OpenLobby.EU
Explore

RoHS exemption for the use of mercury in other discharge lamps for special purposes

Environment

Links

Public consultation

ID: 13081

Lobbying Activity

12 responses

Consultation response

European Environmental Bureau, 12 Jul 2021

The global markets for UV LED technology are growing very rapidly. Consequently, we urge the Commission to reevaluate this Exemption in three years, rather than granting a five-year exemption with no expiry date. According to one market report, “Amid the COVID-19 crisis, the global market for UV…

Consultation response

Deutsche Umwelthilfe e.V., 7 Jul 2021

Dear Sir or Madam, In the past years, we Environmental Action Germany (Deutsche Umwelthilfe - DUH), have campaigned massively for the implementation of the Directive 2011/65/EU (RoHS Directive) in Germany. Among other activities, we tested whether the legal mercury limits were compliant for…

Consultation response

European Federation of National Associations of Water Services, 12 Jul 2021

The current exemption 4(f): "Mercury in other discharge lamps for special purposes not specifically mentioned in this Annex" should continue to cover the UV disinfection of drinking water and treated waste water to permit compliance with the Drinking Water Directive, the Water Reuse Regulation and…

Consultation response

Flexible Packaging Europe, 9 Jul 2021

Ladies and Gentlemen, We appreciate the opportunity to comment on this legislation proposal. FPE (Flexible Packaging Europe) and etma (European Tube Manufacturers Association) together represent the economic and technical interests of more than 120 member companies producing flexible packaging or…

ESIA Urges Wording Correction for Mercury Lamp Exemption

European Electronic Component Manufacturers' Association, 12 Jul 2021

ESIA asks the Commission to correct a discrepancy in the draft annex. They request the wording 'Mercury in lamps emitting light in the ultraviolet spectrum'. This ensures technical accuracy for semiconductor manufacturing where no alternatives exist.
Maintaining the exemption prevents production halts and significant costs for semiconductor manufacturers.
Downstream sectors lose access to essential components if semiconductor production is disrupted.

ESIA seeks correction to mercury exemption for ultraviolet lamps

European Electronic Component Manufacturers' Association, 12 Jul 2021

ESIA asks the Commission to correct a wording error in the draft annex. They request the exemption cover all mercury lamps emitting light in the ultraviolet spectrum.
Maintaining this exemption ensures the continuity of essential European semiconductor production.
Restricting these lamps would harm many sectors and technologies relying on semiconductors.

Consultation response

Japan Business Council in Europe, 12 Jul 2021

JBCE strongly believe that RoHS Directive has been successful in reaching the objective of reducing hazardous substances in EEE in the EU. As a cross-sector association with member companies operating in different industries and stages in the supply chain, JBCE welcomes the opportunity to provide…

LightingEurope seeks technical correction to UV lamp exemption wording

LightingEurope, 12 Jul 2021

The organization requests correction of a technical error in the exemption wording. They note that the Annex incorrectly describes 'high-pressure sodium vapour lamps emitting in the UV spectrum' which do not exist. They ask the Commission to use the correct wording from the main text instead.
This ensures the regulation accurately reflects existing lamp technologies their members produce.

Consultation response

Performing Arts Employers Associations League Europe, 1 Jul 2021

The European Ecodesign-Coalition, representing artists, manufacturers and service providers in the theatre and entertainment technology sectors, appreciates the EU Commission’s efforts to reduce the use of hazardous substances in products brought into the European Market. We have been working…

Consultation response

European Carton Makers Association, 9 Jul 2021

Dear Ladies and Gentlemen, As indicated in the consultation, carton makers are widely using mercury-containing UV lamps for safe curing. We fully support the further comments submitted by our suppliers and assume the text in Annex 4(f) - IV can be reworded into "Mercury in lamps emitting light…

Consultation response

CLASP, 12 Jul 2021

CLASP fully supports the comments submitted by the EEB on this product group. The global markets for UV LED technology are growing very rapidly and consequently the Exemption should be re-evaluated in three years, rather than granting a five-year exemption with no expiry date. As noted in one…

Consultation response

European Printing Ink Association, 9 Jul 2021

Mercury discharge lamps are commonly used in the printing ink industry to dry inks, coatings and adhesives which are used on all types of packaging including a broad selection of food packaging, as well as magazines, books, advertising matter, credit and loyalty cards, business forms, labels and…