Ref. Ares(2014)76401 - 15/01/2014 Workshop
29 June 2007
Preliminary results of the
“Study on Directives 2002/95/EC on the Restriction of the Use of Certain Hazardous Substances (RoHS)”
that research teams from ECOLAS and RPA are commissioned to conduct
by the European Commission, DG Enterprise & Industry
- PROGRAMME -
09.30 Welcome by Mr. Dino Pinelli, EC DG Enterprise & Industry
09.40 Presentation of the preliminary results of the study Sarah Bogaert, ECOLAS Ltd.
10.10 Discussion of preliminary results
Coffee Break
11.00 Presentation of data gaps Sarah Bogaert, ECOLAS Ltd.
11.20 Discussion of data gaps
12.00 Lunch
13.30 Presentation of preliminary options for revision of the RoHS Directive Mike Van Acoleyen, ECOLAS Ltd.
14.00 Discussion
16.00 Closing
Review of Directive 2002/95/EC Stakeholder Workshop 3 July 2007
List of Participants Signature Member States Morning Afternoon Maya de Grott Belgium [email protected] Elina Velinova Bulgaria [email protected] Demetris Demetriou Cyprus [email protected] Malle Pirsoo Estonia [email protected] Tiia Salamaki Finland [email protected] Thierry Rimbon France [email protected] Christiane Schnepel Germany [email protected] Jozsef Kelemen Hungary [email protected] Darren Byrne Ireland [email protected] Federico Foschini/Andrea Lanz Italy [email protected], [email protected] Mindaugas Stonkus Lithuania [email protected] Theo Klomberg Netherlands [email protected] Mariusz Biedrzycki Poland [email protected] Lucian Ursea Romania [email protected] Anna Dobrócsyová Slovakia [email protected] Alojz Grabner Slovenia [email protected] Marc Jay United Kingdom [email protected]
Trade Associations Korrina Hegarty CECED [email protected] Claire Schonbach EICTA [email protected] Christie Jarita ELCFED [email protected] Sue Bell AeA [email protected] Sigrid Linher Orgalime [email protected] Gunnar Ahlbom COCIR [email protected]; [email protected] Jacques Cipriano ASD [email protected] Meglena Mihova EPPA Test & Measurement Coalition [email protected] Cristina Marongiu UEAPME [email protected] Nicolle Darcy AmCham [email protected] Phil Hope CEFIC [email protected] Yoij Harikura JEITA [email protected] Ferdinand Quella ZVEI [email protected]
Companies Malte Becker Electrolux [email protected] Salla Ahonen Nokia [email protected] Sara Rodriguez Martinez HP [email protected] Pascale Moreau Epson Pascale_Moreau@epson-europe.com Julian Lageard INTEL [email protected] Lars Bruckner NEC [email protected] Kay Nimmo Tintechnology [email protected] Chris Robertson Era Technology [email protected] Marek Kubel Ambex [email protected]
NGOs Nadia Haiama Greenpeace [email protected] Lisette van Vliet HEAL/HCWH [email protected]
Consultant Sarah Bogaert Ecolas [email protected] Mike Van Acoleyen Ecolas [email protected] Rocio Salado RPA [email protected]
European Commission Anna Passera European Commission [email protected] Michail Georgios Papadoyannakis European Commission [email protected] Dino Pinelli European Commission [email protected] Cost-Benefit analysis of RoHS Directive in: A Study on RoHS and WEEE Directives EC – DG Enterprise & Industry
3 July 2007 Sarah Bogaert – ARCADIS ECOLAS Agenda
Presentation of the team
Goals of the study
Scope of the study
Approach
Preliminary results
2 Presentation of the team – ARCADIS ECOLAS (RoHS) Belgian based Part of Arcadis Belgium (Arcadis group) Some EC experience: DG Enterprise: Framework Service Contract for the procurement of services on Commission Impact Assessments and Evaluations – Lot 5: Impact Assessment on Environmental Economics (2006-2010) DG Environment: Service contract for the evaluation of the environmental component of infrastructure investment projects (2000 - 2007) DG Regio: Strategic Evaluation on Environment and Risk Prevention Under Structural & Cohesion Funds for the period 2007 – 2013 (2006) DG Environment: Study on the implementation of Packaging Directive and options to strengthen prevention and re-use (2005)
