Preliminary comments on the revision of Annex II of the RoHS Directive - Joint submission from CEFIC, Eurometaux, Orgalime & PlasticsEurope

Published: 13 June 2013

Policies & Issues: Environment

We acknowledge that the updated Methodology for Identification and Assessment of Substances for Inclusion in the List of Restricted Substances under the RoHS2 Directive ('RoHS Methodology') as presented during the 2nd stakeholder meeting and described in the Draft Manual released by the Austrian UBA on 7 May has integrated some of the issues raised during the second consultation:

  • References to the REACH Regulation where the assessment of substances is concerned
  • Reference to chapter R.18 of the ECHA guidance on exposure scenario building for the waste life phase
  • Clearer decision trees and improved criteria for prioritisation

However, we believe that the methodology should be further improved in order to ensure that the implementation of the RoHS2 directive achieves maximum coherence and efficiency in dealing with its main remit, which is the restriction of hazardous substances used in electrical and electronic equipment ('EEE'). More emphasis is therefore needed on the assessment, including the waste phase, rather than on the production volume as is the case in the Draft Manual.

Related Position Papers

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]

Comments on Product and Organisational Environment Footprint methodologies (PEF/OEF) [19 December 2018]

Circular Economy: Resolving the interface between EU waste, product and chemicals policy [29 October 2018]

Strategy on long-term EU Greenhouse Gas (GHG) emissions reduction: Turning challenges into opportunities - The contribution of the European technology industries [10 October 2018]