the european chemical industry council (cefic) has posted a position paper on the proposed regulation for the restriction of hazardous substances (rohs) in electronic and electrical equipment – which is currently under debated within the eu institutions.
the document outlines seven requests which aim to achieve a consistent, workable and proportionate legislation, but foremost, the association says that any recast of the existing rohs directive should be consistent with the reach regulation. such a consistency implies that the criteria, requirements and procedures for the restriction of substances under rohs and reach are aligned.
1. restrictions and exemptions of substances only according to reach (art. 6a and annex
iv);
2. exemptions of substances only according to reach (art. 5);
3. deletion of annex iii;
4. no duplication of procedures when assessing substances;
5. no extension of the scope;
6. no immediate and unjustified inclusion of substances to annex iv;
7. the new rohs directive must take the upcoming reach review into consideration.
