On March 11, 2013, IPC submitted comments to the Austrian Environmental Agency (Austrian UBA) on their proposed methodology for evaluating substances under the RoHS Directive.
While IPC supports the overall goal of developing a formal scientific methodology for identifying and assessing substances for potential restriction under RoHS, IPC raised several concerns, specifically:
- The proposed approach for identifying candidate substances is overly broad and could have unintended consequences
- Substance evaluations and subsequent restrictions must be based on sound science
- The proposed methodology for prioritizing substances must be improved and aligned with the REACH methodology
- The draft methodology for identifying candidate substances should be designed to identify the substances with the highest health and environmental impacts
IPC’s comments presented to the Austrian UBA are part of the overall review process on the RoHS Directive. In February IPC submitted comments to the European Union Commission encouraging the Commission to first establish a scientific methodology for identifying and assessing substances for inclusion in Annex II. As a result of IPC’s lobbying efforts during the RoHS revisions process in 2011, the Commission did not implement additional substance restrictions under the revised RoHS Directive.