What are the “winning” and “losing” arguments for a RoHS exemption?
A good proportion of industry exemption requests get thrown out. It is therefore critical to understand what makes a good request. You may find the following tips helpful. A. Understand the two criteria that the EU is allowed to take into account, and what makes a bad argument. • Technical feasibility (good argument). Substitution is not possible, or is possible under such conditions as to be unfeasible in practice. There might not be adequate supply, for example. • Environmental impact (good argument). The negative environmental impact of not allowing the exemption would outweigh the positive environmental impact of the ban. This might be because of increased waste resulting from predictably higher failures, or because the substitutes are as toxic as the banned substances, etc. • Cost or cost/benefit (bad argument). The EU legislation does not permit cost to be taken into account in making a decision on exemptions. This does not mean that you cannot refer to the costs; indeed many EU
