Study on Hazardous Substances in Electrical and Electronic Equipment, not Regulated by the RoHS Directive
Following the requirements of Article 4 (1) of the Directive 2002/95/EC on the restriction of the use of certain hazardous substances in electrical and electronic equipment (RoHS Directive), Member States of the European Union have to ensure that “from 1 July 2006, new electrical and electronic equipment put on the market does not contain lead, mercury, cadmium, hexavalent chromium, PBB or PBDE.” The Annex to the Directive lists a limited number of applications of lead, mercury, cadmium and hexavalent chromium, which are exempted from the requirements of Article 4 (1).
Article 4 (3) mentions that “as soon as scientific evidence is available, and in accordance with the principles on chemicals policy” EU bodies shall decide on the prohibition of other hazardous substances and the substitution thereof by more environment-friendly alternatives which ensure at least the same level of protection for consumers.
Under Article 6, it is provided that the Commission has to review the list of restricted substances in Article 4 (1) on the basis of scientific facts and taking the precautionary principle into account. In particular the Commission has to present proposals for including in the scope of this Directive equipment which falls under categories 8 and 9 set out in Annex IA to Directive 2002/96/EC (WEEE) . It is further mentioned, that particular attention shall be given to impacts on the environment and human health of other hazardous substances and materials used in Electrical and Electronic Equipment (EEE) and that the Commission shall examine feasibility of replacing such substances and materials. It shall then “present proposals to the European Parliament and to the Council in order to extend the scope of Article 4 as appropriate”.
The objective of the present study is thus to provide the necessary support to the Commission services for fulfilling RoHS Article 6 requirements, including investigation on:
- Other hazardous substances or materials used in EEE
- How they are managed currently
- Possible substitutes as well as the sustainability (environmental, economic, social) characteristics of these other hazardous substances and possible substitutes
- Appropriate policy options.
 Categories 8 and 9 set out in Annex IA to Directive 2002/96/EC (WEEE) comprise medical devices (with the exeption of all implanted and infected products) as well as monitoring and control instruments, respectively.