EuroWindoor appreciates the opportunity to give feedback during the call for evidence supporting the review of Directive 2011/65/EU on the restriction of the use of certain hazardous substances in electrical and electronic equipment (RoHS)1. As mentioned in “the call for evidence” there is a range of issues with the practical operation of the Directive and the surrounding systems especially for construction products like windows, doors and facades with electrical devices in category 11 (“Other EEE not covered by any of the categories”).
Electrical devices attached to windows, doors and facades shall be regulated by RoHS, but not the construction product itself which is covered sufficiently by CPR (2011/305/EU) and REACH (2006/1907/EC).
EuroWindoor represent the interest of the European window, door and façade sector and has in this role previously provided input for studies and consultations related to RoHS (2011/65/EU). These products which are normally installed permanently in buildings by professionals have a long life time (40+ years) whereas the electrical device that might be fitted to it will have a much shorter life time (10-15 years). The electrical devices will therefore always be easily replaceable and by that possible to both buy and dispose separately …
EuroWindoor Feedback on the call for evidence to review the RoHS Directive – CZ