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Environment: Orgalim response to the public consultation on the RoHS evaluation

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12/06/2019 | 12:16pm EST

Contribution ID: 566d35e8-50c8-4899-a64e-4cef442915e7

Date: 06/12/2019 14:24:20

Public Consultation on the RoHS Evaluation

Fields marked with * are mandatory.

Introduction

The rise in the production and usage of electrical and electronic products, such as mobile phones, computers and kitchen appliances, has resulted in an increasing volume of electrical and electronic waste.

During the collection, treatment and disposal of the waste, the products may release harmful (hazardous) substances such as lead, mercury and cadmium. These hazardous substances may even be released during the use of the product.

To address such challenges, EU legislation restricts the use of certain hazardous substances in electrical and electronic equipment (the RoHS Directive (2011/65/EU)). Currently, it restricts the use of ten substances: lead, cadmium, mercury, hexavalent chromium (chromium (VI)), polybrominated biphenyls (PBB) and polybrominated diphenyl ethers (PBDE), bis(2ethylhexyl) phthalate (DEHP), butyl benzyl phthalate (BBP), dibutyl phthalate (DBP) and diisobutyl phthalate (DIBP). All products with an electrical and electronic component,

unless specifically excluded, have to comply with these restrictions.

The legislation protects human health and the environment. It also contributes to the free movement of goods within the EU, encourages development of innovative products and technologies, and inspires non-European countries to pass similar laws.

The purpose of this consultation is to gather views of consumers, civil society and other organisations on how the restriction of hazardous substances in electronic products works in practice.

The views will help the Commission in assessing what works well, what not and why.

About you

  • Language of my contribution
    Bulgarian
    Croatian
    Czech
    Danish
    Dutch
    English
    Estonian
    Finnish
    French
    Gaelic
    German
    Greek
    Hungarian
    Italian

1

Latvian

Lithuanian

Maltese

Polish

Portuguese

Romanian

Slovak

Slovenian

Spanish

Swedish

  • I am giving my contribution as

Academic/research institution

Business association

Company/business organisation

Consumer organisation

EU citizen

Environmental organisation

Non-EU citizen

Non-governmental organisation (NGO)

Public authority

Trade union Other

  • First name

Stéphanie

  • Surname

Mittelham

  • Email (this won't be published)

stephanie.mittelham@orgalim.eu

  • Organisation name

255 character(s) maximum

Orgalim, Europe's Technology Industries

  • Organisation size

Micro (1 to 9 employees)

Small (10 to 49 employees)

Medium (50 to 249 employees) Large (250 or more)

2

Please specify whether your annual turnover is

≤ 2 million euros

≤ 10 million euros

≤ 43 million euros

> 43 million euros

I prefer not to disclose this information

Please specify whether you are primarily involved as or represent:

Raw material supplier

Manufacturer of components to be integrated into finished electrical and electronic equipment

Manufacturer of finished electrical and electronic equipment

Distributor/ Importer

Waste manager Other

Please specify which of the following RoHS categories of electrical and electronic equipment you deal with (maximum of three choices):

Large household appliances such as refrigerators, microwaves, washing machines or air conditioner appliances

Small household appliances such as vacuum cleaners, irons, electric knives or appliances for hair-cutting, hair drying or tooth brushing

IT and telecommunications equipment such as printers, computers, telephones or other products or equipment transmitting sound, images or other information by telecommunications

Consumer equipment such as radios, televisions, video cameras or audio amplifiers

Lighting equipment such as straight fluorescent lamps, compact fluorescent lamps, high intensity discharge lamps or low pressure sodium lamps

Electrical and electronic tools such as drills, saws, sewing machines or tools for mowing or other gardening activities

Toys, leisure and sports equipment such as electric trains, hand-held video game consoles or sports equipment with electric or electronic components

Medical devices such as radiotherapy equipment, dialysis, cardiology or laboratory equipment

In vitro diagnostic medical devices

Monitoring and control instruments such as smoke detectors, heating regulators or thermostats

Industrial monitoring and control instruments such as control panels

Automatic dispensers such as for hot drinks, solid products or money Other equipment not covered by any of the categories above

  • If other, please specify:

3

Orgalim represents the manufacturers of electric and electronic equipment as covered by the scope of the RoHS Directive 2011/65/EU as a whole. Overall, Orgalim represents Europe's technology industries - innovative companies spanning the mechanical engineering, electrical engineering and electronics, and metal technology branches. Together they represent the EU's largest manufacturing sector, generating annual turnover of around €2,000 billion, manufacturing one-third of all European exports and providing 11 million direct jobs.

