EuroWindoor proposes for a recast of RoHS that 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). That would lessen the administrative burdens and bring the consistency within the EU regulations.
Windows, doors and facades are normally assembled and installed by professionals and will stay in the building for 40+ years whereas an electrical device itself typically will be replaced 2 to 3 times during this period. This is partly due to shorter expected life time for these components but maybe more importantly due to high innovation rate in development of new and smarter solutions that can be an integrated part of smart buildings. EuroWindoor believes RoHS has for construction products no further added protection of humans and the environment beyond of what is already achieved through the Construction Product Regulation and REACH.
For further information please see:
EuroWindoor Feedback on the call for evidence to review the RoHS Directive (March 2022)
EuroWindoor General Secretariat
60594 Frankfurt / Germany
Phone: +49 (69) 95 50 54 - 36
Fax: +49 (69) 95 50 54 - 11