RoHS Directive: EGMF input to the evaluation study

RoHS Directive: EGMF input to the evaluation study

RoHS Directive: EGMF input to the evaluation study

 

In the context of the ongoing evaluation of the RoHS Directive, EGMF has submitted its views to the European Commission consultation.

The RoHS directive is an important pieces of legislation for our sector. While several types of garden machinery have already been impacted for many years, a substantial amount of combustion engine powered equipment with an electric function must now comply with the RoHS requirements since July 2019.

Through the 50 questions of the consultation, EGMF expressed some key messages on the functioning and implementation of the RoHS directive.

First, we believes that the RoHS directive has been effective. This piece of EU legislation contributed to reduce the use of hazardous substances and had a positive impact on the environment and human health. It also contributed to the free circulation of goods on the single market.

As regards its negative aspects, the RoHS Directive has increased costs for manufacturers due to the substitution of certain substances, the request for exemptions, and supply chain information. This negatively impacted the European competitiveness; however, to a limited extend.

Although the RoHS directive is generally efficient, we have negatively pointed out the lengthy and inefficient process to renew exemptions, resulting in uncertainties for manufacturers. We also underlined certain gaps and overlaps with the REACH Regulation, ELV and Batteries directives, and exhaust emission Regulation, which are hampering the overall coherence of the EU legislation.