RoHS Roundtable FH 2009 July 14
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Base presentation from European Commission on RoHS Directive prepared for Fleishman-Hillard EU Roundtable on WEEE and RoHS.
RoHS Roundtable FH 2009 July 14
- 1. Recast of the Directive on restrictions of hazardous substances in electrical and electronic equipment (RoHS) Roundtable Brussels, 14 July 2009 Madalina Caprusu European Commission DG Environment
- 2. Current RoHS Directive Objective: to avoid leakage of hazardous substances from waste to the environment and to prevent contamination with these substances when recycling materials Key elements: Ban on the use of 4 heavy metals and 2 brominated flame retardants in electrical and electronic equipment (EEE) Scope of products leaning on the WEEE Directive Exemptions by comitology, based on availability of alternatives and an assessment of their impacts in terms of environment, health, and consumer safety Similar legislation adopted by China, Korea, Japan, some U.S. states
- 4. Why a revised RoHS? Better Regulation Problems with implementation Coherency with other legislation Article 6 current RoHS: Inclusion of Medical Devices and Measurement and Control Equipment (categories 8 and 9) Adaptation of the list of restricted substances
- 5. Scope Current RoHS Proposal (Art.2, Annexes I and II) Based on the WEEE Directive Product categories and binding EEE under categories 1 - list of products defining the 7 and 10 of Annex IA of scope are set under RoHS the WEEE Directive Products list amendable Electric light bulbs and through comitology luminaries in households Inclusion of categories 8&9 Not spare parts for repair or Not spare parts for compliant reuse of EEE put on the market EEE before 1/7/2006 Not (guidance): Not (legal text): Military Military Equipment designed as part Equipment designed as part of another equipment of another equipment Fixed installation Fixed installation (clarified)
- 6. Definitions Current RoHS Proposal (Art. 3) EEE EEE Producer EU marketing of Main problem: some definitions products legislation are unclear (e.g. producer) or definitions e.g. missing (e.g. put on the manufacturer, distributor, market) making available on the market, market surveillance etc. Categories 8&9 definitions (e.g. AIMD) Homogenous material
- 7. Substance restrictions Current RoHS Proposal (Art. 4(7), Annex IV) Ban on the use of heavy metals No changes to the list of (Pb, Hg,Cd,CrVI) and substances brominated flame retardants Substance restriction (PBB&PBDE) in EEE put on the mechanism in line with the market after 1/7/2006 REACH methodology Maximum concentration List of banned substances and values (MCVs) to be tolerated MCVs - amendable through regarding compliance (Annex) comitology instead of co- New substances co-decision decision 4 substances identified for priority assessment
- 8. Exemptions Current RoHS Proposal (Art. 5, Art.4(4)(f), Art. 5(1)(b)- Criteria for Annexes V&VI) granting exemptions: 4-year maximum validity period, if elimination or with possibility of requesting substitution is technically renewals or scientifically New exemption criteria: impracticable, or availability and reliability of where the negative substitutes and socio-economic environmental, health impacts. and/or consumer safety Permission to use non- impacts caused by compliant spare parts is substitution are likely to extended to equipment outweigh the benefitting from an exemption environmental, health New annex - exemptions for and/or consumer safety categories 8&9 benefits Review at least every 4 years Rules for exemption request - or 4 years after comitology Applications listed in the Annex
- 9. Compliance Current RoHS: Proposal (Arts. 7-17) Art. 4: MS to ensure that from 1/7/06 products put on the EU market comply Alignment with the recently Does not foresee compliance adopted EU "Marketing of procedures or standards to be Products" legislation applied Harmonised provisions on Compliance: is entirely conformity assessment competence of the MS. procedures, CE marking and 2006-MS have set up an market surveillance informal Enforcement Bodies Network
- 10. Summary of proposed modifications Clarification of scope and definitions Inclusion of Medical Devices and Measurement and Control Equipment A clearer mechanism for identifying and restricting the use of additional hazardous substances Adaptation of the procedure for exemptions Harmonisation of conformity assessment requirements with EU legislation on the Marketing of Products Full COM proposal downloadable at: http://ec.europa.eu/environment/waste/weee/pdf/com_2008_809.pdf Thank you for your attention.