The Review of the Directive 2002/95/EC of the European Parliament and of the Council on the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment, Invitation for Comments on Policy Options and for Information Supply The IPC - Association Connecting Electronics Industries Government Relations and Environment, Health and Safety Committees submit the following comments to the European Commission regarding the Restriction of Hazardous Substances (RoHS) Directive Review.

IPC urges the Commission to avoid restricting additional substances, eliminating existing technology exemptions or adding additional electronics equipment to the RoHS scope while industry, governments and the public are still facing a variety of implementation challenges. Any expansion of the RoHS scope, including removal of existing exemptions must be thoroughly reviewed for technical feasibility. Should the Commission deem additional substance bans to be absolutely necessary, a full life cycle assessment of the substance and its substitutes must be conducted in order to ensure that the substitution does not have unintended adverse environmental and human health impacts.

IPC believes that any further substance restrictions beyond RoHS would more appropriately be addressed under the current REACH (Registration, Evaluation and Authorization of Chemicals) Directive to avoid unnecessary confusion and regulatory overlaps. IPC is a global trade association with over 275 member companies located in the European Union. IPC represents all facets of the electronics interconnect industry, including design, printed circuit board manufacturing and electronics assembly. Printed circuit boards and electronic assemblies are vital components of all electronic devices including computers, cell phones, pacemakers, and sophisticated missile defense systems.

Click on this link to read all the comments (IPC.org).