JBCE contributed the Impact Assessment to Call for Evidence in RoHS General Review

14/03/2022

JBCE contributed the Impact Assessment to Call for Evidence in RoHS General Review.  

JBCE has supported the RoHS Directive. Major changes – such as repealing the RoHS Directive or incorporation into other legislation - are not desired. JBCE would like to suggest the following points in order to make the RoHS
Directive more efficient and effective.

1, Exemption

Firstly, the exemption period for some items should be longer.

Secondly, our experience has shown that 18 months of transition period is short to replace with the
entire supply chain after the expiration of the exemptions.

Thirdly, the wordings of exemptions should be simple and understandable so that the RoHS Directive
can be complied throughout the supply chain.

2,　Spare Parts

Current provisions of the RoHS Directive Article 4 make the repairment of legacy equipment possible.
Through this, a huge amount of EEE waste is saved.

3,Substance restriction assessment: “One substance, one assessment” principle

Regarding to the assessment of restriction substances, a better alignment of RoHS Directive with
REACH Regulation would be good.

4,Consistency with related EU legislations

Double regulation should be avoided. To ensure the best possible inter-relationship among different
chemical legislations and to avoid contradictions, we welcome documents such as “REACH AND
DIRECTIVE 2011/65/EU (ROHS) A COMMON UNDERSTANDING” by European Commission published
in 2014. Such a document reduces administrative burdens and increase the efficiency.

For more information please contact 

Tetsusaburo Miura, Policy Manager(Environment& Enegry)

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