On June 10, 2013, IPC submitted its third set of comments on the draft methodology for evaluating substances for restriction under Annex II of the RoHS2 Directive. IPC stressed the importance of evaluating both hazard and exposure characteristics of a substance and potential alternatives prior to restricting a substance. IPC has remained engaged in the development of the methodology for evaluating substances for restriction under the RoHS2 Directive
The stakeholder consultation on the review of substances for restriction under Annex II of the RoHS2 Directive began on January 20, 2013. IPC submitted comments applauding the EU Commission for supporting the use of a scientific methodology and encouraged the Commission to first establish the methodology before asking stakeholders to submit substances they believe are harmful.
However, the first draft methodology released in February 2013, did not reflect the EU Commission’s previously stated goals. On March 11, 2013, IPC submitted comments expressing concern that the draft methodology would not result in the development of a strong, scientifically based methodology for the review of restricted substances under RoHS2, as outlined in Article 6 of the RoHS 2 Directive (2011).
On April 15, 2013, IPC submitted joint technical comments with SEMI (Semiconductor Equipment and Materials International) suggesting the use of an alternative approach to evaluating substances for restriction under the RoHS2 Directive. These comments can be viewed by visiting www.umweltbundesamt.at/rohs2. On April 30, 2013, IPC and SEMI met with the RoHS2 desk officer to discuss those comments.
During the RoHS revisions process, IPC successfully lobbied for the revised Directive to be scientifically based. As a result, the Commission did not implement additional substance restrictions under the revised RoHS Directive. The Commission is required to complete its review of Annex II by July 2014. IPC will remain engaged in the review process. For more information, contact Stephanie Castorina, IPC manager of environmental programs, at +1 703-522-0225.
Filed under: Environment, Health and Safety, IPC, Regulations Tagged: Annex II, EU Commission, RoHS2, scienfically based methodology, substance restrictions
