EGMF comments on the RoHS revision roadmap

Several types of outdoor power equipment are impacted by the Directive 2011/65/EU, the so-called RoHS 2 Directive. Therefore, EGMF submitted on 14 March its comments on the RoHS revision inception impact assessment roadmap. The purpose of this roadmap is to provide an initial non-exhaustive list of possible options identified by the European Commission regarding the review of the RoHS Directive, which is scheduled for Q4 2022.

EGMF paper aims to share our key observations and asks regarding the revision of the RoHS Directive:

  • The Directive has been effective, has prevented the multiplication of legislation restricting use of hazardous substances at national level and possible inconsistencies and has played a positive role at international level.
  • However, the Directive still needs to be improved, especially the lengthy and inefficient process to renew exemptions, resulting in uncertainties for manufacturers.
  • As regards the RoHS revision roadmap, EGMF supports a combination of options 2 and 3, namely ‘Simplify and clarify the RoHS Directive by introducing and revising legislative measures’ and ‘Transform the RoHS Directive into a regulation’. However, we oppose to options 4 and 5 that aim to repeal the RoHS Directive and incorporate its provisions into the REACH Regulation and/or the upcoming Sustainable Products Initiative.

To consult the document click HERE.