The RoHS Directive has been under review since 2005. ERA has provided input to all three recent consultations - on options for improvement, revision and addition of substances to the existing six. The Öko Institut has published a candidate list of 46 plus brominated flame retardants.

ERA carried out the first study under the present review for the European Commission on categories 8 (medical) and 9 (monitoring and control equipment) and has since actively engaged in the process.

Options for improvement
A stakeholder consultation closed in February 2008. ERA provided input on the potential restriction of innovation, improvement of the exemption process, harmonising enforcement, the need for unambiguous and uniform interpretation of scope across the EU, and the need to base restrictions on risk not hazard.

Options for simplification
A second study has considered the impact of RoHS and looked at options for revision and simplification of the Directive. In ERA's view many of the estimates of the quantities of restricted substances eliminated from the EU as a result of RoHS were incorrect.

Additional restricted substances and stakeholder workshop
A third study by the Öko Institut is considering whether more substances can be restricted by RoHS beyond the existing six. Öko has issued an inventory of hazardous substances used in electrical products for comment. The candidate list comprises 46 substances plus brominated flame retardants. It includes the flame retardant TBBPA and beryllium - a constituent of high performance thermal conductors and springs.

Öko is asking for submissions from stakeholders to enable them to make recommendations to the European Commission. Additional substances could be restricted if:

Some of the substances on the Öko list are already restricted by Directive 76/796/EEC, which will be replaced by REACH. Others will be difficult or impossible to replace for technical reasons; at least one (TBBPA) is not regarded by the EU as posing a risk and there are some where there is very little data on the impact on health and the environment from potential alternatives. A few are used mostly in applications other than electrical equipment and so, if restrictions are necessary, restrictions by REACH might be more effective.

ERA has submitted comments on the list and has been invited to a stakeholder workshop to discuss these issues on the 6 May 2008. This workshop will be one of industry’s last opportunities to influence Öko’s recommendations. ERA would be pleased to hear your views on these issues prior to the workshop.