"The proposed directive will require manufacturers to consider environmental factors at the design stage and throughout the life cycle of a product," says Helen Delaney, president of Delaney Consulting Inc. (Bethesda, MD), which specializes in standards and trade matters. "Manufacturers will have to show that there has been an assessment of the environmental impact of a product throughout its life cycle. They will have to document specific design choices and the reasons behind them," she says.

The directive is meant to reduce waste and pollution. The European Commission's DG Enterprise says the new directive's objectives can be achieved without compromising industry competitiveness. However, a recent report on the directive noted that many small businesses are not even aware of the directive. In addition, small businesses may lack the resources necessary to comply with environmental legislation.

Standardization bodies such as ETSI and CENELEC would develop harmonized standards to meet the requirements of the new directive. Compliance with the essential requirements of the EEE Directive is supposed to result in improvement in the environmental performance of electronic products. It is also supposed to allow companies to maintain or improve their competitiveness--not act as a barrier to innovation. It may be difficult, however, to convince manufacturers.

The proposed directive covers nearly every electronic product, from electric appliances, office machines, and computers to telecommunications equipment and medical instruments.

Electrical or electronic components placed on the EU market as final products for consumers will also be considered electrical or electronic equipment and, therefore, will be required to comply with the requirements of the EEE Directive.

According to Delaney, no environmental directive to date has been as far- reaching as this one. "Manufacturers know that consideration of the environment is good business. But when environmental integration officially begins in Europe, that is, when the proposal becomes final, designing products with environmentally correct materials is going to lose its voluntary status. Everybody will have to comply, small businesses as well as large," says Delaney.

The draft EEE Directive is available at ttp://europa.eu.int/comm/enterprise/electr_equipment/eee/workdoc.pdf. Comments can be sent to entr-eee@cec.eu.int. entr-eee@cec.eu.int.