Preliminary comments on the revision of Annex II of the RoHS Directive - Joint submission from CEFIC, Eurometaux, Orgalime & PlasticsEurope

Published: 13 June 2013

Policies & Issues: Environment

We acknowledge that the updated Methodology for Identification and Assessment of Substances for Inclusion in the List of Restricted Substances under the RoHS2 Directive ('RoHS Methodology') as presented during the 2nd stakeholder meeting and described in the Draft Manual released by the Austrian UBA on 7 May has integrated some of the issues raised during the second consultation:

  • References to the REACH Regulation where the assessment of substances is concerned
  • Reference to chapter R.18 of the ECHA guidance on exposure scenario building for the waste life phase
  • Clearer decision trees and improved criteria for prioritisation

However, we believe that the methodology should be further improved in order to ensure that the implementation of the RoHS2 directive achieves maximum coherence and efficiency in dealing with its main remit, which is the restriction of hazardous substances used in electrical and electronic equipment ('EEE'). More emphasis is therefore needed on the assessment, including the waste phase, rather than on the production volume as is the case in the Draft Manual.

Related Position Papers

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

Environment: Orgalim response to the consultation by the Platform on Sustainable Finance on EU taxonomy [5 October 2021]

Environment: Joint statement on the need for a transition period for the implementation of the Batteries Regulation [28 July 2021]

Environment: Orgalim input to the European Commission consultation on the Revision of the Urban Waste Water Treatment Directive [20 July 2021]

Environment: Orgalim position on the Sustainable Products Initiative [8 June 2021]

Environment: Orgalim position on draft reporting rules for companies under the EU Taxonomy Regulation [2 June 2021]

Environment: Orgalim position on the cross-cutting aspects of the Ecodesign and Energy Labelling Working Plan 2020-2024 [2 June 2021]

Environment: Orgalim comments on the REACH revision roadmap [1 June 2021]

Environment: Orgalim comments on the French draft decrees on the identification of hazardous substances and the provision of information identifying endocrine disruptors in products [22 March 2021]