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: Joint industry statement on the impact of restricting primary batteries in Europe [15 September 2020]

Environment: Orgalim calls for an impact assessment and a delay of implementation of ECHA SCIP database [30 June 2020]

Environment: Orgalim comments on the development of sustainability requirements for batteries under a New Regulatory Framework for Batteries [26 June 2020]

Environment: Wastewater matters too: Orgalim’s recommendations for the revision of the Urban Waste Water Treatment Directive [22 May 2020]

Environment: Think Blue: Orgalim recommendations for the improvement of the Water Framework Directive [22 May 2020]

Environment: Response to Commission circular economy roadmap consultation [20 January 2020]

Environment: EU-wide uniform conditions for the proper quality treatment of WEEE: A call for Implementing Acts to lay down minimum quality WEEE treatment standards in strict accordance with the European standards [12 December 2019]

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]