Brussels, January 2024 – EuroWindoor is pleased with the harmonisation of requirements according to the RoHS directive with REACH regulation for the use of profiles in electrical and electronic windows and doors containing recovered rigid polyvinyl chloride (PVC). This brings a long process to a positive conclusion which was introduced by an exemption request from EuroWindoor and EPPA in the year 2015.
While REACH applies to all substances, mixtures and articles, RoHS only applies for electrical and electronic products. The aim in restricting the use of certain hazardous materials is to reduce the environmental impact of electronic waste and improve the safety of electronic products. Windows and doors are falling under REACH and additionally RoHS when they have electrical equipment attached or integrated which did cause difficulties in the past because of different requirements.
Supporting circular economy the Commission Delegated Directive (EU) 2024/232 for RoHS (published in January 2024) is aligning the rules of the REACH derogation of Commission Regulation (EU) 2023/923 allowing the use of recovered rigid PVC material when it does not exceed 0,1 % cadmium by weight and 1,5 % lead by weight. So recycled PVC material can also be used in profiles for electrical windows and doors.
Only a small issue remains because of the differing validity periods outlined in the RoHS Delegated Directive compared to the REACH derogation. While the REACH derogation is set to expire in May 2033, RoHS expiry date is set to May 2028. To avoid future conflicts EuroWindoor strongly advocates to ensure that there will be a renewal of the Commission Delegated Directive in 2028 to keep RoHS aligned with REACH. Furthermore EuroWindoor continuous to recommends limiting the scope of RoHS to the electrical device of windows and doors for avoiding double regulation.
For more information see:
- Commission Delegated Directive (EU) 2024/232 here.
- Commission Regulation (EU) 2023/923 here
- EuroWindoor feedback to the Public Consultation on the draft RoHS exemption for PVC in electrical windows and doors here.
EuroWindoor General Secretariat
60594 Frankfurt / Germany
Phone: +49 (69) 95 50 54 – 36
Fax: +49 (69) 95 50 54 – 11