Industry bodies representing the digital technology industry have submitted their comments to the European Commission on the proposed list of EEE (electrical and electronic equipment) substances to be controlled under the revised Restriction on Hazardous Substances (RoHS) directive.
Their comments indicate several problems with the proposed list, including the number of substances proposed which are already on the list or controlled by other regulations such as REACH. This is a continued indication of the lack of a joined-up approach to EU regulations of chemicals across the different Directorates-General and sectors. The number of proposed substances not used in the digital technology industry – and therefore not needed to be controlled – was also an issue.
However, one of the more worrying comments in this response concerned the “lack of use or wrong use of CAS numbers concerning several entries makes the review of the inventory difficult. In case of substance groups being proposed for restriction, all relevant CAS numbers should be provided”. The nomenclature of substances is a fundamental underpinning factor in the correct description and subsequent regulation of chemicals and needs to be correct otherwise any regulation based upon it is undermined.
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