Transparency register number

255 character(s) maximum

Check if your organisation is on the transparency register. It's a voluntary database for organisations seeking to influence EU decision- making.

Orgalim is registered under the European Union Transparency Register - ID number: 20210641335-88.

  • Country of origin

Please add your country of origin, or that of your organisation.

Afghanistan

Djibouti

Libya

Saint Martin

Åland Islands

Dominica

Liechtenstein

Saint Pierre

and Miquelon

Albania

Dominican

Lithuania

Saint Vincent

Republic

and the

Grenadines

Algeria

Ecuador

Luxembourg

Samoa

American

Egypt

Macau

San Marino

Samoa

Andorra

El Salvador

Madagascar

São Tomé and

Príncipe

Angola

Equatorial

Malawi

Saudi Arabia

Guinea

Anguilla

Eritrea

Malaysia

Senegal

Antarctica

Estonia

Maldives

Serbia

Antigua and

Eswatini

Mali

Seychelles

Barbuda

Argentina

Ethiopia

Malta

Sierra Leone

Armenia

Falkland Islands

Marshall

Singapore

Islands

Aruba

Faroe Islands

Martinique

Sint Maarten

Australia

Fiji

Mauritania

Slovakia

Austria

Finland

Mauritius

Slovenia

Azerbaijan

France

Mayotte

Solomon

Islands

Bahamas

French Guiana

Mexico

Somalia

Bahrain

French

Micronesia

South Africa

Polynesia

Bangladesh

French

Moldova

South Georgia

Southern and

and the South

Antarctic Lands

Sandwich

Islands

4

Barbados

Gabon

Monaco

South Korea

Belarus

Georgia

Mongolia

South Sudan

Belgium

Germany

Montenegro

Spain

Belize

Ghana

Montserrat

Sri Lanka

Benin

Gibraltar

Morocco

Sudan

Bermuda

Greece

Mozambique

Suriname

Bhutan

Greenland

Myanmar

Svalbard and

/Burma

Jan Mayen

Bolivia

Grenada

Namibia

Sweden

Bonaire Saint

Guadeloupe

Nauru

Switzerland

Eustatius and

Saba

Bosnia and

Guam

Nepal

Syria

Herzegovina

Botswana

Guatemala

Netherlands

Taiwan

Bouvet Island

Guernsey

New Caledonia

Tajikistan

Brazil

Guinea

New Zealand

Tanzania

British Indian

Guinea-Bissau

Nicaragua

Thailand

Ocean Territory

British Virgin

Guyana

Niger

The Gambia

Islands

Brunei

Haiti

Nigeria

Timor-Leste

Bulgaria

Heard Island

Niue

Togo

and McDonald

Islands

Burkina Faso

Honduras

Norfolk Island

Tokelau

Burundi

Hong Kong

Northern

Tonga

Mariana Islands

Cambodia

Hungary

North Korea

Trinidad and

Tobago

Cameroon

Iceland

North

Tunisia

Macedonia

Canada

India

Norway

Turkey

Cape Verde

Indonesia

Oman

Turkmenistan

Cayman Islands

Iran

Pakistan

Turks and

Caicos Islands

Central African

Iraq

Palau

Tuvalu

Republic

Chad

Ireland

Palestine

Uganda

Chile

Isle of Man

Panama

Ukraine

China

Israel

Papua New

United Arab

Guinea

Emirates

Christmas

Italy

Paraguay

United

Island

Kingdom

Clipperton

Jamaica

Peru

United States

Cocos (Keeling)

Japan

Philippines

United States

Islands

Minor Outlying

Islands

5

Colombia

Jersey

Pitcairn Islands

Uruguay

Comoros

Jordan

Poland

US Virgin

Islands

Congo

Kazakhstan

Portugal

Uzbekistan

Cook Islands

Kenya

Puerto Rico

Vanuatu

Costa Rica

Kiribati

Qatar

Vatican City

Côte d'Ivoire

Kosovo

Réunion

Venezuela

Croatia

Kuwait

Romania

Vietnam

Cuba

Kyrgyzstan

Russia

Wallis and

Futuna

Curaçao

Laos

Rwanda

Western

Sahara

Cyprus

Latvia

Saint

Yemen

Barthélemy

Czechia

Lebanon

Saint Helena

Zambia

Ascension and

Tristan da

Cunha

Democratic

Lesotho

Saint Kitts and

Zimbabwe

Republic of the

Nevis

Congo

Denmark

Liberia

Saint Lucia

  • Publication privacy settings

The Commission will publish the responses to this public consultation. You can choose whether you would like your details to be made public or to remain anonymous.