3 Presentation of the team – RPA (WEEE)
UK based Some EC experience: DG Enterprise: Framework contract for Impact Assessments on Environmental Economics and Industrial Products & Services Sectors (2006-7) DG SANCO: Establishing a Comparative Inventory of Approaches and Methods Used by Enforcement Authorities for the Assessment of the Safety of Consumer Products Covered by Directive 2001/95/EC on General Product Safety and Identification of Best Practices (2006) DG Enterprise: Cost Benefit Analysis on the Draft Amendment of the EC Directive on Electromagnetic Compatibility (2002) DG Environment: Employment Effects of Waste Management Policies (2001)
4 Goals of the study
RoHS part:
Analysis of economic and environmental impacts of the RoHS Directive:
Cost-Benefit Analysis
Impact on internal market
Impact on innovation
Impact on products and sectors not covered by ban
Potential synergies and conflicts with other EU legislation (REACH, EuP) and other policy objectives (e.g. identifying cases where the RoHS has increased/reduced world trade integration)
Comparison of EU approach with other approaches
Recommendations for revision to improve cost-effectiveness
5 Goals of the study
WEEE part:
Assessment of impacts on innovation and competition
Identification of factors and requirements with a critical positive or negative impact
Comparison of EU approach with other approaches
Recommendations for revision to improve cost- effectiveness
6 Scope of the study
Focus on product groups Criteria: Presence and quantity of hazardous substances Economic importance Environmental impact Innovation pace of the sector/innovative potential Data availability Selection of product groups: Refrigerators PC & laptop, incl. spare parts Printers & copiers Cellphones Television sets Clocks & watches Fluorescent lamps (straight and compact) Lawn mowers & gardening equipment Video games & handheld video games Dispensers for hot and cold beverages 7 Scope of the study
RoHS: initially less stringent focus on product groups because Companies may have a range of RoHS relevant products - costs may be difficult to differentiate Any cost information contributes to revealing the whole picture WEEE: focus on countries Belgium Germany Ireland Lithuania UK
8 Approach - CBA Aim of Cost-Benefit Analysis:
General quantified information on all product groups
Quantification of B/C per product group
Qualitative description of inefficiencies
Approach:
Literature review
Stakeholder consultation – written questionnaires
Target groups: Member States Trade associations Individual companies Environmental organisations
Sent out 20 & 25 April – deadline 25... May
9 Identification and quantification of benefits
Methodology:
(1) Quantity of substances in product per product group
(2) Product volumes brought on the market per product group
(1)*(2) = estimated total presence of hazardous substances
Quantification of environmental impact based on life- cycle assessment and dose-response relationships
Monetization of environmental and health impact based on benefit transfer
10 Identification and quantification of benefits
Generalisation of the quantity of the hazardous substances in the selected products Based mostly on the available information in literature and expert judgment An estimation of the quantities: in the components of the selected products if possible, for the total of the product Differences in quantities caused by different literature sources, reference years, products, etc. Preliminary overview for refrigerator and PC/laptop in the next slides – watches/clocks and fluorescent lamps looked at, other product groups to be completed
11 Generalisation of the quantity of the hazardous substances in the selected products
