Feedback to the Public Consultation on draft RoHS Exemption for the use of PVC recycling material with cd and/or pb in windows and doors with electrical functions
EuroWindoor appreciates the opportunity to give feedback to the draft Delegated Directive amending RoHS Directive 2011/65/EU as regards an exemption for cadmium and lead in plastic profiles in electrical and electronic windows and doors containing recovered rigid polyvinyl chloride (U-PVC).
EuroWindoor highly supports the Delegated Directive as it aligns the requirements of RoHS with the Commission Regulation (EU) 2023/923 amending Annex XVII to REACH to comply with the circular economy targets. This is also supported by EuroWindoor in order to harmonize the overlap between different European legislations as long as complete construction products are included in the scope of RoHS. But there is an important difference in the draft delegated Act regarding the period of validity compared to the REACH derogation. While the expiry date in REACH is set to 28 May 2033 the derogation in RoHS will end on 28 May 2028.