AmCham | Gaps and overlaps between RoHS and REACH: Going beyond the common understanding paper
Introduction - When the European Commission released its ‘REACH and Directive 2011/65/EU (RoHS) a Common
Understanding’ document in July 2014, it publicly acknowledged that there could be overlaps and
inconsistencies between these laws, which both have the ability to ban chemical substances. Already then, some
substances undergoing REACH authorisation were also prioritised for bans under RoHS.
We have since then experienced other forms of these possible overlaps. We have identified examples of the
most harmful cases, along with those that create unnecessary duplication. We have also gained extensive
experience with the REACH Risk Management Option Analysis (RMOA) , have seen the nature of REACH
restrictions evolve, and have been through the process of applying for authorisation. We believe such experience is essential to upcoming legislative discussion on the RoHS directive as well as for
upcoming REACH investigations; we would like to share these observations help inform the important
discussions to come.
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