Example: quantities in the components of the product REFRIGERATOR Component of product Substance Quantity of substance in component of product pigment plastic cable sheating Pb 10 - 30 g/kg plastic material stabiliser PVC sheating Pb 20 g/kg plastic material Lead bronze (copper alloy) bearing and bushes Pb 7.4 g/product (1) solders in refrigirator Cd < 0.025 % of solder plating of e.g. electrical contact Cd < 0.01 % of component Cd pigment in plastics of electrical contacts Cd < 0.05 % of component (2) cooling system and electrical contact Cr(VI) ? temperature switch Hg 1 - 5 g/switch switch Deca-BDE 10 - 15 % of component cable (wire) Deca-BDE 10 - 15 % of component (1) assumed that all units contain one bearing (2) general maximum for large EEE units
12 Generalisation of the quantity of the hazardous substances in the selected products
Example: quantities for the total of the product PC / LAPTOP Component of product Substance Quantity of substance in component of product total Pb 63 g/kg product total Cd 0.094 g/kg product total Cr(VI) 0.063 g/kg product total Hg 0.022 g/kg product total flame retardants (1) ? (1) Flame retardants = Polybrominated biphenyls (PBB) and polybrominated diphenyl ethers (PBDEs)
Assumptions:
Average total weight PC ca. 30 kg Average total weight Laptop ca. 2.5 kg
13 Dose-response relationships
General (eco)toxicological information on substances available Life cycle assessment (LCA) functional units: Environmental burden (expressed in environmental load units) on: 6+ natural resources: Hg > Cd >>> Pb > Cr ; 6+ air emissions: Pb > Hg >> Cd > Cr ; Human toxicity potential (expressed in 1,4-dichlorobenzene (1,4-DCB) eq.): is different for the different environmental compartments and mostly only slightly different for the different time horizons there is no hazardous substance that has always the highest HTP for the different environmental compartments it seems that Pb has never the highest HTP Ecotoxicity potential (expressed in 1,4-DCB equivalent): for the different environmental compartments + types of ecotoxicity (water, sediment and terrestrial): Hg has always the highest ecotoxicity potential Pb has always the lowest ecotoxicity potential
14 Dose-response relationships
Potential effects of the presence of the hazardous substances in the different phases (production, users, end-of-life) of the life cycle - preliminary results based on emission factors to water, air, waste
PHASE / component / product Emission factor aquatic (after WWT) air waste
min max min max min max Cd-production (mg/kg Cd) 0 42241 2.1 4598 n.a. CdO-production (mg/kg Cd) 0 0.24 n.a. production of Cd-Stabilisers (mg/kg Cd) 0 n.a. 0 n.a. n.a. production of Cd-pigments (mg/kg Cd) 3 203 3 29 n.a. production of Cd-plating (mg/kg Cd) >0 0 n.a. production of Cd-alloys (mg/kg Cd) n.a. >0 n.a. Fluorescent lamps: total Pb-emission during production n.a. 0.07 0.2 30 100 + use + waste management (mg/10+6 Lh) Fluorescent lamps: total Hg-emission during production < 0.00001 0.04 0.6 1900 2100 + use + waste management (mg/10+6 Lh) n.a.: not available (yet); Lh: lumen hour
15 Dose-response relationships - Example
Fluorescent lamps: emission during production + use + waste management (mg/10+6 Lh) Emission factor aquatic (after WWT) air waste min max min max min max Pb n.a. 0.07 0.2 30 100 Hg < 0.00001 0.04 0.6 1900 2100 e.g. for Pb (air, max) = emission factor (in mg/10+6 Lh) * number of Lh per fluor.lamp = (0.2 mg/10+6 Lh) * (10,000*1000/10+6 Lh) = 2 mg/fluor.lamp
1 fluorescent lamp: 10,000 hours rated life (average estimation) 1000 lumen (average estimation) 10,000,000 Lh (= Lumen-hour)
Emission (mg/fluorescent lamp) Aquatic air waste during production, use and waste environment management Pb n.a. n.a. 1 2 300 1000
Hg 0.0001 0.4 6 19000 21000
16 Identification of costs
Literature review
Overwhelming number of references available... but not on impact quantification
More or less useful:
Full RIA UK (May 2006)
Belgian Federal Public Service Health, Food Chain Safety and Environment (Nov 2005)
