EU Commission Releases Second Draft of RoHS Methodology – IPC Raises Significant Concerns

On May 7, 2013, the Austrian Environmental Agency, consultants to the European Union (EU) Commission, released the Draft Manual: Methodology for Identification and Assessment of Substances for Inclusion in the List of Restricted Substances (Annex II) under the RoHS2 Directive (draft manual). IPC’s initial review of the draft manual raised significant concerns regarding how substances will be evaluated for restriction under the RoHS2 Directive. IPC will submit comments on the draft manual by the June 4, 2013 deadline. Companies are encouraged to submit individual comments.

As a result of IPC and other industry lobbying efforts, the RoHS2 Directive published in the European Union Official Journal on June 8, 2011, did not include any additional substance restrictions in Annex II. However, RoHS2 called for the EU Commission to review additional substances for restriction. The Commission is required to complete its review of Annex II by July 2014.

In January 2013, the Commission launched a stakeholder consultation on the review of Annex II and stated that it supports developing a scientific methodology to identify and assess substances for inclusion in Annex II. In parallel with the development of the methodology, nominations will be accepted from stakeholders on what substances to consider. The Commission also stated that they support alignment with the REACH Regulation. IPC submitted comments on the first stakeholder consultation that emphasized the importance of developing the methodology prior to accepting nominations for substances to consider.

IPC is concerned that the latest draft of the methodology does not require full evaluation of alternative substances.  Substances should not be restricted unless alternatives that are better for human health and the environment are identified. IPC is also concerned by the draft manual’s focus on evaluating the substance’s environmental and human health impacts during end of life. Evaluation of a substance for restriction under the RoHS2 Directive should be a more comprehensive, life-cycle evaluation. IPC will remain engaged in the stakeholder consultation process.

For more information on IPC’s efforts, please visit IPC’s website.

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