- Categories:Industry News
- Author:
- Origin:Source from HTDC RESEARCH
- Time of issue:2022-02-26
- Views:0
(Summary description)On 14 February 2022, the European Commission triggered a review process of the rules limiting the use of certain harmful substances in electrical and electronic equipment. The review process is intended to simplify, as well as increase the efficiency of, the current rules and enhance their enforcement in the EU Member States. Feedback is sought from interested parties until 14 March 2022.
The European Commission is calling for evidence from economic operators and any other party that may be impacted by, or interested in, the EU rules restricting certain harmful substances in electrical and electrical equipment (EEE). Hong Kong sellers of consumer electronics will recall that EU legislation restricting the use of hazardous substances in EEE has been in place since 2003, in the form of the RoHS Directive. The Directive has been amended a number of times; it currently restricts the use of 10 hazardous substances in EEE. These include four phthalates, as well as lead and cadmium. The RoHS Directive also complements Directive 2012/19/EU on Waste Electrical and Electronic Equipment (WEEE).
An evaluation of the RoHS Directive has thrown up some concerns concerning its practical operation. These point, in particular, to a high administrative burden and complexity of provisions, regarding, for example, procedures on granting, renewing or revoking exemptions to substance restrictions, which are felt to be complex and have in part proved to be impracticable in their application. There are also issues of predictability (or a lack thereof) for economic operators and an overall high administrative burden.
It is additionally noted that there are insufficiently clear provisions on how the restriction process is triggered, as well as confusion over whether these should be found in RoHS or in the REACH Regulation. There are, furthermore, enforcement difficulties, in particular in the context of e commerce; certain unclear and outdated provisions on spare parts or scope; and insufficient provisions to support the circular economy (e.g. for secondary resources). The problems that have been identified mainly affect (although to differing degrees) economic operators, public authorities including the European Commission, workers in the recycling sector, and the public at large.
It is highlighted that the RoHS Directive addresses consumer goods (EEE) of high economic relevance. Such goods are part of a cross border market that is continually growing, relying on the free movement of goods between the EU Member States. The environmental issues addressed also have cross border effects (i.e., emissions of hazardous substances into the environment), while recycling markets function across borders. As a result, a harmonised approach – taken at EU level – is viewed as being crucial to avoid barriers to trade and distortion of competition in the EU, as well as to establish a sustainable circular economy.
The Commission indicates that, to address the problems identified, a range of possible measures will be considered, keeping in mind that these will have to be aligned with the EU’s overall environmental and health objectives, such as those set down in the EU Chemicals Strategy and the Sustainable Products Initiative.
In order to tackle the issues raised, the Commission has drawn up an initial non exhaustive list of possible options. These represent a mix of predominantly legislative and non legislative (e.g. guidance) measures, and include the following:
Maintain the RoHS Directive as it stands and introduce certain non-legislative (‘soft’) measures, such as an update of the RoHS FAQ document. The guidance would, among other things, explain interactions with, e.g., the REACH Regulation and the Ecodesign Directive.
Reform the substance restriction provisions, including timelines and procedure, and clarify links and potential overlaps with the REACH Regulation and the Ecodesign Directive.
Revise the provisions for spare parts, as well as update and clarify the scope of the RoHS Directive.
Reform the provisions on enforcement and market surveillance, while possibly addressing e-commerce challenges and providing further guidance.
The Commission openly acknowledges that for some changes to the RoHS Directive, such as stricter criteria regarding exemptions so as to encourage more and faster substitution of restricted substances, there may well be increased initial costs for industry, including for SMEs, throughout companies’ supply chains. Indeed, in general, due to their limited resources, SMEs may – it is stated – need to outsource some actions and hence may experience greater impacts than larger companies.
It is felt that an improved regulatory framework for the restriction of hazardous substances in EEE will lead to more coherent and efficient restrictions. This would contribute to the protection of human health and the environment, including the environmentally sound recovery and disposal of waste EEE.
