New RoHS Recast Proposal Targets Scope

Several EU Member States Draft Proposal for RoHS Recast

In early September, the Swedish Presidency circulated initial draft compromise texts for the RoHS recast from several EU Member States. The proposal recommends that the scope of RoHS be expanded to cover all electrical and electronic equipment unless it is explicitly exempted. According to the proposal, any product that relies on electricity to function could be included in the scope of RoHS. Therefore, Annexes I and II, which currently contain a detailed list of covered products, would be deleted. The proposal also suggests changing how a substance is ultimately banned under RoHS by basing it on the process set out in Articles 69 to 72 of REACH and comitology. Comitology is a committee of EU Member State representatives which provide guidance to the EU Parliament on proposals put forward by the EU Commission. Some consultants have speculated that comitology may allow for EU Member States to make requests for certain substances to be examined for restriction under the RoHS Directive if they are considered to pose a hazard. The proposal also recommends deleting Annex III that lists substances for priority assessment, which can lead to future restrictions. For more information,

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