I&P Europe - Imaging and Printing Association, would like to submit the following comments regarding spare parts: Our members welcome the extension of the spare parts exemption from 7 to 10 years. However, imaging equipment can have a much longer lifetime than 10 years. This can lead to a situation where large equipment would become waste due to the non-availability of a compliant and fitting "replacement fan". A limited spare part exemption will result in expensive redesign and unnecessary waste creation and is counterproductive to the circular economy and detrimental to the Least Life Cycle Cost (LLCC) principle. For the circular economy to be feasible, spare parts should be available for activities such as maintenance, repair, refurbishment and remanufacturing. We ask that the exemption is not limited in time, such as the repair as produced principle in the RoHS Directive.
We would like to express our support concerning the items in the position papers of the “German chemical industry association - Verband der Chemischen Industrie (VCI)” and “Cefic, the European Chemical Industry Council”.
Additionally, in our opinion CLP must be equipped to deal with hazards resulting from the physical state. Currently a substance is classified based on chemical identity and a mixture is classified based on the chemical identity of the ingredients. In the case of TiO2 we have seen that the carcinogenicity hazard is related to the physical form of the particle (poorly soluble dust). Mixtures must then not be classified by only looking at their ingredients but also by taking into account physical form. We know that this item is not part of the Inception Impact Assessment of the Commission, but we think it is nevertheless a very important issue.