ERA Technology – Investigation of exemptions
GreenRose: SME’s
17 Identification of costs
National authorities - Compliance costs
Activities:
Communication
Monitoring and review
Exemption procedure
Enforcement
Quantification of
Resource costs
Time/staffing requirements
18 Identification of costs
Companies - Compliance costs
Activities:
Training or information measures
Collecting and reviewing information
Exemption procedures
(Temporary) monetary losses/gains of e.g. ÈÇ turnover, discontinuation of non-compliant products, delayed introduction of products
Quantification of
Resource costs
Time/staffing requirements
19 Identification of costs
Companies - Technical costs of phase-out of RoHS substance:
Capital expenditure
Operating expenditure
R&D expenditure
Ability to pass on costs to customers
Companies - Trade impact: change in sales volumes
20 Identification of costs
Social costs/benefits:
Gain/loss of jobs
Implementation of new health and safety measures in companies
Impact on consumer e.g. pricing out of lower income groups
21 Quantification of costs/benefits
Stakeholder consultation – National authorities
Quantified response by 4 MS
Reliable quantitative information is difficult because budgets are often not yet attributed
Monitoring and review costs:
XRF analysers for testing (30,000 to 45,000 € each)
Gas Chromatography Mass Spectrometer analysis (20,000 €)
Studies to prepare RoHS implementation e.g. development of inspection methodology
22 Quantification of costs/benefits
Stakeholder consultation – National authorities
Dedication of staff time
Activities: Communication: Placing information on the internet Dealing with scope issues and public queries Training of inspectors Investigations not resulting in prosecution Participation in TAC meetings Participation in EU-wide RoHS enforcement network Etc.
Total of 30-100% of FTE
23 Quantification of costs/benefits
Stakeholder consultation – Companies Profile of respondents
Response of 19 companies (of which 5 non-quantitative)
All large companies
Activities: IT and Telecommunications equipment (12) Monitoring & control instruments (6) Large household appliences: refrigerators and air conditioning (5) Medical devices (4) Consumer equipment: audio/video/tv (2) Electrical and electronic tools (1) Small household appliences: watches (1)
24 Quantification of costs/benefits
Stakeholder consultation – Companies
Resource costs
Figures from 14 companies expressed in € and/or FTE
Very broad range of figures
Technical costs of phase-out of RoHS substances
Mainly lead (6 companies)
Not considerable for other substances?
Only one company gave a figure for CrVI
25 Quantification of costs/benefits
Stakeholder consultation – Companies
Technical costs of phase-out of lead
Capital expenditures: Large ranges in costs of replacement or modification/refurbishing of machinery
Operating expenditure:
Increased direct material costs (5) from 7,500 to 62,500 €/tonne of Pb phased out
0- 10% increase in energy costs
26 Quantification of costs/benefits
Stakeholder consultation – Companies R&D expenditure Personnel, materials, depreciation costs Adaptation of existing design often requires more resources than new design Extreme cases between: Companies with relatively high absolute R&D costs, but low share in total R&D Companies with relatively low R&D costs, but high share in total R&D Ability to pass on costs to consumers depends on market competitiveness, product lifetime, activity (assembler/component supplier), etc.
27 Quantification of costs/benefits
Stakeholder consultation – Companies
Extrapolation per product group is necessary e.g. different length of product life
Impossible to extrapolate:
Low response
Lack of representativeness per product group
Lack of representativeness in company size
Lack of economic indicators e.g. turnover
Often difficult interpretation e.g.
