Orgalime Position Paper RoHS Recast Proposal

Published: 27 October 2011

Policies & Issues: Environment

The RoHS recast proposal claims to simplify existing legislation and to avoid unnecessary bureaucracy and administrative costs in line with Better Regulation principles of the EU. Also, the legislative environment in terms of existing EU law changed considerably since the entry into force of the initial RoHS Directive, which should have been reflected accordingly for the RoHS recast. While we acknowledge some improvements, we feel that the RoHS recast proposal generally fails to realise these objectives, in particular since it continues overlapping with other legislation and thereby creating legal uncertainty.

Related Position Papers

Environment: Orgalim response to the public consultation on the RoHS evaluation [6 December 2019]

Environment: Evaluation of Directive 2011/65/EU (“RoHS”): Improving implementation in a Circular Economy context [6 December 2019]

Environment: The European technology industries’ priorities for the sustainable use and management of water in Europe [14 November 2019]

Environment: Orgalim's response to a public consultation on sustainability requirements for batteries [27 August 2019]

Waste policy: Joint industry comments on modulating producers’ financial contributions for Waste Electrical and Electronic Equipment [26 July 2019]

Eunomia study in support of developing Guidance for Extended Producer Responsibility (EPR) Schemes: Comments on modulation of producers’ financial contributions [12 March 2019]

Orgalim response: Consultation by Technical Expert Group on Sustainable Finance [25 February 2019]

Feedback on the usability of the taxonomy - Orgalim response [25 February 2019]

Orgalime response to consultation on RoHS Substance Review Methodology [21 December 2018]