IPC and SEMI Submit Comments on Draft Methodology for Evaluating Substances under the RoHS Directive

On April 15, IPC and SEMI (Semiconductor Equipment and Materials International) jointly submitted detailed comments to the European Commission on their proposed methodology for evaluating substances under the RoHS Directive.

IPC and SEMI’s comments provide an alternative approach to evaluating substances based on risk, rather than solely on hazard.

Within the comments, IPC and SEMI made the following recommendations:

  • Simplify the process for determining a substance’s hazard.
  • Use a more robust process for evaluating risk to the environment and populations exposed to the recycling equipment or live near a recycling site.
  • Include a new step to evaluate whether the RoHS Directive is the only viable control for a substance. IPC and SEMI question whether the RoHS Directive is appropriate regulation to address all substances in EEE.
  • Include more robust language to clarify the discussion on evaluation of substances, particularly the evaluation of socio-economic impacts.

IPC’s comments presented to the European Commission are part of the overall review process on the RoHS Directive. In March, IPC submitted comments encouraging the Commission to base substance evaluations and subsequent restrictions on sound science.

For more information, contact Stephanie Castorina, IPC manager of environmental programs, at +1 703-522-0225.

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