歐盟第二次RoHS相關利益者諮詢意見報告
Last spring, the European Commission set the review topics for the RoHS Directive and began a consultation process to encourage stakeholders to provide their opinions. The results of the consultation will serve as the basis for amending the RoHS Directive. The second consultation committee meeting began in December 2007 and ended at the end of February 2008. This consultation received a total of 62 responses, including 14 from private companies, 26 from industry organizations in the electrical and electronic equipment industry (mainly from the United States and Japan, and developing countries), 8 from material manufacturers and associations, 2 from non-governmental organizations (NGOs), and 6 from EU member states and other countries.
This review primarily discussed whether to include medical devices and monitoring and control instruments within the scope of the RoHS Directive, and whether it was necessary to expand the scope of restricted/prohibited substances in the RoHS Directive. The consultation results showed that almost all stakeholders agreed on including medical devices and monitoring and control instruments under the RoHS Directive. Most industry stakeholders indicated that they did not believe it was necessary to add other substances restricted in electrical and electronic equipment (EEE), as the EU's new REACH chemical regulation already regulates environmentally harmful substances in EEE. In contrast, non-governmental organizations (NGOs) expressed support for expanding the scope of restricted substances in the RoHS Directive, and submitted a list of substances that should be prioritized for regulation, along with sufficient supporting evidence. Those stakeholders who believed that the scope of restricted substances should be expanded indicated that if there was sufficient evidence to support the addition of regulated substances, the expansion could be combined with exemption clauses; this approach would be more acceptable to the industry.
Because some opinions suggested that the RoHS Directive could be included under the REACH Regulation, all EU member states participating in the consultation unanimously stated that the REACH Regulation is still not entirely appropriate for the control of hazardous substances in electrical and electronic equipment (e.g., the control range is too high, the registration deadline is too long, and there are different treatments for imported finished products). Therefore, they were unwilling to include the RoHS Directive under the REACH Regulation.
Regarding the definition of the RoHS directive, some have suggested that "fixed equipment" and "large industrial tools" should be described with examples in the appendix to reduce concerns about certain products falling into a gray area. Many stakeholders (especially in certain industries) insist that the term "putting on the market" needs a more precise definition.
Regarding enforcement, all stakeholders agreed to include provisions to strengthen market surveillance mechanisms, administrative cooperation, and compliance testing when reviewing the RoHS Directive. As for compliance assessment procedures, the industry unanimously opposed declaring compliance through third-party certification, preferring instead to demonstrate product compliance through due diligence and the use of other standards.
The opinions gathered in this consultation will serve as one of the bases for the Executive Committee's subsequent review of the RoHS Directive, and the Executive Committee is currently working on drafting a revised version of the RoHS Directive and its impact assessment.
The attached document is a summary report of the opinions gathered during this consultation. Additionally, you can refer to the opinion letters from various interest groups at the following website.http://circa.europa.eu/Public/irc/env/rohs_2008_review/home
– Reference source: EU WEEE website, 2008-04-22
– Translated by Plastic Industry Technology Development Center
For reference only, please refer to the original text.
Other related files can be downloaded:
RoHS 2nd_consultation_comments.pdf
