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Review: Restriction of the use of hazardous substances in electronics

Environment

EU rules limit the use of certain harmful substances in electrical and electronic equipment in order to protect human health and the environment and ensure proper functioning of the internal market. The initiative will simplify and increase the efficiency of the current rules and improve their enforcement.

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Public consultation

ID: 13137

Lobbying Activity

41 responses

Consultation response

American Chamber of Commerce to the European Union, 14 Mar 2022

AmCham EU welcomes this opportunity to provide comments to the call for evidence (CfE) on the review of RoHS. AmCham EU members have gained significant experience with the implementation of RoHS, ever since its inception. On this basis, we have actively sought to engage at every step of the ongoing…

Chemical Industry Seeks RoHS Coordination with REACH Framework

European Chemical Industry Council, 14 Mar 2022

Cefic requests coordination between RoHS and REACH regulations to avoid overlapping assessments. They want REACH recognized as the primary framework for chemical safety assessment, with RoHS complementing only where necessary.
This would reduce duplicative regulatory assessments and prevent inconsistent requirements across different EU laws.
Environmental and health advocates lose an independent assessment pathway for electronic equipment hazards.

Consultation response

DIGITALEUROPE, 14 Mar 2022

The European technology industry provides the backbone for the future of the EU. Our sector will help the European Commission to deliver on each of its six core priorities including the European Green Deal and the Circular Economy Strategy. Technology provides the key to coming out of the Covid-19…

Consultation response

EUROMETAUX, 14 Mar 2022

Dear Madam, Dear Sir, Please find herewith Eurometaux' s contribution to the call for evidence: RoHS Review/IA Many thanks

MedTech Europe calls for simplified hazardous substance rules

MedTech Europe, 11 Mar 2022

The association recommends that RoHS be maintained but simplified to resolve sectoral challenges. They request longer transition timelines and more predictable exemption processes to preserve innovation resources.
This would allow manufacturers to redirect critical engineering resources toward new product development.
Patients and hospitals lose access to new technologies and affordable equipment.

Consultation response

Verband Deutscher Maschinen- und Anlagenbau e.V., 14 Mar 2022

First of all, VDMA thanks the European Commission for initiating this short sounding feedback opportunity. We appreciate the work which has already been done by the Commission so far and will further be invested during this important review process. The mechanical engineering industry would like…

Consultation response

APPLiA (Home Appliance Europe), 9 Mar 2022

APPLiA, representing the home appliance industry, welcomes the launch of the call for evidence on the RoHS Directive revision. We see an opportunity that a further revision of the RoHS Directive can address some of the ongoing challenges related to the implementation of the legislation towards more…

Consultation response

Scania AB (publ), 14 Mar 2022

Scania is a global manufacturer and provider of transport solutions. With our products, partners and customers we are driving the shift towards sustainable and decarbonised transport systems. Scania welcomes this opportunity to reply to this call for evidence for an impact assessment for a review…

Consultation response

Wirtschaftsvereinigung Stahl, 14 Mar 2022

Die RoHS-Richtlinie ist ein wichtiger Bestandteil der EU-Initiativen zur Kreislaufwirtschaft, der Chemikalienstrategie für Nachhaltigkeit und des Null-Schadstoff-Aktionsplans unter dem Mantel des europäischen Grünen Deals. Die Stahlindustrie ist stets bemüht negative Umweltauswirkungen, die durch…

Consultation response

ASD-Eurospace, 14 Mar 2022

The Commission document titled 'Call for Evidence for an Impact Assessment’ (Ref. Ares(2022)1071846 - 14/02/2022) lists 'Updating and clarifying the scope of the RoHS Directive' among the possible options/sub-options part of the ongoing Review of RoHS. In this regard we would like to recall our…

Consultation response

European Recycling Industries' Confederation, 14 Mar 2022

The European Recycling Industries’ Confederation (EuRIC) welcomes the publication of the call for evidence published by the European Commission on the restriction of hazardous substances in electronics. EuRIC is fully in line with the fact that restricting the use of hazardous substances will have…

Medical Tech Group Urges Proportionality in EU Chemical Rules

European Coordination Committee of the Radiological, Electromedical and healthcare IT Industry, 12 Mar 2022

They seek a simpler exemption process using proportionality for essential medical equipment. They also propose a legacy approach for spare parts to ensure device availability.
Companies would avoid high costs by not redesigning old models for negligible benefits.
Environmental advocates lose as some hazardous chemicals remain in the supply chain longer.

