The objective of the EU RoHS Directive is the protection of human health and the environment and, more specifically, contribute to environmentally sound recovery and disposal of electrical and electronic equipment. ChemSec hopes that theses objectives will be reflected in the outcome of the European parliament Environment Committee vote on Wednesday.

Methodology

A methodology for future substance restrictions focusing on waste considerations, in line with the specific aims of the RoHS Directive, is of great importance in the review of the RoHS Directive. A comprehensive methodology is needed for phasing out hazardous substances in electrical and electronic products and phasing out substances that will transform to hazardous substances if the product is incinerated at insufficiently high temperatures at end of life.

A clear methodology will enable industry to predict potential future restrictions and assess new materials and substances and avoid investing in materials that are later identified as hazardous.

ChemSec supports consolidated package III on methodology for future restrictions (consolidated amendment 3a, 3b and 3c).

Annex III & Annex IV

ChemSec advocates for an inclusion of brominated flame retardant and PVC in Annex IV. Our main argument for this is that both brominated flame retardant and PVC form dioxins, some of the most toxic substances ever made by humans, when incinerated at insufficiently high temperatures. A large part of industry has also already replaced these substances due to their environmental and human health properties. The ChemSec Electronics Without Brominated Flame Retardants and PVC - a Market Overview, shows that more than 500 electrical products on the market today are free from brominated flame retardant and PVC today and that many more products could be free from these substances and plastic in the future.

ChemSec supports:

• Consolidated package VII on additional restrictions (consolidated amendments 7a, 7b, 7c, 7d, 7e, 7f).
Inclusion of brominated and chlorinated flame retardants and CMR-classed* phthalates in Annex IV for RoHS category 3 & 4 (IT and telecommunications equipment & Consumer equipment).

• Consolidated package IV on Annex III (consolidated amendments 4a, 4b, 4c, 4d, 4e).
Inclusion of PVC and medium-chain chlorinated paraffins (MCCP) in Annex III (If Consolidated package VII falls, Consolidated package IV will include brominated and chlorinated flame retardants and CMR-classed* phthalates in Annex III.

*CMR: Carcinogenic, Mutagenic or toxic to Reproduction category 1A or 1B in accordance with regulation (EC No 1272/2008).

ChemSec: RoHS Voting Recommendations