On 14 February 2022, the CRM Alliance submitted feedback to the Commission's call for evidence for an impact assessment on the review of Directive 2011/65/EU (RoHS Directive) on the restriction of certain hazardous substances in electrical and electronic equipment (EEE).
The evaluation identifies a range of issues with the practical operation of the Directive and some systemic issues, pointing to the high administrative burden and complexity of provisions and processes in place. The roadmap proposes the following policy options:
Maintaining the status quo (RoHS Directive stays the same)
Simplification of the RoHS Directive in reference to the identified weaknesses.
Transformation of the RoHS Directive into a Regulation
Repeal the RoHS Directive and incorporate its provisions in the REACH Regulation or in the Sustainable Products Initiative and Ecodesign Directive
Among other issues, the CRM Alliance (1) encourages the Commission to assess the impact of its policies on the competitiveness and resilience of the EU’s supply chains, (2) supports a risk-based approach to the restriction of substances and (3) ask the Commission to carry out an initial socio-economic analysis for any regulatory proposal that covers CRMs.
Read our submission below: