AXREM Statement on proposed RoHS Charges

18 August 2022

AXREM have serious concerns about proposed new red tape and costs burdens announced in a new government consultation.

DEFRA are in the process of consulting industry about charging fees for exemptions to the Restrictions of the Use of Certain Hazardous Substances (RoHS) in Electrical and Electronic Equipment. These exemptions were managed previously, without a fee, by the EU but following BREXIT have been transferred to DEFRA.

The proposed fee of £39,721 per application disproportionately affects medical devices, which represent 1% of the electrical equipment in scope, but almost 50% of the current exemptions. There are an estimated 95 exemptions required and more may be needed if exemptions are split or additional materials added that require exemptions. These fees disproportionately affect specialised products that are produced in low quantities, such as medical devices (including reagents used in laboratory medical diagnostic equipment).

These charges could lead to a serious risk of equipment and products simply being withdrawn from the market due to the additional costs of this process, which will not only harm the economy, but will also negatively impact health due to unavailability of critical medical devices (including medical laboratory diagnostic tests).

It is also currently not clear if each company requires an exemption or if the exemptions will apply to all companies. Ideally the EU exemptions should be accepted, otherwise no fee should be applied and like the EU an umbrella group formed by manufacturers should collate the required exemptions and provide this to DEFRA. 

ENDS