DIGITALEUROPE’s

Initial

Views

on

the

Revision

of

Directive

2011/65/EU

on

the

restriction

of

the

use

of

certain

hazardous

substances

in

electrical

&

electronic

equipment

(RoHS)

The digital technology industry provides the backbone for the sustainable growth of the Union’s economy. Technologies such as artificial intelligence, high-performance computing, telemedicine and teleworking are key to creating a more resilient, green and digital economy and to expediting scientific research to address ongoing and future societal challenges including climate change, health and poverty.

DIGITALEUROPE has been involved since the inception of the RoHS Directive (“EU RoHS”) in the mid-1990s. We have been key contributors and  welcome the opportunity to engage with all stakeholders to review and update the legal framework in the context of the European Green Deal, in particular the circular economy and sustainable chemicals strategies, to the benefit of everyone.

EU RoHS is a blueprint for the Union’s global political and strategic objectives. It has been a worldwide success and continues to set the global bar for electronics, with similar laws having been introduced or being introduced in approximately in 50 jurisdictions outside the EEA. The global success of EU RoHS is evidence of the Union´s ability to drive the sustainable transformation of the economy and society as a global leader on climate and environmental measures. A robust EU legal framework helps to give certainty for the digital technology industry and its complex global supply chain.

EU RoHS builds on many strengths. It levels the playing fields between Union and non-EU actors, it contributes to the circular economy by avoiding waste and has both efficient and well-defined processes, such as the exemptions for example. Moreover, EU RoHS has triggered innovation including the search for viable substitutes.

DIGITALEUROPE´s initial recommendations for the EU RoHS Review include maintaining important principles such as ‘repair-as-produced’, considering longer exemption transition times and dedicating more resources to its processes. When it comes to substance risk and disclosure management of products, DIGITALEUROPE considers that sectorial approaches are the way forward, to assist the waste sector. For electronics, the International Electrotechnical Commission (IEC)’s 62474 Declarable Substances database and the disclosure due to the WEEE directive, as exemplified through the successful cross-industry “Information for Recyclers – I4R” collaborative platform, already provides the necessary information to recyclers.

Finally, as more countries across the world are enacting similar laws, it is an opportunity and responsibility for the Union to reinforce its global environmental leadership by promoting regulatory alignment with EU RoHS globally when mirrored outside the EEA.