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Restriction of hazardous substances - evaluation

Environment

Directive 2011/65/EU concerns the restriction of the use of certain hazardous substances in electrical and electronic equipment, in order to protect human health and the environment and to maximise their end-of-life recovery. The evaluation will assess the effectiveness, efficiency, relevance, coherence and EU added value of the Directive, with a particular emphasis on its contribution to the circular economy.

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Public consultation

ID: 1891

Lobbying Activity

15 responses

Consultation response

European Environmental Bureau, 12 Oct 2018

It is of utmost importance to phase out the use of hazardous substance in products. This is the overarching principle. In the same time a coherence with the Circular Economy STrategy must be achieved. The EEBs report looks into this subject in…

Consultation response

American Chamber of Commerce to the European Union, 12 Oct 2018

The American Chamber of Commerce to the EU (AmCham EU) welcomes the Commission’s initiative to evaluate the performance of the Restriction of Hazardous Substances (RoHS) Directive. Our members have been implementing the directive since its inception in 2003, this has given them the practical…

Consultation response

DIGITALEUROPE, 12 Oct 2018

DIGITALEUROPE welcomes the opportunity to provide input to the consultation on the Roadmap for the Review of the Directive 2011/65/EU on the restriction of the use of certain hazardous substances in electrical and electronic equipment (RoHS). The RoHS Directive is an important piece of EU…

Consultation response

Orgalim – Europe's Technology Industries, 12 Oct 2018

Orgalime representing the European Technology Industries welcomes the opportunity to comment on the Commission Roadmap to evaluate the performance of RoHS Directive 2011/65/EU on the restriction of certain hazardous substances in electrical and electronic equipment (EEE). Orgalime considers the…

Consultation response

Scania AB (publ), 12 Oct 2018

Please find attached the input provided by Scania CV AB, a world-leading provider of engine technologies, offering a comprehensive engine range and tailored services for its customers worldwide as well as transport solutions, including trucks and buses for heavy transport applications combined with…

Consultation response

Plastics Europe, 11 Oct 2018

PlasticsEurope comments to the Commission on Roadmap for evaluation of the EU RoHS (Restriction of Hazardous Substances in electrical and electronic equipment) PlasticsEurope appreciates the opportunity to comment on the Commission Roadmap for evaluation of Directive 2011/65/EU of 8…

COCIR urges specific RoHS review for medical imaging sector

European Coordination Committee of the Radiological, Electromedical and healthcare IT Industry, 9 Oct 2018

COCIR recommends a specific assessment for medical imaging devices because current rules ignore unique business models. They want the evaluation to identify actions reducing impacts on innovation and the circular economy.
These changes would reduce legal uncertainty for long-term research investments and boost refurbishment sales.
Patients and healthcare systems lose access to advanced technologies due to regulatory barriers.

Consultation response

Japan Business Council in Europe, 11 Oct 2018

JBCE would like to thank the European Commission for the opportunity to provide input to the consultation on the roadmap for the review of the RoHS Directive. We support that this evaluation will assess effectiveness, efficiency, relevance and coherence, however, there are a few areas which we…

LightingEurope calls for more efficient EU hazardous substance exemptions

LightingEurope, 12 Oct 2018

LightingEurope requests an optimized application process to reduce the administrative burden on manufacturers. They advocate for increased transparency through progress updates and clear timetables for exemption reviews. They also seek better alignment between RoHS and other EU laws to eliminate overlapping requirements.
Streamlined procedures would lower compliance costs and eliminate the business uncertainty caused by delays.
Environmental advocates may see weaker protections if innovation justifications permit restricted substance use.

Consultation response

VinylPlus, 3 Oct 2018

The Roadmap is useful to clarify the Commission’s purpose and intentions. The members of the Plastics producers’ associations are not themselves producing E&E goods therefore we cannot comment on the effectiveness and efficiency of RoHS legislation. However, we will be able to comment on the…

Consultation response

European PVC Window Profiles and related Building Products Association, 9 Oct 2018

We understand and support the need of the RoHS Directive aiming to restrict hazardous substances in EEE, in particular to avoid adverse effects when it comes to dismantle such products for EoL reasons. PVC windows may be subject to RoHS, when they are equipped with electric devices such as cables,…

Consultation response

SEMI Europe, 11 Oct 2018

SEMI, representing the electronics manufacturing industry, welcomes the opportunity to give feedback on the roadmap. We see the following areas of improvement: i) RoHS and REACH inconsistencies; ii) global aspect of RoHS; iii) retention of Large-Scale Stationary Industrial Tools (LSSIT) and…

EUROMOT demands more efficient and predictable RoHS exemption procedures

European Association of Internal Combustion Engine and Alternative Powertrain Manufacturers, 12 Oct 2018

EUROMOT urges a review of the exemption process to make it more transparent and efficient. They recommend defined deadlines or transitional solutions to resolve long evaluation delays.
Streamlined procedures would provide legal certainty and ensure engine manufacturers do not lose orders.
Consumers and industrial users lose access to essential products due to slow approvals.

Consultation response

EuroWindoor AISBL, 12 Oct 2018

EuroWindoor appreciates the opportunity to give feedback to the evaluation of restrictions included in the RoHS Directive 2011/65/EU. EuroWindoor represent the interest of the European window, door and façade sector and has in this role previously provided input for a study initiated by the…

Consultation response

International Thin-Film Solar Industry Association, 8 Oct 2018

Please find attached the input provided by PVThin, the international industry coalition whose objective and purpose is to strengthen global energy security, help create sustainable energy infrastructures, as well as promote the social, economic and environmental benefits of thin-film solar…