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Orgalime meeting RoHS recast proposal

Orgalime meeting RoHS recast proposal. Brussels December 3rd, 09. RoHS recast proposal : main milestones. 24/02/2010 : deadline for amendments 06/04/2010 : vote of Environment Commission of European Parliament 18/05/2010 : vote of European Parliament in plenary session

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Orgalime meeting RoHS recast proposal

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  1. Orgalime meetingRoHS recast proposal Brussels December 3rd, 09

  2. RoHS recast proposal : main milestones • 24/02/2010 : deadline for amendments • 06/04/2010 : vote of Environment Commission of European Parliament • 18/05/2010 : vote of European Parliament in plenary session WEEE recast proposal should have the same dates, however, RoHS planning will not be delayed if WEEE status is late according to these dates.

  3. Convergence REACH - RoHS • The battle is lost! Otmar Frey • Most of the members states seem against • European Commission, Sweden Presidency, Envi Committee of EU parliament are against • May be not the war! • Arguments are not very sharp • Many people consider discussion just starting and not closed.

  4. Extension of the scope 1/2 • Category 11 called « catch-all » is legally a non-sense (Otmar Frey, WEEE/RoHS Orgalime Task Force Chairman) • Do we have to take into account all EEE for aircraft for example? • Where is the limit for electrical generator between engine (not EEE) and generator? Same question for electrical pump? • “One size does not fit all” what about the small series? • RoHS conversion of small series can be economically a non-sense, the cost of the technical modification can overtake 1 or more years of turn over. • The over cost can push small companies to stop their activity. • Other risk is numerous requests of product derogation sent to EU commission bringing administrative overload.

  5. Extension of the scope 2/2 • Orgalime proposition • To create 2 new categories : • 11a for industrial EEE with cut off date of July 2017 • 11b for general public EEE with cut off date of July 2014 This lead-time of 7 years should let enough time for the renewal of the small series EEE in most of the cases. • In order to reinforce our position, to communicate more widely on our industrial products • Most of the people don’t have any idea on what are industrial EEE. • Proposition to make a digest of our offer in France for instance (Schneider + ?)

  6. Accessories and consumables • “Consumable” means any unit used with the EEE where the EEE can not function as intended without the consumable. • They are for example tapes, CDs, DVDs, toner cartridges or lamps • “Accessory” means any unit used with the EEE that can not function without the EEE. • Orgalime position : It is a deviation of the Directive that shall apply to EEE. • Tapes, CDs, DVDs, toner cartridges are not EEE. • Whether accessories & consumables are EEE and therefore IN the scope or they are not and they do not have to be RoHS compliant.

  7. New substances • New list: • Orgalime position: • Behind some particular cases as PVC for example, we do not accept the methodology used to add new substances. • As it is at stake for the producers, we need to get a clear and consistent methodology to make a decision to add new substances (as for REACH). • For example, we can not accept in Miss Jill Evans’s proposal“Proposals for specific provisions on nanomaterials will be added in January 2010 following further evaluation of the situation” according to which criteria? By who? Etc… • PVC is still a big concern for extrusion activity. • Some small companies could stop their production. The ban of PVC could oblige to complete renewal of production lines, overtaking financial capacity of those companies.

  8. Compliance conformity • Producers have the charge to prove the compliance. • According to NLF 768/2008/EC, and based on “tests and measurements” article 16 • Orgalime position (under discussion, to be finalized) Producers need to work according to worldwide acceptable standards. • To refer to new IEC standard 62 476 “Guidance for evaluation of product with respect to substance use restrictions in electrical and electronic products”. • Based article 16 Presumption of conformity on “assessments and measurements”.

  9. TF WEEE Orgalime action plan • 4 works group to be set up • Methodology for introduction of new substances and exemptions • Creation of 2 new categories 11a and 11b • Accessories and consumables • Compliance conformity • Publish position paper before final adoption by Envi Committee of EU parliament according to this schedule • Work groups to Secretary 18 Dec • Secretary to TF Members 24 Dec • TF Members to Secretary 15 Jan • Secretary to TF Members 20 Jan (final draft) • TF Members to Secretary 29 Jan (agreement)

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