Directive 2011/65/EU (“RoHS2”): Impact Assessment of Article 2.2

Published: 15 June 2012

Policies & Issues: Environment

Following the last BioIS stakeholder meeting on the RoHS2 scope impact assessment study, Orgalime appreciates the opportunity to provide additional input to the current discussion on impacts of article 2.2 RoHS2 and the notion of “making available” in particular.

This issue is relevant for any equipment newly in scope following the recast of the Directive (see Orgalime’s earlier comments): If BioIS maintained its understanding that new equipment could fall either under category 11 or any other category of Annex I of RoHS2, the given scope of the impact assessment on category 11 “only” is too narrow and its results may be misleading and incomplete as all other affected product categories would not be taken into account.

Related Position Papers

Environment: Orgalim preliminary key messages for the upcoming revision of the EU Waste Framework Directive Orgalim [11 August 2022]

Environment: Position and recommendations from Europe’s technology industries on the proposed Ecodesign for Sustainable Products Regulation [1 June 2022]

Environment: Orgalim position paper on the upcoming revision of the RoHS Directive [31 May 2022]

Environment: Orgalim position on the upcoming revision of the REACH Regulation [13 April 2022]

Environment: Orgalim Position Paper on the “right to repair” [5 April 2022]

Environment: Orgalim Position Paper on the restriction of PFAS [27 January 2022]

Environment: Orgalim Position Paper on the draft French Decree on consumer information for waste-generating products [21 December 2021]

Environment: Joint industry position paper on the concept of Essential Use [3 November 2021]

Environment: Orgalim comments on the draft French Decree on the minimum proportion of reused packaging [28 October 2021]