Anonymous

Only your type of respondent, country of origin and contribution will be published. All other personal details (name, organisation name and size, transparency register number) will not be published.

Public

Your personal details (name, organisation name and size, transparency register number, country of origin) will be published with your contribution.

I agree with the personal data protection provisions

  • Please select the statement(s) that best apply to you
    (Your choice(s) will define the parts of the survey that you have access to):

You are a citizen with a general interest in hazardous substances in electrical and electronic equipment

You have specific knowledge in the domain of hazardous substances in electrical and electronic equipment and/or Directive 2011/65/EU

Questionnaire for stakeholders and individuals with special

knowledge in the domain of hazardous substances in electrical and electronic equipment

6

Effectiveness

The following questions aim to evaluate the effectiveness of the Directive by determining to what extent its objectives have been achieved as well as by identifying the factors that contribute to or stand in the way of reaching such objectives. The questions furthermore aim to determine if any unexpected or unintended effects linked to the Directive have occurred.

Human health and environment

1. Has the RoHS Directive helped to reduce the use of hazardous substances in electrical and electronic equipment placed on the market?

Don't

Yes No

Electrical and electronic equipment produced and sold in the EU

Electrical and electronic equipment produced in the EU and sold outside the

EU

Electrical and electronic equipment produced outside the EU and sold in the

EU

know

If yes, please indicate the strength of the reduction for the relevant substance (s):

STRONG

LIMITED

NO EFFECT

DON'T KNOW

Lead

Mercury

Cadmium

Hexavalent chromium

Polybrominated biphenyls (PBB)

Polybrominated diphenyl ethers (PBDE)

Bis(2ethylhexyl) phthalate (DEHP)

Butyl benzyl phthalate (BBP)

Dibutyl phthalate (DBP)

Diisobutyl phthalate (DIBP)

2. Has the RoHS Directive helped to protect human health?

Yes

To a limited extent

No

Don't know

What factors contributed to or stood in the way of protecting human health?

7

500 character(s) maximum

Factors, which contributed to protect human health: the RoHS Directive has directly contributed to reduce the quantity of hazardous substances present in EEE through substance restriction and to promote substitution. However, scientific evidence is limited.

Factors, which stood in the way of protecting human health: lack of focus on a risk-based approach to restriction and lack of enforcement.

3. Has the RoHS Directive helped to reduce damage to the environment?

Yes

To a limited extent

No

Don't know

What factors contributed to or stood in the way of reducing damage to the environment?

500 character(s) maximum

Factors, which contributed of reducing damage to the environment: the RoHS Directive has directly contributed to reduce the quantity of hazardous substances present in EEE throughout the life cycle, including use and end of life management phase.

4. Has the RoHS Directive helped to ensure the free movement of electrical and electronic equipment throughout the EU?

Yes

To a limited extent

No

Don't know

Please elaborate:

500 character(s) maximum

RoHS contributes to the free movement of goods within the EU despite the free movement of electrical and electronic equipment not being the primarily goal of the Directive. The legal base of Article 114 of the EU Treaty secures maximum harmonisation throughout the internal market. However, during implementation at Member States' level certain inconsistencies and different interpretations occur, which the Commission's FAQ document helps to address to some extent, however in a non-binding way.

5. Has the RoHS Directive facilitated the environmentally sound collection and treatment of electrical and electronic waste?

Yes

To a limited extent

No

Don't know

What factors contributed to or stood in the way of facilitating the environmentally friendly collection and treatment of electrical and electronic waste?

500 character(s) maximum

8

Considering the reduced presence of restricted substances in EEE, RoHS supports environmentally friendly collection and treatment. However, installed recycling technologies would need to improve further (e.g.: better sorting technologies) to further facilitate environmentally friendly treatment. EU standards EN 50625 & EN 50614 covering the collection, transport, reuse and treatment of WEEE should be applied uniformly by all actors in a harmonised way throughout Europe.

