BEAMA

25 July 2011

At the end of May 2011, the European Council rubberstamped a two and half year recast procedure on the revised RoHS Directive. The legislation, which restricts the use of six hazardous substances in electrical and electronic equipment, such as TVs, laptops, washing machines, fridges and lighting equipment has now been extended to progressively phase in medical devices, monitoring and control equipment and other electrical and electronic equipment into the scope.

Adrian Harris, Director General of Orgalime, commented “We said back in May that now this legislation is adopted, we have to make it work and along the timelines fixed. To aid our industry, Orgalime has compiled a guide to the RoHS recast – available for download below. The legislation is critical for our manufacturers as it has far reaching implications: not only do substance restrictions imply design changes with the costs that this entails, but it is also a complex task to ensure that the necessary changes happen in our global supply chains which often include many thousands of suppliers. And our first duty is to ensure that the technical solutions we adopt satisfy our customers while also respecting other essential requirements such as health and safety regulations”.

The Directive also harmonises the rules for reviewing the existing substance restrictions and for adding new ones and it improves the exemptions mechanism in case there are no alternative solutions available for certain applications. Finally, the Directive has been aligned with the concept of ‘New Approach’, which we support. The recast RoHS Directive also ties in with other environmental legislation applying to the same products, notably the REACH Regulation, the Eco Design Directive and the WEEE Directive, and this renders application unduly complex.

The forthcoming transposition and implementation phase will also be crucial for manufacturers. In particular, producers feel it important that:

• Member State’s transpositions respect the harmonised rules set out by the Directive (unlike in the first round of implementation).
• Coherence with the REACH Regulation is ensured, especially when applying the new RoHS substance evaluation methodology before reviewing/setting new restrictions.
• Stakeholders and notably industry experts are involved in the application, including for the input to the new Comitology process.
• Clarity on the scope is provided without delay.

  Orgalime RoHS Guide - July 2011