RoHS limits the use of specified hazardous substances in the manufacture of certain electrical and electronic products.
The proposed fee would be £39,721 fee per exemption application to allow the supply of products using one the restricted substances above the threshold limits set down in the RoHS Regulations where specified criteria are met. An application is required per exemption application, therefore, one organisation may require a handful of separate exemptions potentially resulting in even larger costs.
On 9 August, BIVDA members were invited to an ad-hoc Environmental working party meeting to discuss how BIVDA should respond to this consultation. The overwhelming opinion is that we would disagree with DEFRA implementing this fee for exemption applications, and that it could result in a lack of products being placed on the market in Great Britain.
A has been produced, and we would request members to review this to ensure we are representing the view of the membership as a whole. Please use to indicate if you agree with this response, and to provide any substantial comments on the documents; minor comments will not be accepted as the response is due on 26 August.
Once the response has been finalised, we will share this with the membership and provide it to MedTech Europe.
As well as this, BIVDA have written to the Office of Life Science, the Department of Health, and ministerial contacts to alert them to the possible repercussions of this fee.
