Comments on Öko-Institut consultation for a review of the RoHS 2 Directive scope provisions – 2nd area of review: EEE newly in scope

Orgalime thanks the Öko-Institut for the stakeholder consultation to provide further input to the European Commission impact assessment on the scope of the RoHS2 Directive as requested by Article 24(1). However, at an earlier stage a similar study has already been carried out by Bio Intelligence Service on behalf of DG Environment1. We call for taking this earlier study into account in this follow up work. 

As a European association representing the European manufacturers of mechanical, electrical, electronic and metal articles as a whole, Orgalime will focus its comments on the impacts of the suggested scenarios to solve the current side-effects of Articles 2(2), 4(3) and 4(4), as listed under section six of the questionnaire, rather than on sections three, four and five, which, in our view, target individual companies [more in download]