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.