Restriction of the use of certain hazardous substances in electrical and electronic equipment

04-04-2017

The IA defines in a clear way the problems and the objectives of the proposed initiative, and is based on extensive research conducted by external contractors. However, it omits to explain the sequential process and the underlying assumptions leading to the identification of the four problems analysed, mentioning only the supporting studies. Also, it contains some discrepancies with respect to the supporting studies in terms of terminology and recommendations which are not explained in the IA. A broad range of stakeholders provided valuable data and information that were used in the IA, even though only 40 (out of 300) provided comments and suggestions. The IA seems to make a reasonable case for the preferred options, which are reflected in the legislative proposal, intending to amend four articles of RoHS 2. However, one of these amendments has been proposed without a clear explanation being provided in the IA. The analysis of competitiveness of SMEs appears to be, in general, insufficiently developed or explained.

The IA defines in a clear way the problems and the objectives of the proposed initiative, and is based on extensive research conducted by external contractors. However, it omits to explain the sequential process and the underlying assumptions leading to the identification of the four problems analysed, mentioning only the supporting studies. Also, it contains some discrepancies with respect to the supporting studies in terms of terminology and recommendations which are not explained in the IA. A broad range of stakeholders provided valuable data and information that were used in the IA, even though only 40 (out of 300) provided comments and suggestions. The IA seems to make a reasonable case for the preferred options, which are reflected in the legislative proposal, intending to amend four articles of RoHS 2. However, one of these amendments has been proposed without a clear explanation being provided in the IA. The analysis of competitiveness of SMEs appears to be, in general, insufficiently developed or explained.