Orgalime Position Paper RoHS Recast Proposal

Published: 27 October 2011

Policies & Issues: Environment

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.

Related Position Papers

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]

Environment: Financing key enablers of the green transition: Orgalim position on the EU taxonomy for sustainable activities [6 October 2021]