Consultation response

ZVEI e.V. - Verband der Elektro- und Digitalindustrie, 14 Mar 2022

ZVEI thanks for the opportunity to comment in the context of this Call for Evidence. The electrical and digital industry sees the RoHS Directive as an effective tool for the restriction of hazardous substances in electrical and electronic equipment. A simple structure and easy-to-understand…

Consultation response

FEAD, 14 Mar 2022

The Commission has opened a public consultation on the call for evidence for the review of the Restriction of the use of hazardous substances in electronics (RoHS Directive). This initiative intends to update among others, the provision and procedures on granting/ renewing/ revoking exemptions to…

Consultation response

European Federation of National Associations of Water Services, 14 Mar 2022

EurEau welcomes the revision of the RoHS directive which should lead to a clearer scope and simplified, but effective processes to phase out hazardous substances and protect public health and the environment. EurEau believes that the directive should not be maintained as it stands limiting changes…

Consultation response

International Chemical Secretariat, 14 Mar 2022

ChemSec appreciates the opportunity to give feedback to the call for evidence supporting the review of the RoHS directive. To improve the RoHS directive, ChemSec believes that it is preferable to propose ‘hard’ legislative measures rather than ‘soft’ non-legislative measures and that the desired…

Consultation response

Jernkontoret, 14 Mar 2022

Jernkontoret, the Swedish steel Producer´s Association, supports the conclusion that the RoHS Directive has contributed to protecting environment/human health and to the functioning of the internal market. It is therefore important to keep momentum and uphold the function of the…

Consultation response

Japan Business Council in Europe, 13 Mar 2022

JBCE has been supporting European Commission and consultants by taking part in consultations and assessments. JBCE is keen to contribute the impact assessment for the review in order to make RoHS Directive more efficient and effective. We upload a file that summarizes JBCE's ideas. We would…

Consultation response

Electrolux Home Products Europe, 11 Mar 2022

Electrolux is a leading global appliance company that has shaped living for the better for more than 100 years. Under our brands, including Electrolux, AEG and Frigidaire, we sell approximately 60 million household products in approximately 120 markets every year. First of all, we would greatly…

Consultation response

IPC International, Inc., 14 Mar 2022

IPC members represent the global electronics manufacturing supply chain. The industry is financially invested in ensuring RoHS-compliant products continue to be available and it is adherent to RoHS and RoHS-like policies across the global community of electronics manufacturers. To retain the…

SPECTARIS urges simpler exemption rules for electronic hazardous substances

SPECTARIS Deutscher Industrieverband für Optik, Photonik, Analysen- und Medizintechnik e.V., 14 Mar 2022

SPECTARIS wants the exemption process to consider socioeconomic impacts and substitute availability. They also request longer validity and transition periods for highly regulated sectors.
This would reduce administrative burdens and allow companies to focus on research.

Consultation response

Fédération Nationale des Activités de Dépollution et de l'Environnement, 14 Mar 2022

FNADE, the French association for waste management and environmental services, fully support this Commission’s initiative in order to promote cleaner material cycles and environmentally sound waste treatment of EEE. Please find attached FNADE's comments.

Consultation response

Critical Raw Materials Alliance, 14 Mar 2022

Please see the CRM-Alliance contribution attached.

Consultation response

Fédération des Industries Mécaniques, 14 Mar 2022

The French trade association of mechanical engineering industries (FIM) represents 11 700 companies of more than 10 employees that design, manufacture, install and maintain production equipment, mechanical equipment and the parts and sub-assemblies thereof. As a general comment, FIM considers the…

Consultation response

DVGW Deutscher Verein des Gas- und Wasserfaches e.V. - Technisch wissenschaftlicher Verein, 11 Mar 2022

The current scope of the Restriction of Hazardous Substances Directive (RoHS) includes Mercury-based UV low pressure and medium pressure discharge lamps. These kinds of special purpose lamps are widely used across Europe for drinking water disinfection and water treatment purposes guaranteeing the…

Consultation response

BSEF - The International Bromine Council, 10 Mar 2022

BSEF input to ‘Call for Evidence’ on the ‘Review: Restriction of the use of hazardous substances in electronics’ BSEF – the International Bromine Council welcomes the opportunity to contribute to the call for evidence on the RoHS review. As pointed out at previous occasions, we think that…

Consultation response

Beryllium Science & Technology Association, 14 Mar 2022

The Beryllium Science and Technology Association (BeST) represents the manufacturers, suppliers and users of beryllium metal, beryllium containing alloys and beryllium oxide ceramics in the EU market. BeST has the objective of promoting sound policies, regulations, science and actions related to…

