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RoHS-extended scope on its way

The RoHS (Restriction of Hazardous Substances) Directive (Article 6) requires that the directive is reviewed. The European Commission invited the German based Oko Institute to look at the possibility of adding new restricted substances.


The validity of all the current exemptions is also to be addressed as a separate study that is not part of the RoHS review.


Prior to that ERA Technology, based in Surrey, had won the contract to look at the viability of adding categories 8 (medical equipment) and 9 (monitoring and control instruments) to the scope of the RoHS Directive. RoHS originally covered 8 of the 10 categories of the WEEE (Waste Electrical and Electronic Equipment) Directive and categories 8 and 9 were omitted. This was due to the uncertainties, at that time, around the reliability of lead-free solder. Finally, the EC was looking to provide clarity on some of the grey area definitions such as fixed installations, large scale stationary industrial tools and spare parts.


Following these exhaustive reviews, complimented by invited stakeholder consultations, the European Commission was intending to announce its findings in early September. However, this date has slipped, not least because the stakeholder consultation on the final list of potential restricted substances has only recently finished. We are now looking at November or December.


What is likely, but never certain, is that categories 8 and 9 will be included within scope, supported by a raft of exemptions.. Implementation, if approved, is not expected before 2012.


A list of 46 potential restricted substances has been reduced to 8 plus organohalogens, and some of these could well be included. These may include several flame retardants and plasticisers, which are extensively used in plastics.


Finally, 3 or 4 exemptions could well be removed from the current list of 30 as they are no longer valid or required. These are likely to be very specific ones without widespread impact but several others may be re-worded to make them more application specific.

 

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