EU consultants propose RoHS exemption for reused spare parts
11 November 2014 / Europe, Electrical & electronics Consultants have recommended that reused spare parts in medical devices, in vitro diagnostics, electron microscopes and certain instruments in monitoring and control appliances should be exempt from the substance bans, set out in the EU Directive on the restriction of hazardous substances (RoHS) in electrical and electronic equipment (EEE). The Öko-Institut, contracted by the European Commission to provide assistance on technological, socio-economic and cost benefit assessment, related to exemptions under RoHS, says such parts, which contain substances listed as banned under the Directive, could still be used if: reuse takes place in “auditable closed-loop business-to-business return systems”;it is notified to consumers; and the spare parts comply with REACH. The recommendation also specifies that it be permitted, only in cases where the device, from which the parts were originally recovered, was compliant with EU legislation, at the time first placed on the market. The parts would be allowed in: medical devices to 22 July 2021; in vitro diagnostic medical devices to 22 July 2023; and electron microscopes and instruments, used as accessories in industrial monitoring and control equipment to 22 July 2024. A microscopes producer had initially requested an exemption for lead and hexavalent chromium in reused spare parts (CW 6 January 2014), but amended this to include all the substances banned under RoHS, due to difficulty in determining the substances' presence, other than by destroying the items. The European Commission is still to take a final decision on the recommendation. Under the RoHS Directive, exemptions are not company specific. Thus, if granted, the exemption would allow the refurbishment of the product categories and groups specified with spare parts still containing the substances banned under RoHS, provided conditions set out in the exemption are respected.