6. In terms of collecting and recycling electrical and electronic waste, to what extent do you agree with the following statements

STRONGLY

STRONGLY

DON'T

AGREE

DISAGREE

KNOW

AGREE

DISAGREE

I know what to do with electrical and electronic waste

It is easy to recycle electrical and electronic waste

7. In terms of collecting and recycling electrical and electronic waste, to what extent do you agree with the following statements

STRONGLY

STRONGLY

DON'T

AGREE

DISAGREE

KNOW

AGREE

DISAGREE

Presence of hazardous substances hinders the recycling of electrical and electronic waste

The information on presence of hazardous substances in electrical and electronic waste is sufficient

The way in which electrical and electronic waste is recycled reduces risks to the environment

The way in which electrical and electronic waste is recycled reduces risks to human health

The information available on the results of electrical and electronic waste treatment is sufficient

8. The following hazardous substances hinder environmentally sound treatment of waste electrical and electronic equipment (WEEE)

9

STRONGLY

STRONGLY

DON'T

AGREE

DISAGREE

KNOW

AGREE

DISAGREE

Lead

Mercury

Cadmium

Hexavalent chromium

Polybrominated biphenyls (PBB)

Polybrominated diphenyl ethers (PBDE)

Bis(2ethylhexyl) phthalate (DEHP)

Butyl benzyl phthalate (BBP)

Dibutyl phthalate (DBP)

Diisobutyl phthalate (DIBP)

Other

If other, please specify:

500 character(s) maximum

The presence of these substances impacts the WEEE treatment and restrictions positively support environmentally friendly WEEE treatment. However, the applied recycling technology also strongly influences if the WEEE treatment has been environmentally friendly or not. EU standards EN 50625 and EN 50614 covering the collection, transport, reuse and treatment of WEEE should be applied uniformly by all actors in a harmonised way throughout Europe for further improving quality waste management.

9. To your knowledge, has the Directive contributed to the decrease of the following hazardous substances in waste electrical and electronic equipment (WEEE)?

Yes

No

Don't know

Lead

Mercury

Cadmium

Hexavalent chromium

Polybrominated biphenyls (PBB)

Polybrominated diphenyl ethers (PBDE)

Bis(2ethylhexyl) phthalate (DEHP)

10

Butyl benzyl phthalate (BBP)

Dibutyl phthalate (DBP)

Diisobutyl phthalate (DIBP)

10. Please specify to which specific stream of WEEE your answers apply.

500 character(s) maximum

  1. To your knowledge, has the decrease of the listed hazardous substances in WEEE influenced waste treatment operations?
    Yes
    No
    I do not know
  2. Is the RoHS Directive enforced by the responsible authorities in your country?
    Yes, fully
    To some extent
    Not at all
    Don't know

Please elaborate:

500 character(s) maximum

13. Are there differences in the enforcement of the RoHS Directive across EU countries?

Yes

No

Don't know

Please elaborate:

500 character(s) maximum

The level enforcement varies from one EU Member State to another. There are no harmonized enforcement activities throughout the EU Member States.

For example, interpretation regarding the categories and what is meant with "equipment" and "large-scale" (stationary industrial tools and fixed installations) varies between different Member States, manufacturers, customers etc.

The Commission RoHS FAQ is a helping tool to some extent, however not legally binding.

14. Has there been any effect of the RoHS Directive on innovation? There has been a positive effect

There has been a negative effect

There has been no effect

11

Don't know

Please provide an example highlighting the positive or negative effect of the Directive on innovation.

500 character(s) maximum

POSITIVE: stronger research for substitution + incentive to improve technology/material use. NEGATIVE: international different scope & substances of non-EU RoHS & EU RoHS increase effort & complexity in communication. POSITIVE for substance innovation BUT NEGATIVE for circular economy innovation: RoHS impacts remanufacturing & using recyclates since reused EEE or EEE made of recyclates containing substances in concentrations exceeding current thresholds not allowed to be made available in EEA.

15. Has the RoHS Directive had any effect on your expenditure on research and investment?

There has been a positive effect

There has been a negative effect

There has been no effect

Don't know

Please provide an example highlighting the positive or negative effect of the Directive.

500 character(s) maximum

POSITIVE effect on expenditure on research&investment + level playing field created awareness on the content of substances+increase of resources dedicated to research&innovation, especially to substitute restricted substances.

