Scope of WEEE & RoHS Directives
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.