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ALR Innovations LtD ( T/A Votechnik)

VT

Votechnik is SME company specializing in metallurgy, materials recovery and recycling and the application of robotic technology in the raw material space for enhanced efficiencies.

Lobbying Activity

Response to Review: Restriction of the use of hazardous substances in electronics

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 procedures for secondary raw materials is a challenge for the circular economy - In addition secondary raw materials will need to move with in EU countries and this requires agreement between the individual countries and status of the secondary raw materials which creates very bespoke situations and conditions for a secondary raw material - slowing its appeal as a raw material that can be imported. Having the administration at EU level rather then member state level would help resolve this problem.
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