RoHS &WEEE指令分析及解决思路
This study is framed within the context of the Commission’s overall legislative simplification exercise. By 2008 the Commission intends to present specific proposals for the review of Directive 2002/96/EC on waste electrical and electronic equipment (WEEE) and Directive 2002/95/EC on the restriction on the use if certain hazardous substances in electrical and electronic equipment (RoHS). The WEEE and RoHS EU Directives have been identified as presenting potential for simplification in Commission Communication COM(2005) 535 and included in the simplification rolling programme for 2008. In line with article 4 point 3 and article 6 of the RoHS Directive a review of the scope and appropriateness is foreseen and DGEnvironment is taking the lead in the review processes of both Directives. However, the review of the RoHS Directive in accordance with article 6, and the consideration of the inclusion of product categories 8 and 9 from the WEEE Directive in the scope of the RoHS Directive in particular, are not included in this study.Simplification of legislation has been recognised by the Commission as being a necessity for obtaining legislation which is strong and more effective in achieving its goals. Through simplification, legislation will be more transparent, more focused, more cost effective and more accepted by the target groups. Therefore, in every simplification exercise the first question will always be to save and to promote the goals of the original instrument, but it will do this by using the most suitable, the least burdensome and most effective instruments. The economic principle, to achieve the best results with the least effort, is the guiding principle. A good simplification exercise should be neutral against the goals of the policy; it is merely an instrumental exercise. However, the argument of simplification will often be used to achieve shifts in the level of ambition or in the goals of the legislation, and this is a pitfall to be avoided, particularly in discussions with stakeholders. As described in the request for services, this simplification exercise will scrutinise the current legislative approach with a view to replacing or amending it with more efficient, less prescriptive, flexible and proportionate instruments while maintaining the same level of environmental protection. The proposals formulated in this study seek to maintain the environmental objectives at the least cost possible, including static costs such as administrative burden and dynamic costs such as any effects on innovation. The study does not attempt to discuss or to justify the overall need for the RoHS or WEEE Directives and as a result it does not evaluate its objectives, but it rather concentrates on the means of achieving these objectives.
With respect to the overall review of the WEEE Directive, a number of former initiatives and studies are completed and close co-ordination with some of them has been searched, with respect to data collection and consultation with stakeholders due to the number of overlaps and the need to avoid ‘stakeholder fatigue’. For this Directive the former studies aim at investigating the modification of the targets. This current study will help at closing certain gaps by covering the remaining issues. For the RoHS Directive this is a stand-alone assignment and a thorough data collection and assessment exercise is made and can serve as the main basis for the possible adaptations to the Directive to be proposed. Therefore, main focus of the study has been laid on the RoHS Directive with a concentration on technical issues over policy questions.
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