Cumulation of resource costs/staff time
Cost of XRF analysers up to 15 million €
28 Quantification of costs/benefits
Stakeholder consultation – Companies Social costs and benefits: Gain/Loss of jobs: Job loss (0) 0 jobs gained (6) 2 jobs gained (5) 10 jobs gained (3) 30 jobs gained (1) 50 jobs gained (1) Consultancy contracts (2) Mix of permanent/temporary Increased focus to general Material & Substance requirements (1)
29 Impact on the Internal Market
Legal basis of RoHS: Art. 95 of EU Treaty (measures for the approximation of the provisions laid down by law, regulation or administrative action in Member States which have as their object the establishment and functioning of the internal market)
Whether and to what extent are differences in implementation hindering the functioning of the Internal Market?
E.g. scope, monitoring, enforcement procedures
30 Selection of inefficiencies reported by TA/companies
Need to involve the whole supply-chain:
Collection of compliance proof e.g. material declarations
Education and training e.g. of non-European suppliers Testing compliance of products, parts, components Stock management – market segmentation issues:
Markets with and without RoHS legislation
Products included and exempted from RoHS legislation
Compliant and non-compliant products Length and transparancy of exemption process Unequal implementation and transposition in MS Scope-related issues e.g. discrepancy in individual Member State enforcement
31 Impact on innovation
Whether and to what extent has the RoHS ban an impact on innovation: Impossibility of using banned substances: prolongs the time-to-market (thereby increasing the costs of innovation) e.g. checks and reporting along supply chain retains companies from exploring new research avenues (substitution + innovation in other field) Innovative products may be discriminated against mature products performing a similar function that have already been granted an exemption Granting of exemptions may hinder innovation as industry is not encouraged to further explore alternatives Innovation pushes towards cleaner electric and electronic products provided by the RoHS ban
32 Impact on innovation
Preliminary information:
Customer relationships – role of advisors as well as suppliers
Branding – opportunity to market green credentials
Compliance linked strategies – RoHS and others guide future R&D and design strategies
Standardisation – setup of common reporting format, standard definitions, set method for testing
Technical challenges – time derogation is unlikely to have a significant impact on innovation
33 Other impacts
Impacts on markets for raw materials/ components/inputs to production: Price changes Availability or shortages of inputs Quality problems of input Market fragmentation resulting from RoHS exemptions RoHS synergies or conflicts with other EU legislation (REACH, EuP) and other policy objectives (e.g. identifying cases where the RoHS has increased/reduced world trade integration) Needs to be further elaborated
34 Data gaps in RoHS part EC – DG Enterprise & Industry
3 July 2007 Sarah Bogaert – ARCADIS ECOLAS Goals of the RoHS study
Analysis of economic and environmental impacts of RoHS:
Cost-Benefit Analysis: General quantified information on all product groups Quantification of B/C per product group Qualitative description of inefficiencies
Impact on internal market
Impact on innovation
Impact on products and sectors not covered by ban
Potential synergies and conflicts with other policy objectives Comparison of EU approach with other approaches Recommendations for revision to improve cost-effectiveness
2 Gaps in RoHS due to low response
Lack of representativeness per product group: Refrigerators (1) PC & laptop, incl. spare parts (2) Printers & copiers (4) Cellphones (1) Television sets (1) Clocks & watches (1) Fluorescent lamps (straight and compact) (0) Lawn mowers & gardening equipment (0) Video games & handheld video games (0) Dispensers for hot and cold beverages (0) Lack of representativeness in activities: Mainly assemblers 4 component producers Lack of representativeness in company size – not 1 SME Lack of economic indicators e.g. turnover Often difficult interpretation (can be solved through individual contacts)