NEGATIVE: not always considered as positive, since the additional R&D expenses were considered sometimes as a cost, rather than investments dedicated to improving equipment performances. POSITIVE for substance innovation BUT NEGATIVE for circular economy: see Q.14

  1. What has been the overall impact of the RoHS Directive in the EU on exports from the EU to a third country?
    Exports increased
    Exports decreased
    There has been no effect on exports to third countries
    Don't know
  2. What has been the overall impact of the RoHS Directive in the EU on imports to the EU from a third country?
    Imports increased
    Imports decreased
    There has been no effect on imports from third countries
    Don't know
  3. Are there specific examples that illustrate the effect of the Directive on trade?

500 character(s) maximum

12

19. Beyond the main objectives of the RoHS Directive, have there been any unexpected negative or positive changes as a result of this Directive?

500 character(s) maximum

POSITIVE: EU leading role in the world + RoHS helped to improve communication on material and component knowledge through the supply chain + original RoHS intention was to contribute to the protection of human health & the environment. Its provisions now also aim at supporting the circular economy to some extent.

NEGATIVE: financial & administrative burden + no harmonized enforcement worldwide + highly increased communication requirements over the whole product lifetime

Efficiency

The following questions aim to evaluate the efficiency of the Directive by identifying the main costs and benefits of implementing it. More importantly, this section aims to assess to what extent the benefits of the restriction on the use of hazardous substance justify the costs of the Directive. Furthermore, the aim of these questions is to obtain information and data to assess if there have been significant differences in costs and benefits between Member States as well as identifying if there was any possibility to increase efficiency. These questions aim at understanding whether the Directive has led to unnecessary burden or made the system unnecessarily complex.

20. What are the benefits of the Directive for the economy? Please select all that apply:

Increased a level playing field for economic operators;

Increased legal certainty regarding hazardous substances;

Creation of jobs in customs, inspections

Creation of jobs in electrical or electronic equipment waste treatment and recycling;

Creation of jobs in R&D for electrical and electronic equipment

Easier identification of whether electrical and electronic equipment are legally placed on the market through the CE mark;

Trading costs are reduced when selling electrical and electronic equipment to a different Member State

No benefits Other

21. What are the benefits of the Directive for the environment? Please select all that apply:

Led to a larger number of product designs of electrical and electronic equipment that are more circular in nature;

The substance restrictions provided manufacturers with incentives to find alternatives to hazardous substances;

Avoided emissions of hazardous substances into soil, air and water streams through reduction of use of hazardous substances in producing electrical and electronic equipment;

Avoided emissions of hazardous substances from electrical or electronic equipment waste into soil, air and water streams;

Avoided clean-up of emissions of hazardous substances from waste illegally dumped into the environment;

13

Improved recyclability of electrical and electronic equipment;

No benefits; Other

22. What are the benefits of the Directive for the society? Please select all that apply:

Avoided negative health effects on consumers from emissions of hazardous substances from electrical or electronic equipment waste;

Avoided negative health effects on workers due to exposure to hazardous substances from production, use or end-of-life phase of electrical or electronic equipment;

Avoided health costs to workers due to exposure to hazardous substances from production, use or end-of-life phase of electrical or electronic equipment;

No benefits; Other

  • If other, please specify:

500 character(s) maximum

RoHS may have positively contributed to the proposed areas, however, limited scientific evidence is available.

  1. Do your company/ the companies you represent have the obligations of a manufacturer under the RoHS Directive?
    Yes
    No
    Don't know
  2. What aspects of the RoHS Directive do you have to comply with? Please tick all that apply
    Restrictions
    Declaration of Conformity
    CE marking
    Other

If other, please specify:

500 character(s) maximum

RoHS Article 5 implementation

24.1 How long does it take to complete a declaration of conformity? Less than one working hour

Less than half a working day

Less than a working day

More than a working day

Don't know

14

24.2 How often do you have to update the declaration of conformity for a given product, please specify?

500 character(s) maximum

No one size fits all answer possible, depends on the case. In general, the declaration of conformity needs to be updated depending on changes in supplier processes and when changes in legislation enter into force, e. g. amendments or expired exemptions. Changes are also made further to customer requests.

25. In your experience, what are the costs for your company/ the companies you represent triggered by the RoHS Directive (please consider both monetary and non-monetary costs)?

