Comments on Öko-Institut consultation for a review of the RoHS 2 Directive scope provisions – 2nd area of review: EEE newly in scope

Published: 10 March 2014

Policies & Issues: Environment

Orgalime thanks the Öko-Institut for the stakeholder consultation to provide further input to the European Commission impact assessment on the scope of the RoHS2 Directive as requested by Article 24(1). However, at an earlier stage a similar study has already been carried out by Bio Intelligence Service on behalf of DG Environment1. We call for taking this earlier study into account in this follow up work. 

As a European association representing the European manufacturers of mechanical, electrical, electronic and metal articles as a whole, Orgalime will focus its comments on the impacts of the suggested scenarios to solve the current side-effects of Articles 2(2), 4(3) and 4(4), as listed under section six of the questionnaire, rather than on sections three, four and five, which, in our view, target individual companies [more in download]

Related Position Papers

Environment: Orgalim position on the Sustainable Products Initiative [8 June 2021]

Environment: Orgalim position on draft reporting rules for companies under the EU Taxonomy Regulation [2 June 2021]

Environment: Orgalim position on the cross-cutting aspects of the Ecodesign and Energy Labelling Working Plan 2020-2024 [2 June 2021]

Environment: Orgalim comments on the REACH revision roadmap [1 June 2021]

Environment: Orgalim comments on the French draft decrees on the identification of hazardous substances and the provision of information identifying endocrine disruptors in products [22 March 2021]

Environment: Orgalim comments on a proposal for a Regulation for Batteries and Waste Batteries [1 March 2021]

Environment: Orgalim comments on the 1st draft delegated act on climate change sustainable activities supplementing the EU Taxonomy Regulation [18 December 2020]

Environment: Orgalim views and recommendations on the Sustainable Products Initiative [16 November 2020]

Environment: Orgalim position paper on the new Circular Economy Action Plan [15 October 2020]