EFS Consulting

RoHS Regulation instead of RoHS Directive?

Public consultation has been launched on a review of the ROHS Directive 

The EU Commission has launched a public consultation regarding a review of the EU rules for the restriction of the use of hazardous substances in electronics.  The RoHS Directive currently restricts the use of 10 hazardous substances in EEE and is a part of the CE conformity assessment system in the EU. 

The assessment and consultations undertaken by the EU Commission as part of the RoHS Directive’s evaluation process indicated that the Directive basically reaches its objective.  However, the evaluation also identified a range of issues with the practical operation of the Directive and some systemic issues, pointing in particular to the high administrative burden and complexity of provisions and processes in place. 

Therefore, several options are being considered to improve the RoHS framework in the EU: 

  • Maintain the RoHS Directive as it stands and introduce certain non-legislative (‘soft’) measures, such as an update of the RoHS FAQ document. 
  • Simplify and clarify the RoHS Directive by introducing and revising legislative (‘hard’) measures and soft measures to: (i) clarify and improve the exemption criteria and process; (ii) clarify and improve the substance restrictions trigger, criteria and process; (iii) ensure coherence with other legislation, primarily REACH and Ecodesign; and (iv) improve implementation and enforcement.
  • Transform the RoHS Directive into a regulation, to simplify application and reduce unnecessary regulatory burden related to differing transposition in different Member States. 
  • Repeal the RoHS Directive and incorporate its provisions into the REACH Regulation. 
  • Repeal the RoHS Directive and address product requirements related to the environmentally sound recovery and disposal of electrical and electronic waste under sustainable products legislation. 

The public consultation can be accessed HERE. 

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