Mitsubishi Electric Europe
MEU
Mitsubishi Electric Europe is the European subsidiary of Mitsubishi Electric Corporation, headquartered in London and incorporated in the Netherlands.
ID: 852220992305-91
Lobbying Activity
Meeting with Maroš Šefčovič (Commissioner) and
28 Oct 2025 · Priorities of the EU’s trade agenda
Response to Exemptions under RoHS for lead in glass or ceramic of electrical and electronic components
7 Feb 2025
Mitsubishi Electric supports the overall objectives of the RoHS Directive and remains committed to continue supporting the procedure for adaptation to scientific and technical progress. We also support targeted adaptations where warranted from a standpoint of practicability, reliability and environmental, health and consumer safety impacts. Recognising the nature and breadth of this complex task, we welcome the opportunity to comment on the draft delegated directives published for public consultation on the Have Your Say portal on 13 January 2025. To make the proposal more feasible, please consider the followings. The proposed expiry dates (31 December 2026 or 2027) are unusually short. The short validity periods of 7(c)-I (expiry date 31 December 2026) leave industry with just over 5 months to compile and submit a renewal application by the application deadline of 30 June this year. On the other hand, it takes around 18 months to make the application for renewal of the exemption across the industry. We request to align these dates with previous discussions and similar decisions taken in the past. Rewording and split of exemptions are supported if they lead to greater protection of human health and the environment. However, we have difficulty in understanding how this can be the case for the proposed rewordings and splits. Efforts to simplify and provide clarity in legal text to aid implementation are valid but in this case does not appear justified. Including when considering RoHS alignment globally. We have found that the proposed rewordings and splits would not cover some important applications (such as resistors under 7(c)-I) for which there are currently no alternatives. This may exclude important equipment from the European market and create a serious risk of being inconsistent with the principles of Article 5(1) of the RoHS Directive.
Read full responseResponse to Persistent organic pollutants - UV-328
26 Aug 2024
Mitsubishi Electric Europe welcomes the opportunity to provide comments on the draft Delegated Regulation to list UV-328 in Annex I of the EUs POPs Regulation. UV-328 is regulated not only as a chemical substance but also as a content in articles according to Annex A of the global Stockholm Convention. Therefore, Mitsubishi Electric is promoting the substitution of UV-328 uses in Refrigeration, Air Conditioning and Heat Pump (RACHP) equipment globally and in the EU. On the other hand, the EUs Ecodesign for Sustainable Products Regulation (ESPR) promulgated in 2024 seeks to reduce the disposal of products and to introduce requirements for product life-time extension, like reusability and reparability. In order to meet both these new policy expectations and requirements and the UV-328 POPs restriction, certain time-limited derogations for long-lifetime RACHP equipment are indispensable (10-20+ years according to EU Ecodesign studies). Specifically, the placing on the market of UV-328 present in articles and the use of such articles should be derogated as follows: 1) Spare parts for long-lifetime RACHP equipment that has already been placed on the market in the Union before or on the date of application of the regulation where UV-328 was initially used in their production, in line with the well-established repair as produced principle. 2) RACHP equipment and its spare parts containing UV-328 that have already been placed on the market in the Union before or on the date of application of the regulation. Otherwise, this will result in the following and would make it impossible to achieve the product sustainability that ESPR aims for: 1) Since placing on the market of the spare parts will be prohibited after the date of application of the regulation, it will be impossible to repair RACHP equipment that has already been placed on the market before the application date of the regulation. Therefore, the products must be discarded as waste in case the products break down. 2) RACHP equipment or its spare parts cannot be used after the date of application of the regulation, if they have been placed on the market, for example import in the EU market, but have yet to be put into use, for example sold to end users, by the date of application of the regulation. Therefore, the RACHP equipment or its spare parts must be discarded as waste.
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