RoHS recast proposal: Time for compromise & for moving on

Published: 19 November 2010

Policies & Issues: Environment

While Orgalime feels that it is now time for the European Institutions to achieve a compromise on the recast proposal for Directive 2002/95/EC on the Restriction of Certain Hazardous Substances in Electrical and Electronic Equipment (RoHS), which reconciles the views of different parties and takes into account a number of concerns of our industry, there are still issues which we feel will need to be resolved for the implementation of the RoHS Recast Directive to make this legislation truly workable and in the future to provide legal certainty to companies. These include:

• The extension of the scope of the RoHS directive to all EEE

• The unequal weight of criteria for granting RoHS exemptions and the significant impact of the RoHS recast on some sectors which need exemptions for specific applications

• The introduction of a RoHS substance evaluation methodology almost entirely independent from the REACH Regulation

• Achieving consistency between RoHS exemptions, REACH authorisation, and REACH exemptions from authorisation

• A better alignment of the RoHS Directive with the New Legislative Framework

Related Position Papers

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

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

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

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

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