DIGITALEUROPE, as the voice of the digital technology industry in Europe, welcomes the opportunity to contribute to the Commission’s consultation on the “analysis of the interface between chemicals, products and waste legislation”.
While we agree to the importance of a smooth transition of recycled materials from waste to new products, we will only comment in detail on the first two complexities mentioned in the stakeholder consultation paper: “insufficient information about substances of concern in products and waste” and “presence of substances of concern in recycled materials and in articles made thereof”.
We would also like to make the following observation: the tensions between chemical-product-waste legislation exist not only for recyclers but also for manufacturers engaged in repair activities. Recent decisions to grant short exemptions for legacy spare parts, for example, are at the expense of product longevity. We support safeguarding the principle of “repair as produced” as outlined in the Restriction of Hazardous Substances (RoHS) for electrical and electronic equipment Directive.