This page was last updated on 10/16/06.  
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