Commission proposal for amending RoHS Directive 2011/65/EU repairs legal certainty for European manufacturers

The European Commission has presented its proposal for a targeted amendment of Directive 2011/65/EU on the restriction of the use of certain hazardous substances in electrical and electronic equipment (RoHS 2). In their present form, the provisions of certain articles in this directive raise a number of concerns due to inconsistencies on three fronts – with the principle of non-retroactivity of legislation, with the New Legislative Framework, and with the objectives of a circular economy.

The Commission’s proposals to amend the RoHS Directive would, in Orgalime’s view, facilitate European manufacturers’ compliance efforts with the directive’s provisions – helping to re-establishing legal certainty for manufacturers and market surveillance authorities, while allowing secondary market operations on products that have been legally placed on the market before the respective substance restriction applied.

Download our position paper to read Orgalime’s views in more detail.