Scope of WEEE & RoHS Directives

Published: 24 July 2006

Policies & Issues: Environment

Interpretation of 'Fixed Installations'

Orgalime is concerned about uncertainties linked to the scope of the WEEE and RoHS Directives. Transposition in Member States leads to divergences with the result being that the similar products falling within the scope of the Directives in one MS are omitted in another.

The Commission in its Frequently Asked Questions (FAQs) provides a set of criteria for determining the scope of WEEE and RoHS, which Orgalime supports. We particularly support the given interpretation guideline of 'fixed installations' to more specifically determine the criterion of article 2.1 WEEE.

Any change in the application of these given criteria at this moment in time would upset industry's own preparation for the implementation of the Directives.

In our position, we call upon the Commission to endorse its given guideline and ensure that MSs should not depart from this common understanding.

Related Position Papers

Environment: Orgalim views and recommendations on the Sustainable Products Initiative [16 November 2020]

Environment: Orgalim position paper on the new Circular Economy Action Plan [15 October 2020]

Environment: Orgalim executive summary of the position paper on the new Circular Economy Action Plan [15 October 2020]

Environment: 40 industry organisations call for urgent actions to postpone the legal obligations to the ECHA SCIP database [21 September 2020]

Environment: Joint industry statement on the impact of restricting primary batteries in Europe [15 September 2020]

Environment: Orgalim calls for an impact assessment and a delay of implementation of ECHA SCIP database [30 June 2020]

Environment: Orgalim comments on the development of sustainability requirements for batteries under a New Regulatory Framework for Batteries [26 June 2020]

Environment: Wastewater matters too: Orgalim’s recommendations for the revision of the Urban Waste Water Treatment Directive [22 May 2020]

Environment: Think Blue: Orgalim recommendations for the improvement of the Water Framework Directive [22 May 2020]