Orgalime kindly requests the support of European regulators for the following initial comments on the Commission’s proposal of 3.12.2008 for amending Directive 2002/95/EC on Restrictions of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment (RoHS):

• The RoHS recast proposal claims to simplify existing legislation and to avoid unnecessary bureaucracy and administrative costs in line with Better Regulation principles of the EU. However, the RoHS recast proposal in our view fails to realise this objective, in particular since it overlaps with other legislation and thereby creates legal uncertainty. Therefore, Orgalime’s fundamental request to regulators is to ensure full legal consistency between the RoHS Directive and other legislative initiatives, in particular with the REACH Regulation and New Legislative Framework (NLF) that have been finalised after the adoption of the initial RoHS Directive.