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Position paper - Comments on RoHS Substance Inventory
Following the release of the latest Substance Inventory and final restriction methodology (both dated 26 September 2019) prepared by Oeko Institut. The American Chamber of Commerce to the European Union (Amcham EU) is concerned about how the methodology was applied to produce the Inventory, since it prioritized in Group I chemicals which are not hazardous under CLP and/or not present in EEE. This alone, questions the adequacy of the methodology overall and/or the adequacy of its implementation to produce the Inventory and systematically assess the seven shortlisted substances. We request responses to the comments made in previous letters and request that the restriction assessment under RoHS be discussed under the RoHS Review.
For additional information about our position on the RoHS Substance Inventory, please contact Alicia Jensen (AJE@amchameu.eu).