WEEE developments
From ORGALIME; The current discussions on the directives’ scopes in Parliament and Council which risk leading to include product groups that have not been in the spotlight before.
The Orgalime WEEE/RoHS task force already stressed the high possibility of extension to mechanical products, and identified possible targets such as industrial tools, boilers, heaters, pumps, motors, solar or photovoltaic equipment, material handling equipment, electric trucks or cars. These are only examples, and are not cited in any official documents, but could well be targeted.
An inclusion in the scope would mean implement
– WEEE and the waste take back obligations, including targets and financing obligations and
– RoHS bans of a) the existing 6 substances and b) any possible new substances to be added for restriction
Orgalime arguments against an open scope so far are the following:
– There is no representative EU impact assessment providing comprehensive and complete information on the expected impacts of the proposed change. In the absence of such impact assessment, sufficient, Orgalime addressing the shortcomings of the existing scope provisions instead of introducing new provisions which may further complicate the matter
– An open scope would create more uncertainties.
– For WEEE, a legal base of article 175 applies. This would allow member states to ignore exemptions accepted at EU level in their own member state.
– For RoHS, an unknown amount of new exemptions could become necessary, questioning the existing RoHS exemptions mechanism to follow (existing exemptions mechanism is lengthy and complex and often not providing the necessary legal certainty for companies in time).
Orgalime is also encouraging its members and concerned sectors to contact your MEPs and national governments and highlight the uncertainties related to such a proposal.
In the meantime, you might start consider which of your sector’s products could fall under WEEE/RoHS, knowing that the fixed installation criterion is at stake, and as well as the current exclusion of large scale industry tools, and you might want to think of arguments to possibly exclude them.
First published on 10/11/2009
