RoHS recast proposal: Time for compromise & for moving on

While Orgalime feels that it is now time for the European Institutions to achieve a compromise on the recast proposal for Directive 2002/95/EC on the Restriction of Certain Hazardous Substances in Electrical and Electronic Equipment (RoHS), which reconciles the views of different parties and takes into account a number of concerns of our industry, there are still issues which we feel will need to be resolved for the implementation of the RoHS Recast Directive to make this legislation truly workable and in the future to provide legal certainty to companies. These include:

• The extension of the scope of the RoHS directive to all EEE

• The unequal weight of criteria for granting RoHS exemptions and the significant impact of the RoHS recast on some sectors which need exemptions for specific applications

• The introduction of a RoHS substance evaluation methodology almost entirely independent from the REACH Regulation

• Achieving consistency between RoHS exemptions, REACH authorisation, and REACH exemptions from authorisation

• A better alignment of the RoHS Directive with the New Legislative Framework