Environmental Project No. 1316, 2010

Impact assessment of introduction of a general scope of the RoHS Directive – selected aspects

Abstract
In the proposal for the recast of the current RoHS Directive the European Commission has introduced two new annexes describing the scope of the Directive. The first annex describes broad product categories and the second provides binding product lists within each product category.

An alternative definition of scope could be a general scope based on a definition of electric and electronic equipment (EEE).

By introducing a general scope a number of product groups would change status from being outside the scope to being inside. Compared to the binding list of the Commission’s proposal, 77 product groups have been identified that might change status. The products are mainly large and small household appliances, electrical and electronic tools and toys and leisure and sports equipment. For most of the products the market volumes are significant, however the total turnover of the equipment in is only in the range of a few percent of the total turnover of EEE.

Areas not addressed in this study are 1) equipment for the protection of the essential interests of the security of Member States; 2) large-scale stationary industrial tools; 3) transport equipment, 4) aerospace applications; 5) equipment designed for “fixed installations”; and 6) equipment which is not intended to be placed on the market as a single functional or commercial unit.

For eight selected product categories (representing about 50 of the identified product groups) an assessment has been made of the consequences of introduction of a general scope. It has been assessed, at a screening level, whether the costs could be expected to be relatively high or/and the benefits relatively small.

Apart from a few specific applications there is no indication that it should be particularly difficult to replace the RoHS substances in the assessed products.

For veterinary equipment there may be a need for an extended transition period as for medical equipment. Further, photovoltaic cells based on CdTe would need an exemption assessment.

For EE toys without motors and furniture with light, where the EE parts takes up a limited portion of the products the administrative costs of including these products is deemed to be relatively high. A number of similar product groups have been identified, but not assessed further. These include clothing and footwear with EE components, fun and joke equipment and ornaments with EE components, electric toilets and shower heads and mirrors with light.

Abstract in Danish

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