Scope of WEEE & RoHS Directives

Published: 24 July 2006

Policies & Issues: Environment

Interpretation of 'Fixed Installations'

Orgalime is concerned about uncertainties linked to the scope of the WEEE and RoHS Directives. Transposition in Member States leads to divergences with the result being that the similar products falling within the scope of the Directives in one MS are omitted in another.

The Commission in its Frequently Asked Questions (FAQs) provides a set of criteria for determining the scope of WEEE and RoHS, which Orgalime supports. We particularly support the given interpretation guideline of 'fixed installations' to more specifically determine the criterion of article 2.1 WEEE.

Any change in the application of these given criteria at this moment in time would upset industry's own preparation for the implementation of the Directives.

In our position, we call upon the Commission to endorse its given guideline and ensure that MSs should not depart from this common understanding.

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]

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]