EuroWindoor AISBL agreed on July 1st in Copenhagen on a position regarding impacts from RoHS2 on windows and doors with electric functions.
The directive for ‘Restriction of Hazardous Substances’ in ‘electrical and electronic equipment’ was extended to a new category applicable to the sector from 22 July 2019. A study for the analysis of impacts from RoHS2 confirmed the concern of the sector, but concluded in the recommendation that 4 years are enough for solving the problems. The conclusion is mainly based on the assumption that substances regulated by RoHS anyhow would disappear from the products due to other legislation. But even if a window or door fulfils the requirements of CPR and REACH, it does not necessarily comply with RoHS.
EuroWindoor does not agree to the conclusion. The use of recycling material may exceed the limits. When providing input from big manufacturers for the study difficulties became obvious in gathering sufficient chemical data from even main suppliers. For SME difficulties are expected to be many times higher.
EuroWindoor suggests to exclude the window/door itself and limit the scope to the electrical part only similar to the category “Large Scale Fixed Installations”.
On August 18th, 2015 EuroWindoor presented the position to the European Commission (DG ENV) in Brussels without being able to find the solution now.
EuroWindoor AISBL applied in cooperation with EPPA an exemption to the RoHS II directive for using recycled PVC for windows and doors profiles. Lead and Cadmium in postconsumer PVC-U profiles of windows and doors cannot be mechanically disjointed; therefore, the exemption will not weaken environment and health protection afforded by RoHS. The exemption can be justified by the fact, that PVC is a material well suited to recycling.
Benefits: Recycling PVC-U reduces the amount of energy and natural resources (such as water, petroleum and natural salt) needed to create virgin PVC. Recycling PVC-U-profiles of windows and doors also keeps them out of landfills and allows the PVC to be reused in manufacturing new profiles (Life Cycle and socioeconomic advantages), as intended by the communication COM(2014) 398 “Towards a circular economy: A zero waste programme for Europe”.
The aims of REACH (EC 1907/2006) are to enhance the protection of human health and the environment through the better and earlier identification of the essential characteristics of chemical substances. There are four processes: registration, evaluation, authorisation and restriction of chemicals. REACH as well aims to strengthen innovation and competitiveness of the EU chemicals industry.
In 2015 the European court of justice skipped the previous opinion on Art. 33 from ECHA with a majority of Member States and decided that declaration of single articles (e.g. for a profile) has to be “forwarded” with the article made of articles (e.g. window). The previous interpretation of the REACH declaration is no longer applicable.
EuroWindoor decided in the Directing Council meeting on July 6th, 2016 in Amsterdam to publish an information “REACH – fast facts” which has been elaborated on basis of a proposal from the German member associations VFF and BF. This information will support the manufacturers of windows, doors and facades (curtain walling) and their suppliers to deal with this clarification of the legal situation. Beside a general overview on REACH the focus of the document is on duties and recommendations for downstream users.
Other languages: DE