‘Odd’ definition creates RoHS Directive loophole

A potential European Restriction of Hazardous Substances (RoHS) Directive loophole may be the unintended consequence of consultation over the End of Life Vehicles (ELV) Directive.

“One source is Okopol’s ELV [recommendations],” said Knut Sander, recycling specialist at European environmental consultancy Okopol.

Changes to RoHS are likely to limit lead (Pb) to 0.1 per cent mass in “homogeneous materials”, and go on to oddly define a homogeneous material as something which cannot be “mechanically disjointed”.


In extreme interpretations, say some industry watchers, this definition allows 0.1 per cent of lead and mercury by weight, several grammes, in an entire computer, provided the computer cannot be pulled apart by hand.


RoHS limits are largely a copy of ELV limits – which in their final form did not include the odd definition.

According to Sander, old vehicles are shredded in giant machines and this was what Okopol meant by mechanically disjointing. The low mass of resultant shreds would put tight limits on banned substances.

If mechanical disjointing is what someone can achieve with a knife, could a TV be mechanically disjointed? If it could not, said Sander, “you can skip the whole directive”.


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