Any changes to the R
(Summary description)On 14 February 2022, the European Commission triggered a review process of the rules limiting the use of certain harmful substances in electrical and electronic equipment. The review process is intended to simplify, as well as increase the efficiency of, the current rules and enhance their enforcement in the EU Member States. Feedback is sought from interested parties until 14 March 2022.
The European Commission is calling for evidence from economic operators and any other party that may be impacted by, or interested in, the EU rules restricting certain harmful substances in electrical and electrical equipment (EEE). Hong Kong sellers of consumer electronics will recall that EU legislation restricting the use of hazardous substances in EEE has been in place since 2003, in the form of the RoHS Directive. The Directive has been amended a number of times; it currently restricts the use of 10 hazardous substances in EEE. These include four phthalates, as well as lead and cadmium. The RoHS Directive also complements Directive 2012/19/EU on Waste Electrical and Electronic Equipment (WEEE).
An evaluation of the RoHS Directive has thrown up some concerns concerning its practical operation. These point, in particular, to a high administrative burden and complexity of provisions, regarding, for example, procedures on granting, renewing or revoking exemptions to substance restrictions, which are felt to be complex and have in part proved to be impracticable in their application. There are also issues of predictability (or a lack thereof) for economic operators and an overall high administrative burden.
It is additionally noted that there are insufficiently clear provisions on how the restriction process is triggered, as well as confusion over whether these should be found in RoHS or in the REACH Regulation. There are, furthermore, enforcement difficulties, in particular in the context of e commerce; certain unclear and outdated provisions on spare parts or scope; and insufficient provisions to support the circular economy (e.g. for secondary resources). The problems that have been identified mainly affect (although to differing degrees) economic operators, public authorities including the European Commission, workers in the recycling sector, and the public at large.
It is highlighted that the RoHS Directive addresses consumer goods (EEE) of high economic relevance. Such goods are part of a cross border market that is continually growing, relying on the free movement of goods between the EU Member States. The environmental issues addressed also have cross border effects (i.e., emissions of hazardous substances into the environment), while recycling markets function across borders. As a result, a harmonised approach – taken at EU level – is viewed as being crucial to avoid barriers to trade and distortion of competition in the EU, as well as to establish a sustainable circular economy.
The Commission indicates that, to address the problems identified, a range of possible measures will be considered, keeping in mind that these will have to be aligned with the EU’s overall environmental and health objectives, such as those set down in the EU Chemicals Strategy and the Sustainable Products Initiative.
In order to tackle the issues raised, the Commission has drawn up an initial non exhaustive list of possible options. These represent a mix of predominantly legislative and non legislative (e.g. guidance) measures, and include the following:
Maintain the RoHS Directive as it stands and introduce certain non-legislative (‘soft’) measures, such as an update of the RoHS FAQ document. The guidance would, among other things, explain interactions with, e.g., the REACH Regulation and the Ecodesign Directive.
Reform the substance restriction provisions, including timelines and procedure, and clarify links and potential overlaps with the REACH Regulation and the Ecodesign Directive.
Revise the provisions for spare parts, as well as update and clarify the scope of the RoHS Directive.
Reform the provisions on enforcement and market surveillance, while possibly addressing e-commerce challenges and providing further guidance.
The Commission openly acknowledges that for some changes to the RoHS Directive, such as stricter criteria regarding exemptions so as to encourage more and faster substitution of restricted substances, there may well be increased initial costs for industry, including for SMEs, throughout companies’ supply chains. Indeed, in general, due to their limited resources, SMEs may – it is stated – need to outsource some actions and hence may experience greater impacts than larger companies.
It is felt that an improved regulatory framework for the restriction of hazardous substances in EEE will lead to more coherent and efficient restrictions. This would contribute to the protection of human health and the environment, including the environmentally sound recovery and disposal of waste EEE.