Please indicate from a scale of 0-10 the significance of the following costs:

Costs related to training and information measures;

Costs of collecting and reviewing information;

Costs related to a dedicated IT system to manage all required pieces of information;

Costs related to the technical documentation;

Costs related to the conformity assessments;

Costs related to purchasing standards;

Costs related to exemption procedures;

Costs related to the adaptation to amendments to Annexes;

Costs for complying with the rules for the CE mark;

Getting supply chain information;

15

Monetary losses related to RoHS 2 compliance;

Capital expenditure;

R&D expenditure;

Operating expenditure;

Other

If other, please specify:

500 character(s) maximum

We replied 5 to all questions as responses vary from 0 to 10 depending on companies. Orgalim represents companies of different sizes manufacturing a wide range of equipment. Financial & administrative costs for companies in implementing RoHS are very significant. Very high efforts required to prove product conformity throughout the entire supply chain & directly related to complexity of products and size of supply chain. Purchase costs for standards minor & research costs can be substantial.

26. How many full time equivalent (FTE) employees do you have working on the RoHS compliance per year?

None

Less than 0.25

Less than 0.5 FTE

Less than 0.75 FTE

Less than 1 FTE

Less than 2 FTEs

Less than 3 FTEs

More than 3 FTEs

Other

Don't know

If other, please specify:

500 character(s) maximum

It is not possible to give such an estimation considering Orgalim represents companies of different sizes, from SMEs to global companies, which are manufacturing a wide range of equipment.

27. Have you made any initial investment to comply with RoHS? Yes

16

No

Don't know

Please express the initial investment costs due to RoHS compliance in percentage:

Yes but it is not possible to give a precise estimation considering Orgalim represents companies of different sizes, from SMEs to global companies, which are manufacturing a wide range of equipment.

28. Has your operational costs/ the operational costs for the companies you represent increased due to the compliance with RoHS?

Yes

No

Don't know

Please express the increase in operational costs due to RoHS compliance in percentage:

It is not possible to give such an estimation considering Orgalim represents companies of different sizes, from SMEs to global companies, which are manufacturing a wide variety of different equipment. However, almost all companies in EEE sector experienced a significant increase in costs (both monetary and non-monetary) due to the compliance with RoHS. Depending on the company, the increase in operational costs due to RoHS compliance is explained by the following elements:

•Costs to communicate about the RoHS compliance in the supply chain •Declaration of conformity costs

•Costs for production increased and therefore also the costs of EEE increased •Investments for manufacturing companies

In case RoHS will be reviewed, we ask the European Commission to conduct a cost benefit impact assessment.

  1. Do you think that the benefits of the Directive justify the costs of implementation?
    Yes
    No
    Don't know
  2. Have you encountered problems to place an electrical and electronic on the market in the EU?
    Yes
    No
    Don't know
  3. How significant are the following problems? 5 = most significant, 1 = least significant

1 2 3 4 5

It is difficult to decide whether a product is an electrical and electronic equipment or not.

17

It is difficult to decide whether a product is excluded from scope or not.

The categories of Annex I are not well defined.

Existing guidance documents are not sufficient.

The rules for the CE marking are not clear.

The system of exemptions is too complex.

Market surveillance is acting differently in different Member States.

Internet shops cannot be effectively controlled.

Sanctions for non-compliance are different in different Member States.

Sanctions for non-compliance are too strict.

Customs authorities have to refer to the market surveillance authority in case they suspect that an electrical and electronic equipment is non- compliant. This blocks my imports.

Market surveillance is not always targeting the 'bad guys'.

Other

32. Have you encountered problems to place electrical and electronic equipment on markets outside the EEA with similar legislation as the RoHS Directive?

Yes

No

Don't know

If yes, please specify the country:

It is complex for companies operating in different regions of the world to relate to so many different variations of substance restriction legislation. The problems arise when the legislation is quite similar but not equal to Europe. They may differ in important points or in additional and different methodology, such as e.g. China RoHS and Korea RoHS.

33. Has the Directive decreased differences in the administrative processes relating to RoHS compliance among Member States?

Yes

No

Don't know

If yes, please provide examples of how has the Directive decreased differences in the administrative processes among Member States

500 character(s) maximum

Declaration of conformity, placing on the market.

18

34. Please specify any provision of the RoHS Directive that is particularly efficient

500 character(s) maximum

•The targeted number of priority substances restricted has been effective (as opposed to the 201 substances on the REACH Candidate List).