3 Reasons for low response?
“It’s no use crying over spilt milk” – I fully comply and do not want to spend any more time
Questionnaire was too detailed
Questionnaire was too large
Questionnaire came at a bad time:
May: many holidays
Consultation fatigue
Confidentiality problems
4 Solutions for low response
Questionnaire was too detailed New call to MS & companies in relevant Questionnaire was too large product groups Confidentiality problems: non-disclosure agreement
5 Gaps in RoHS - Analysis of costs in MS
Estimation of total direct resource costs of RoHS + indicate % share of Communication Monitoring and review Exemption procedure Enforcement Please... Differentiate between: Personnel costs (# FTE’s, x% of FTE) Resource costs Indicate one-time or recurring cost Specify years to which costs refer
6 Gaps in RoHS - Analysis of costs in companies
Estimation of total compliance costs + indicate % share of: Training or information measures Collecting and reviewing information Exemption procedures Qualitative or quantitative information on (temporary) monetary losses/gains of e.g. ÈÇ sales volumes discontinuation of non-compliant products delayed introduction of products Please... Differentiate between: Personnel costs (# FTE’s, x% of FTE) Resource costs Indicate one-time or recurring cost Specify years to which costs refer
7 Gaps in RoHS - Analysis of costs in companies
Technical costs of phase-out of RoHS substance If possible broken down by: Capital expenditure Operating expenditure R&D expenditure Indicate to wich substance cost refers Indicate one-time or recurring cost Specify years to which costs refer Additional staff time dedicated to RoHS not yet included: # FTE’s, x% of FTE (specify activities) General information: product groups, activity, size, turnover
8 Gaps in RoHS – Sector profile
What information is available:
Eurostat – PRODCOM – NACE DL 30 to 33 Manufacture of electrical and optical equipment
# companies per MS distributed by size
Not all MS participate every year
No complete coverage e.g. medical devices not in RoHS study, video games/lawn mowers not in PRODCOM
Eurostat – Engineering industry – NACE DL 29.1-5, 29.71, 31:
Economic indicators per MS e.g. # companies, production, value added, R&D intensity
9 Gaps in RoHS – Sector profile
Economic indicators needed per product group:
# companies in EU27 by size
Economic profile:
Turnover
Value added
R&D expenditure
Etc.
10 Analysis of environmental benefits
Methodology:
(1) Quantity of substances in product per product group
(2) Product volumes brought on the market per product group
(1)*(2) = estimated total presence of hazardous substances
Quantification of environmental impact based on life- cycle assessment and dose-response relationships
Monetization of environmental and health impact based on benefit transfer
11 Gaps in RoHS - Analysis of env. benefits
Historic evolution of quantities of Pb, Hg, Cd, Cr, flame retardants (PBB, PBDE) per product/kg for each product group
Emission factors per phase in the life cycle, per product, per environmental compartment
LCA functional units on PBB, PBDE
12 Gaps in WEEE – Stakeholder consultation
Individual Companies – Only 10 responses. Need: Cellphones, clocks and watches, lamps, lawn- mowers, dispensers SMEs Examples of innovations made and associated costs R&D costs associated with design for recycling + opportunity costs Effects on volume of sales?
National Authorities – Only 3 responses. Need: Lithuania, Ireland Indications of competition effects at national level Current estimates of free-riders
13 Gaps in WEEE – Stakeholder consultation
Trade Associations – 6 responses
Majority of company members are large firms – SMEs representation?
Examples of difficulties experienced by companies registering in more than one MS
Producer Responsibility Schemes – 3 responses Consumer Organisation – 1 response Recycling company – 1 response
14 All information welcome by end of July
RoHS: ARCADIS Ecolas Ltd. Sarah Bogaert Fonteinstraat, 1A B-3000 Leuven, Belgium http://www.arcadisecolas.com [email protected] WEEE: Risk & Policy Analysts Ltd. Dave Fleet & Rocio Salado Farthing Green House 1 Beccles Road, Loddon, Norfolk NR14 6LT, United Kingdom http://www.rpaltd.co.uk [email protected] and [email protected]
15 Preliminary topics for revision of the RoHS directive
3 July 2007 Mike Van Acoleyen – ARCADIS ECOLAS Key issues for administrative simplification
Availability of data
Testing RoHS-compliance
Stock management and segmentation
Interaction with suppliers
Training
Exemptions and exemption process
Unequal implementation and transposition in Member States
Other issues
2 Preliminary topics for revision of the RoHS Directive
Topic 1a: distributing the administrative burden across the suppliers
Topic 1b: enforcement / market surveillance
Topic 2: streamlining the exemption process
Topic 3: clarifying definitions
Further topics to be investigated?