Consultation response

European Remanufacturing Council, 14 Mar 2022

The European Remanufacturing Council represents organisations that remanufacture and refurbish products at an industrial scale in Europe. Sales in this sector are valued at approximately €30 billion annually. The sector is a key element of the circular economy as it extends the operational life…

Consultation response

European PVC Window Profiles and related Building Products Association, 14 Mar 2022

The European PVC Profiles and related Building Products Association EPPA represents the manufacturers of PVC window systems and related building products in Europe. About 25,000 employees process about 1, 4 million tonnes of PVC creating a turnover of €4 billion with profile systems and building…

EGMF urges faster EU electronics exemption renewals

European Garden Machinery industry Federation, 14 Mar 2022

The group wants faster chemical exemption renewals and standardized industry definitions. They support turning the directive into a regulation while opposing a merger with REACH.
This would provide better business predictability and reduce compliance costs for manufacturers.

Garden machinery federation urges faster electronics exemption renewals

European Garden Machinery industry Federation, 14 Mar 2022

The federation calls for turning the Directive into a Regulation for better harmonization. They demand a more efficient exemption renewal process to remove business uncertainty.
This would provide manufacturers with greater predictability and reduce long-term compliance uncertainties.
Supporters of a unified chemical policy lose the chance to streamline regulations.

Garden machinery industry urges streamlined EU electronics rules

European Garden Machinery industry Federation, 14 Mar 2022

EGMF requests a more efficient exemption renewal process to reduce manufacturer uncertainty. They support transforming the Directive into a Regulation while opposing its merger into REACH. They also call for a uniform definition of non-road mobile machinery.
A regulation would provide legal certainty while streamlining the inefficient exemption process.
Advocates for streamlined environmental law lose if electronics remain separate from REACH.

Garden machinery industry backs transforming RoHS into EU regulation

European Garden Machinery industry Federation, 14 Mar 2022

The group supports transforming the Directive into a Regulation to ensure harmonization across Europe. They want to simplify the inefficient process for renewing exemptions and oppose merging RoHS into the REACH Regulation.
A Regulation would provide manufacturers with greater legal and business predictability.
Recycled material suppliers lose market share because rules currently favor virgin materials.

Consultation response

SEMI Europe, 14 Mar 2022

We support the RoHS Directive essentially as it stands with supporting information from FAQs and other ‘soft’ measures. However, we do think several aspects of the exemption process would be improved with a few changes, particularly relating to aspects of timing. The RoHS Directive should remain…

Consultation response

International Thin-Film Solar Industry Association, 14 Mar 2022

Please find attached PVthin's feedback to the call for evidence on "Review: Restriction of the use of hazardous substances in electronics".

Consultation response

Atlas Copco AB, 14 Mar 2022

We, Atlas Copco would like to propose to the commission to address the situation of misalignment of the NRMM definition over the different regulations, according to the argumentation attached.

Consultation response

EuroWindoor AISBL, 11 Mar 2022

EuroWindoor appreciates the opportunity to give feedback during the call for evidence supporting the review of Directive 2011/65/EU of RoHS. As mentioned in “the call for evidence” there is a range of issues with the practical operation of the Directive and the surrounding systems especially for…

Consultation response

European Electronics Recyclers Association, 9 Mar 2022

The objectives of the RoHS Directive, to reduce the use of hazardous substances in EEE, have been met and this is excellent. RoHS de-facto has become a global standard. EERA is pleased that the EU the Commission published its European Green Deal, announcing a chemicals strategy for…

Consultation response

Verein Plastic Planet Austria Plastikreduktion, 15 Feb 2022

Stop the illegal e waste export to Ghana .Mike Anane hast a lot of pictures which proove the export. Also Sadrach Nirere from Uganda #endplasticpollution and James Wakibia from Kenya. #endecocide choose www.vppa.at Engagement for plasticreduction

Asociatia Principia calls for draft regulation on electronics chemicals

Asociatia Principia, 15 Feb 2022

The association requests a draft regulation to review the Commission's specific solutions. They want to see concrete terms for addressing the identified environmental and health issues.
Accessing the draft allows the organization to better advocate for citizen and consumer rights.

Consultation response

ALR Innovations LtD ( T/A Votechnik), 15 Feb 2022

Some of the most important issues regarding the review including: - If a waste material is to become a secondary raw materials, it has to re-enter the value chain. This makes it subject to reach and ROHS as a raw material. I believe the timeframe for applications as well as the assessment…