Any changes to the R
- Categories:Industry News
- Author:
- Origin:Source from HTDC RESEARCH
- Time of issue:2022-02-26
- Views:0
On 14 February 2022, the European Commission triggered a review process of the rules limiting the use of certain harmful substances in electrical and electronic equipment. The review process is intended to simplify, as well as increase the efficiency of, the current rules and enhance their enforcement in the EU Member States. Feedback is sought from interested parties until 14 March 2022.
The European Commission is calling for evidence from economic operators and any other party that may be impacted by, or interested in, the EU rules restricting certain harmful substances in electrical and electrical equipment (EEE). Hong Kong sellers of consumer electronics will recall that EU legislation restricting the use of hazardous substances in EEE has been in place since 2003, in the form of the RoHS Directive. The Directive has been amended a number of times; it currently restricts the use of 10 hazardous substances in EEE. These include four phthalates, as well as lead and cadmium. The RoHS Directive also complements Directive 2012/19/EU on Waste Electrical and Electronic Equipment (WEEE).
An evaluation of the RoHS Directive has thrown up some concerns concerning its practical operation. These point, in particular, to a high administrative burden and complexity of provisions, regarding, for example, procedures on granting, renewing or revoking exemptions to substance restrictions, which are felt to be complex and have in part proved to be impracticable in their application. There are also issues of predictability (or a lack thereof) for economic operators and an overall high administrative burden.
It is additionally noted that there are insufficiently clear provisions on how the restriction process is triggered, as well as confusion over whether these should be found in RoHS or in the REACH Regulation. There are, furthermore, enforcement difficulties, in particular in the context of e commerce; certain unclear and outdated provisions on spare parts or scope; and insufficient provisions to support the circular economy (e.g. for secondary resources). The problems that have been identified mainly affect (although to differing degrees) economic operators, public authorities including the European Commission, workers in the recycling sector, and the public at large.
It is highlighted that the RoHS Directive addresses consumer goods (EEE) of high economic relevance. Such goods are part of a cross border market that is continually growing, relying on the free movement of goods between the EU Member States. The environmental issues addressed also have cross border effects (i.e., emissions of hazardous substances into the environment), while recycling markets function across borders. As a result, a harmonised approach – taken at EU level – is viewed as being crucial to avoid barriers to trade and distortion of competition in the EU, as well as to establish a sustainable circular economy.
The Commission indicates that, to address the problems identified, a range of possible measures will be considered, keeping in mind that these will have to be aligned with the EU’s overall environmental and health objectives, such as those set down in the EU Chemicals Strategy and the Sustainable Products Initiative.
In order to tackle the issues raised, the Commission has drawn up an initial non exhaustive list of possible options. These represent a mix of predominantly legislative and non legislative (e.g. guidance) measures, and include the following:
- Maintain the RoHS Directive as it stands and introduce certain non-legislative (‘soft’) measures, such as an update of the RoHS FAQ document. The guidance would, among other things, explain interactions with, e.g., the REACH Regulation and the Ecodesign Directive.
- Reform the substance restriction provisions, including timelines and procedure, and clarify links and potential overlaps with the REACH Regulation and the Ecodesign Directive.
- Revise the provisions for spare parts, as well as update and clarify the scope of the RoHS Directive.
- Reform the provisions on enforcement and market surveillance, while possibly addressing e-commerce challenges and providing further guidance.
The Commission openly acknowledges that for some changes to the RoHS Directive, such as stricter criteria regarding exemptions so as to encourage more and faster substitution of restricted substances, there may well be increased initial costs for industry, including for SMEs, throughout companies’ supply chains. Indeed, in general, due to their limited resources, SMEs may – it is stated – need to outsource some actions and hence may experience greater impacts than larger companies.
It is felt that an improved regulatory framework for the restriction of hazardous substances in EEE will lead to more coherent and efficient restrictions. This would contribute to the protection of human health and the environment, including the environmentally sound recovery and disposal of waste EEE.
Any changes to the RoHS Directive will not occur immediately. A public consultation will be launched online in the first quarter of this year. It will run for a minimum of 12 weeks. In addition, among other matters, stakeholder meetings will be organised to present and discuss the main issues and options under consideration.