3 Topic 1a: distributing the administrative burden across the suppliers
Issue
Producers = assemblers
Maximum concentration thresholds in homogeneous materials
4 Topic 1a: distributing the administrative burden across the suppliers
Possible scenarios to be considered
Business as usual ; no changes?
Ask the producer of the homogeneous materials to prove RoHS-compliance?
Alternative definition of homogeneous material?
5 Topic 1a: distributing the administrative burden across the suppliers
Discussion elements
Business as usual? Burden as usual Division of burden as usual
Ask the producer of the homogeneous materials to prove RoHS-compliance? Burden distributed Possibilities for certification systems Structured enforcement/market surveillance
6 Topic 1b: enforcement and market surveillance
Issue
Existing difficulties in enforcement and market surveillance
Connected with topic 1a (burden distribution)
Elements that may be investigated : component – certificate - agency
7 Topic 1b: enforcement and market surveillance
Possible scenarios to be considered
Business as usual ; no changes?
Certification through a “RoHS-agency”?
Certification through New Approach “notified body”?
8 Topic 1b: enforcement and market surveillance
Discussion elements
Business as usual? Enforcement problems
RoHS agency? Independent agency giving certificates Independent information provider Centralised
“notified body”, new approach? Market responsibility Decentralised
9 Topic 1b: enforcement and market surveillance
New Approach and Global Approach
New Approach = product regulation
Global Approach = conformity assessment
limit public intervention to what is essential
leave business and industry the greatest possible choice on how to meet their public obligations
10 Topic 1b: enforcement and market surveillance
Discussion elements of both solutions
Easy to check ; for enforcement and for supply chain management?
Information distribution?
Need for fixed scientific standards?
Change in art. 4 point 1 ‘put on the market’?
11 Topic 2: streamlining the exemption process
Issue article banning substance plus annex listing exemptions 7 amendments in 3 year, via comitology TAC items in annex basic 27/01/03 12 (8 + 4 on lead solder) + 4 comitology amendment 1 18/08/05 on maximum values amendment 2 13/10/05 +2 new amendment 3 21/10/05 +5 new +3 expansions amendment 4 21/04/06 +5 new amendment 5, 6, 7 12/10/06 +7 +1 +1 new
12 Topic 2: streamlining the exemption process
Possible scenarios to be considered Business as usual : banning + exemptions? Improve the current process: amended criteria … see REACH-compromise? Restricted banning in annex? Change the process (like 94/62/EC packaging)? Criteria in the body Examples in the annex
13 Topic 2: streamlining the exemption process
Discussion elements
Business as usual versus restricted banning : everything that is not allowed is forbidden? everything that is not forbidden is allowed?
to respect the current level of environmental protection: long list of additional bans? vague and comprehensive entries needed, covering unknown or new applications?
14 Topic 2: streamlining the exemption process
Discussion elements Criteria + annex with examples? Clear procedure for annex Flexibility Not overruling TAC or EP Positive and negative examples Annex gives more clarification Criteria : REACH compromise CMRs possible? Introduce economic considerations, exemptions are allowed … When “adequately controlled” / beneath threshold Substitution plan R&D plan
15 Topic 3: clarifying definitions
Issue clear definitions enhance transparent legislation lacking definitions in RoHS Directive Definitions to be found? “putting on the market”? “substitution”? “equipment that is part of other equipment”? “homogeneous materials”? “spare parts”? other?
16 Topic 3: clarifying definitions
Discussion elements
Use definitions from New Approach?
New Approach definition of “placing of the market” and “putting into service” excludes transfer for assembling
17 Further topics
To be further examined:
Experiences outside Europe
Further evaluation of the relation with WEEE
Today’s results
18