**2.2 RoHS & REACH**

The EU's RoHS Directive was the first directive to restrict the use of specific hazardous substances in EEE for many types of products, including most consumer products, and is often seen as a supplement to the WEEE Directive, first instuted in 2004 [22]. The directive has later been updated to provide clarity [23], and to add new substances to the list of restrictions [24]. More additions are currently being considered, such as brominated flame retardants, chlorinated flame retardants, and PVC. Other countries have since followed with similar regulations. Sometimes, as is the case with the China RoHS, the regulation does not prohibit the listed hazardous substances but require products to be marked for having none or minimal amounts of certain hazardous substances. Furthermore, because of the size of the EU's market, products offered globally are often compliant with the EU's RoHS regulation, even if offered outside of the EU. Products exported from the EU also have to comply with RoHS regulation.

The EU's REACH regulation also limits to use of hazardous substances but extends beyond the EEE sector, covering 209 different substances [25]. While similar to the RoHS directive, its implementation differs a lot. Besides covering all products imported or produced in the EU and not just EEE products, being a regulation instead of a directive means the law is the same across every member state. Furthermore, while the RoHS directive specifically lists the substances to which it pertains, the REACH regulation refers to an external list that is easier to update, the substance of very high concern list maintained by the European Chemicals Agency. When listed, authorization is required to include said substance in a product on the EU market, customers and consumers also have the right to request a safety data sheet and to be provided information regarding the safe use and disposal of the product.

#### **2.3 Battery Directive**

The EU's Battery Directive affects both batteries and accumulators, which are seen as separate from EEE in regulations but are often included in EEE. It limits the use of specific chemicals, requires proper waste management pertaining to the recycling and collection of batteries and accumulators, sets collection targets for batteries and assigns financial responsibility. As of this moment the annual collection target for batteries is 45% of annual battery sales.

In December 2020 the European Commission proposed a new batteries regulation to replace the old Battery Directive and would come into effect in 2025 if accepted [26]. The proposed regulation aims to make batteries and accumulators used more sustainable. The repurposing of used batteries is heavily encouraged, a new collection target of 65-70% is proposed for portable batteries, a new reporting system for electric vehicle and industrial with a new collection target (yet to be set) would come into effect, lead-acid and li-ion batteries would get a new recycling efficiency target as well as new material recovery rates for cobalt, nickel, lithium, copper, and lead, a carbon footprint declaration is to be provided, minimal performance and durability requirements are set, non-rechargeable batteries are to be phased out, clear EPR specifications are to be developed, more obligations on removability are given for the product design phase, an electronic information

exchange system and product passport scheme must be implemented, and a mandatory supply chain due diligence must come into effect. As of now, EU member states are still debating the approval of the proposed regulation<sup>1</sup> .
