Commission recast proposal for Directive 2002/95/EC (RoHS)

COM (2008)809 final

The RoHS recast proposal claims to simplify existing legislation and to avoid unnecessary bureaucracy and administrative costs in line with Better Regulation principles of the EU. Also, the legislative environment in terms of existing EU law changed considerably since the entry into force of the initial RoHS Directive, which should have been reflected accordingly for the RoHS recast. While we acknowledge some improvements, we feel that the RoHS recast proposal generally fails to realise these objectives, in particular since it continues overlapping with other legislation and thereby creating legal uncertainty.

Consequently, Orgalime’s fundamental request to regulators is to ensure full legal consistency between the RoHS Directive and other legislative initiatives that have been finalised after the adoption of the initial RoHS Directive.