The recast RoHS directive came into force on 3 January 2013, and requires the European Commission to examine the need to amend the scope of this directive before 22 July 2014 with a view to submitting proposed legislation if this is appropriate.
This review was carried out by BIO Intelligence Services and ERA Technology in 2012 and considered whether any products that had been brought into scope of RoHS by the recast could be excluded where the costs clearly outweighed the benefits.
The approach used for the study was to identify product types with significant sales and to estimate the financial cost of inclusion, the amounts of RoHS substances avoided and a variety of other factors such as whether inclusion simplified compliance.
This study was complicated by uncertainties over scope, in particular the definition of ‘large-scale’ when applied to industrial tools and fixed installations.
The consultants did not try to define scope as this was being done at the time of the study by the Commission who subsequently published the RoHS2 FAQ.
For the purposes of the study however, the worst case scenario had to be considered, i.e. assume that most or all equipment in a category was not excluded.
For the executive summary please see the attachment below.
With thanks to Dr. Paul Goodman of ERA Technology.