Position paper - Revision of Directive 2011/65/EU on restriction of the use of certain hazardous substances in electrical and electronic equipment

The European Commission launched a public consultation on the revision of Directive 2011/65/EU on the restriction of the use of certain hazardous substances in electrical and electronic equipment (RoHS Directive). The results of the consultation will contribute to the impact assessment supporting the review of the RoHS Directive. The consultation may significantly impact the requirements for placing on the EU market electrical and electronic equipment (EEE) products.

AmCham EU provided the feedback to the consultation, underlining, that the transformation of RoHS into a Regulation would eliminate the need for transposition and ensure clarity of scope. Moreover, RoHS exemption evaluation should include proper analysis of alternatives and  socio-economic analysis using the well-established methodology developed by ECHA. Timelines for decisions on applications for exemptions needs to be clearly established.