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Position paper - Gaps & overlaps between RoHS and REACH: Going beyond the common understanding paper
On 6 May, AmCham EU published the position paper “Gaps & overlaps between RoHS and REACH: Going beyond the common understanding paper”.
Since the European Commission released the ‘REACH and Directive 2011/65/EU: A Common Understanding’ document in July 2014, it acknowledged that there could be overlaps and inconsistencies between these laws. Since then, AmCham EU member companies have experiences of additional forms of overlaps that create harmful and unnecessary duplication, having gained extensive experience with REACH Risk Management Option Analysis (RMOA), have seen the nature of REACH restrictions evolve, and have been through the process of applying for authorization.
This paper outlines some of our observations to help inform the important discussions to come.