•Declaration of conformity (Article 13) & conditions for affixing the CE marking (Article 15)

•The existence of an exemption mechanism is exemplary in EU chemicals legislation and as such efficient. However important implementation issues exist.

35. Please specify any provision of the RoHS Directive that is particularly inefficient

500 character(s) maximum

•Exemptions dossiers must be handled more quickly as the time required by the Commission to grant an exemption is today 3 years or more compared to 12-18 months in 2006.

•The fact that exemptions where there is no alternative in the foreseeable future, also need to be renewed, is costly.

36. What has been the effect of the RoHS Directive on the competitiveness and comparative advantage of your company/ the companies you represent?

INCREASED

NO EFFECT

DECREASE

DON'T KNOW

Production costs

Prices for consumers

Margins for producers

Don't know

  1. Are you aware of the possibility to ask for exemptions from the substance restrictions set by the RoHS Directive?
    Yes
    No
  2. Has your organisation or company...

Asked for an exemption

Considered asking for an exemption

Not asked for an exemption

39. To which extent does the exemption system generate administrative burden?

To a large extent

To some extent

To a small extent

Not at all

Don't know

19

Coherence

The following questions aim to evaluate the coherence of the Directive with other EU legislation and the internal coherence of the Directive. More importantly, this section aims to understand how the presence or lack of coherence impacts the functioning of the Directive. Additional questions seek to explore whether the Directive has influenced the development of similar legislation in jurisdictions outside the EU.

40. The RoHS Directive interacts with other EU legislation and standards. Are you aware of any unnecessary overlaps, gaps and contradictions between the Directive and the following EU legislation

Don't

Yes No

Waste Framework Directive

Waste Electrical and Electronic Equipment (WEEE) Directive

End-of-life vehicles (ELV) Directive

Batteries Directive

Waste Shipment Regulation

Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) Regulation

Classification, Labelling and Packaging (CLP) Regulation

Persistent Organic Pollutants (POP) Regulation

Regulation on accreditation and market surveillance

Eco-design Directive

Other

If other, please specify:

Exhaust emission regulation: different definitions of Non-Road Mobile Machinery.

Green Public Procurement: different values for chemicals.

know

If yes, please explain and indicate which impact this may have on the functioning of the Directive:

500 character(s) maximum

Examples of unnecessary overlaps, gaps & contradictions between RoHS & following other EU legislation: •Eco-design: phase out of some lamp types in RoHS/Eco-Design is different

•REACH: double regulation of the same substances, for example group entry 51 "phthalates", EEE within the scope of RoHS are exempted, but the spare parts, components and supplied parts are not; for SMEs it can be easier to work with RoHS than REACH since better targeted and focused on their sphere of activity.

41. Are you aware of any different limit values for chemicals applying to the same products in other EU or national legislation?

20

Yes

No

Don't know

If yes, please specify:

500 character(s) maximum

For example, the cadmium limit under other EU legislation is less strict, such as the EU Ship recycling Regulation is 0.1% whereas the cadmium limit under REACH & RoHS is 0.01%.

42. Have you encountered any gaps, contradictions, overlaps or missing links within the Directive?

Yes

No

Don't know

Please explain and indicate which impact this may have on the functioning of the Directive:

500 character(s) maximum

For example, regarding the timing for exemption renewal, the industry has to work on renewal dossiers while the previous procedure is not yet closed.

43. Has the Directive had a notable influence on the development, structure and functioning of legislation concerning the restriction of hazardous substances in electrical and electronic equipment in jurisdictions outside the EU?

Yes

No

Don't know

Please explain and provide examples if relevant:

500 character(s) maximum

There is a lot of RoHS-like legislation in other regions of the world, with varying scopes and maximum concentration values, but clearly inspired by the EU. There are often the same 6 basic restrictions for example in China, Brazil, Japan, Arab states, Korea, Russia, Turkey, Singapore, Ukraine, India and California.

Relevance

The following questions aim to evaluate to what extent the issues or problems addressed by the Directive still exists and whether the objectives of the Directive are adequate to address those issues.

44. To what extent do you agree that there is still a need for EU legislation on hazardous substances in electrical and electronic equipment to achieve the following objectives?

