AmCham | Gaps and overlaps between RoHS and REACH: Going beyond the common understanding paper


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POSITION 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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