Orgalime response to consultation on RoHS Substance Review Methodology

Orgalime, representing Europe’s Technology Industries, including European manufacturers of electrical and electronic equipment (EEE), thanks the Öko-Institut for the opportunity to comment on the draft of the revised manual methodology for identification and assessment of substances for inclusion in the list of restricted substances (Annex II) under the RoHS 2 Directive 2011/65/EU prepared in the framework of the Study to support the review of the list of restricted substances and to assess a new exemption request under RoHS (RoHS Pack 15). 

We reiterate our support to the objective of the RoHS Directive laying down rules on the restriction of the use of hazardous substances in EEE with a view to contributing to the protection of human health and the environment, including the environmentally sound recovery and disposal of waste EEE. 

We welcome the re-evaluation of the methodology for identification and assessment of substances for inclusion in the list of RoHS restricted substances (Annex II) as published in 2013 by the Austrian Umweltbundesamt (AUBA 2013) considering its serious shortcomings. The present AUBA methodology indeed does not provide a reliable and comprehensible basis for the future revisions of Annex II of the RoHS Directive. 

For a proper implementation of both RoHS and REACH, a thorough substance identification and evaluation methodology is a prerogative. Any new substance restriction under RoHS, and any other legislation on chemicals must be based on a robust, science-based and consistent substance evaluation methodology. 

To read our recommendations in full, please download the document.