21

STRONGLY

AGREE DISAGREE STRONGLY

DON'

AGREE

DISAGREE

T

KNOW

Protection of human health

Protection of the environment

Ensuring the environmentally sound recovery and disposal of electrical and electronic waste

Ensuring a well- functioning internal market

  1. Does the list of restricted substances (Annex II) require any modifications? Please select all that apply
    No modifications required
    It requires the listing of new substances
    It requires the de-listing of substances
    It requires the change of concentration values
    Don't know
  2. Annexes III and IV of the Directive provide a list of applications exempt from the restriction of Article 4. Is this list up-to-date with the most recent technical and scientific progress?
    Yes
    No
    Don't know
  3. To what extent do you agree that the application and assessment process for the adaptation of Annexes III and IV to scientific and technical progress (Art. 6 of the Directive) is fit for purpose?
    Strongly agree
    Agree
    Disagree
    Strongly disagree
    Don't know

Please describe which aspects of the application and assessment process are not fit for purpose and in what respect

500 character(s) maximum

Insufficient human resources dedicated by the European Commission to tackle exemption requests that were filed by industry on time and with the required documentation on time.

48. To what extent do you agree that the obligations which the Directive lays down for the following actors are still sufficient to ensure the continued achievement of the Directive´s objectives?

22

Strongly

Agree

Disagree

Strongly

Don't

agree

disagree

know

Manufacturers of electrical and electronic equipment

Authorised representatives of manufacturers

Importers of electrical and electronic equipment

Distributors of electrical and electronic equipment

49. Are you aware of any issues related to hazardous substances in electrical and electronic equipment that the RoHS Directive does not address?

500 character(s) maximum

In the waste hierarchy, prevention takes precedence over waste treatment. Therefore, the development of durable products and a long availability of spare parts is an important objective of the circular economy. Substance restrictions limit the availability of high performance materials without which durable products cannot be realized. The "repair as produced principle" to be aimed at for spare parts is particularly important for future Annex II extensions in order to avoid legal loopholes.

EU added value

The following questions aim to compare what has been achieved through the implementation of the Directive with what could have been achieved by Member States acting at national, regional and at international levels alone. Additional questions seek to assess whether the issues addressed by the Directive continue to require action at EU level.

23

50. What consequences do you think would the withdrawal of the RoHS Directive have for achieving the objectives of the Directive?

POSITIVE

NO

NEGATIVE

DON'T

CONSEQUENCES

CONSEQUENCES

CONSEQUENCES

KNOW

Protection of human health

Protection of the environment

Environmentally sound recovery and disposal of electrical and electronic waste

Ensuring a well-functioning internal market

24

51. Are there any activities or tasks currently performed at EU level that should be performed by Member States instead?

500 character(s) maximum

No, product legislation needs to be harmonised at EU level to secure the functioning of the internal market and free circulation of goods in the EU.

52. In your opinion, who should be responsible for ensuring the safety of hazardous substances contained in electrical and electronic equipment in the EU?

Authorities of the European Union

National authorities

Manufacturers themselves

Don't know

Other

If other, please specify

It is difficult to interpret the question.

If "enforcement" is meant, the response is "national authorities" (Member States).

If "compliance" is meant, the response is "manufacturers themselves".

Any actor in the supply chain, including recyclers, have a role to play, too.

53. To what extent do you agree with the following statements concerning the EU added value of RoHS

Do not

Do not

Agree

know

agree

RoHS creates a large market for the same electrical and electronic equipment.

RoHS creates market for the same electrical and electronic equipment outside the EEA.

RoHS simplifies the trade of electrical and electronic equipment in the

EU.

RoHS supports innovation and use of hazardous-free products.

Additional comments

If you have any further comments, please add them in the box below:

1000 character(s) maximum

If you wish to share any evidence reports, studies or position papers, please upload them here.

Please note that the uploaded document(s) will be published alongside your response to the questionnaire,

25

which is the essential input to this online public consultation. The document is an optional complement and serves as additional background reading to better understand your position.

Please upload your file

The maximum file size is 1 MB

Only files of the type pdf,txt,doc,docx,odt,rtf are allowed

277508e6-ce06-46ce-8cb4-120a421bf664/ORGALIM_PP_RoHS_EVALUATION_2019_12_06_final.pdf

Contact

ENV-ROHS@ec.europa.eu

26

Disclaimer

Orgalim – Europe’s Technology Industries published this content on 06 December 2019 and is solely responsible for the information contained therein. Distributed by Public, unedited and unaltered, on 06 December 2019 17:15:02 UTC

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