Restriction of hazardous substances - evaluation

The Test & Measurement Coalition is an ad-hoc group of companies active in producing Category 9 industrial type products, which represents roughly 60% of the global production of industrial test and measurement products and other Category 9 industrial equipment including chemical analysers. The Test & Measurement Coalition is pleased to contribute to the current consultation on the RoHS evaluation Roadmap.

The American Chamber of Commerce to the EU (AmCham EU) welcomes the Commission’s initiative to evaluate the performance of the Restriction of Hazardous Substances (RoHS) Directive. Our members have been implementing the directive since its inception in 2003, this has given them the practical experience in effectively evaluating which aspects of the directive have worked well and where improvements are needed.

Since its inception in 2002, the RoHS Directive has become a global reference point for regulation of hazardous substances in electrical and electronic equipment (EEE). This has been effective and given the EU a competitive advantage. The worldwide impact of RoHS is significant and the undersigned associations consider that this should be considered in the roadmap for reviewing the Directive.

It is of utmost importance to phase out the use of hazardous substance in products. This is the overarching principle. In the same time a coherence with the Circular Economy STrategy must be achieved. The EEBs report looks into this subject in detail…

Please find attached the input provided by Scania CV AB, a world-leading provider of engine technologies, offering a comprehensive engine range and tailored services for its customers worldwide as well as transport solutions, including trucks and buses for heavy transport applications combined with an extensive product-related service offering.

Orgalime representing the European Technology Industries welcomes the opportunity to comment on the Commission Roadmap to evaluate the performance of RoHS Directive 2011/65/EU on the restriction of certain hazardous substances in electrical and electronic equipment (EEE).

LightingEurope welcomes the opportunity to comment on the Evaluation Roadmap on Hazardous Substances in Electrical and Electronic equipment. We support the list of topics highlighted in the Roadmap and recommend that the following points are also raised during the detailed evaluation.

EuroWindoor appreciates the opportunity to give feedback to the evaluation of restrictions included in the RoHS Directive 2011/65/EU. EuroWindoor represent the interest of the European window, door and façade sector and has in this role previously provided input for a study initiated by the European Commission to analyse the impact on the industry when windows and doors with electrical function becomes part of the…

DIGITALEUROPE welcomes the opportunity to provide input to the consultation on the Roadmap for the Review of the Directive 2011/65/EU on the restriction of the use of certain hazardous substances in electrical and electronic equipment (RoHS).

JBCE would like to thank the European Commission for the opportunity to provide input to the consultation on the roadmap for the review of the RoHS Directive. We support that this evaluation will assess effectiveness, efficiency, relevance and coherence, however, there are a few areas which we would like the evaluation to incorporate: • Providing sufficient consultation period A sufficient consultation period should…

SEMI, representing the electronics manufacturing industry, welcomes the opportunity to give feedback on the roadmap. We see the following areas of improvement: i) RoHS and REACH inconsistencies; ii) global aspect of RoHS; iii) retention of Large-Scale Stationary Industrial Tools (LSSIT) and Large-Scale Fixed Installations (LSFI) exclusions, and importation of used equipment; and iv) the issues surrounding…

PlasticsEurope comments to the Commission on Roadmap for evaluation of the EU RoHS (Restriction of Hazardous Substances in electrical and electronic equipment) PlasticsEurope appreciates the opportunity to comment on the Commission Roadmap for evaluation of Directive 2011/65/EU of 8 June 2011 on the restriction of the use of certain hazardous substances in electrical and electronic equipment.

Firstly, we would like to express our gratitude for your invitation to stakeholders' comments on the draft “Evaluation Roadmap on RoHS Review”. We consider the proposed Roadmap to be reasonable, generally speaking, however, we would like to call your attention on some issues which we regard as challenges.

COCIR appreciates the EC plan to have a public consultation in spring 2019 and then targeted interviews with stakeholders, but we also believe there is a need to look carefully into B2B sectors that entered the scope in 2014.

We understand and support the need of the RoHS Directive aiming to restrict hazardous substances in EEE, in particular to avoid adverse effects when it comes to dismantle such products for EoL reasons. PVC windows may be subject to RoHS, when they are equipped with electric devices such as cables, drives etc.

Please find attached the input provided by PVThin, the international industry coalition whose objective and purpose is to strengthen global energy security, help create sustainable energy infrastructures, as well as promote the social, economic and environmental benefits of thin-film solar photovoltaic technologies.

The Roadmap is useful to clarify the Commission’s purpose and intentions. The members of the Plastics producers’ associations are not themselves producing E&E goods therefore we cannot comment on the effectiveness and efficiency of RoHS legislation. However, we will be able to comment on the coherence, relevance and EU added value.