Directive 2011/65/EU (“RoHS2”): Impact Assessment of Article 2.2

Published:
15 June, 2012
Policies and Issues:
Restriction of Hazardous Substances (RoHS)

Following the last BioIS stakeholder meeting on the RoHS2 scope impact assessment study, Orgalime appreciates the opportunity to provide additional input to the current discussion on impacts of article 2.2 RoHS2 and the notion of “making available” in particular.

This issue is relevant for any equipment newly in scope following the recast of the Directive (see Orgalime’s earlier comments): If BioIS maintained its understanding that new equipment could fall either under category 11 or any other category of Annex I of RoHS2, the given scope of the impact assessment on category 11 “only” is too narrow and its results may be misleading and incomplete as all other affected product categories would not be taken into account.

Orgalime Position Paper Article2_2_RoHS2_2012... (213.1 KB)Download
Responsible:
Sigrid Linher
Position:
Director Energy & Environment

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