|
Am
I a stakeholder
regarding the mercury ban for UV
lamps? | |
|
You
are directly
affected if you
- use
UV lamps (as
part of your machines, processes or
procedures), regardless of
the frequency of
use
- trade
with UV
lamps
- develop
or manufacture
products, machines, procedures or
processes that require one or
more UV lamps to
function
- develop
and / or
manufacture UV lamps.
You
are indirectly
affected if the success of
your activities depends on the continued
availability of UV
lamps on the
market. | | |
|
Take
advantage of the
public consultation opportunity
by voting in favor of the continuation
of exemption 4(f) as
a stakeholder on behalf of your
company.
Please send your
statements with
contact details to rohs@biois.eu.
-> see sample
answers attached
The
deadline
for submitting your
contribution is May
27th,
2021.
In case some
parts of the statement
(not the entire wording)
should be defined as confidential, you could
send a document in
an editable (word) format and
clearly state the parts that are
confidential and
should not be made available. Please don’t state
your entire
contribution as “confidential” because
in that case it will not be
taken into account
for the
evaluation. | | |
|
Why
should I
participate? Isn't it enough for others
to speak
out? | |
|
Every
vote counts! It
can be assumed that the
European Commission dramatically underestimates
the scope of the Hg
ban in the numerous areas of
application. Thousands of companies and
workplaces are
directly affected by the effects of a mercury
ban on UV lamps. The more
interested parties speak
up and vote for an extension of the exemption,
the better the
chances that the European Commission
will recognize the need for UV
lamps for industrial
use and approve further
extensions. | | |
|
How
can I state my
opinion? | |
|
You
can either respond
specifically to the questions
raised in the public consultation or, if
you are not very
familiar with the subject, make a general
comment. In both cases,
please take into account
the advice given in the attached VDMA
document.
Please send
your statements with
contact details to rohs@biois.eu. ->
see sample answers
attached
In case some
parts of the statement (not the entire
wording) should be
defined as confidential, you could send
a document in an editable
(word) format and
clearly state the parts that are confidential and
should not be made
available. Please don’t state
your entire contribution as
“confidential” because
in that case it will not be
taken into account for the
evaluation.
| | |
|
I
am not based in the
EU. Does the regulation still
affect
me? | |
|
Yes.
Due to the
international economic
interdependencies, a mercury ban in the EU also
has a direct impact
on non-EU countries. A ban on
UV lamps in the EU also makes it
impossible to import
/ export UV lamps and the associated
machines. | | |
|
What
are the arguments
against banning the use of UV
lamps in
industry? | |
|
1.
There is no turning
back! Once the exceptions to
the Hg ban have expired without further
extensions, there is no
provision for later
reconsideration. Therefore, the extension of the
exemption must not be
suspended under any
circumstances.
2.
Despite decades of
research, there is no
mercury-free technology or light source that
replaces the useful
properties of mercury-based UV
lamps with 100% compatibility. Discharge
lamps with
alternative fillings and / or forms of
excitation have disadvantages
for many existing
applications (higher cost, short service life of
lamps and / or
components, non-matching spectrum).
For some applications, there are
promising
alternatives (e.g., based on UV LEDs), which,
however, require that the
chemistry on which the
UV polymerization is based on is modified. A
compatible replacement
of UV lamps with UV LEDs is
not possible, or only possible to a limited
extent in many
existing applications. In addition, there
is usually a high investment
requirement for
alternative technologies.
3.
The amount of Hg put
into circulation worldwide by
all UV lamps for special applications is
very low. In the
case of medium-pressure lamps for UV
polymerization, for example, it is
only a few 100 kg.
There are other areas in which
comparatively huge amounts of Hg
are used, and which
ultimately end up in the environment (e.g.,
mercury emissions from
coal-fired power plants:
several 100 tons per annum). These emissions
of Hg are expressly
tolerated by politicians and
regulated poorly or not at all.
4.
The quantities of
mercury contained in UV lamps
are small and cannot penetrate to the
outside of
a lamp. By disposing of these lamps through
suitable disposal
companies, Hg is recycled and
can be reused. A closed cycle without any
environmental
pollution is thus possible.
5. Only
the EU is pursuing
the political goal of banning
mercury with categorical severity. Other
economies like the
U.S., China/Asia or Russia will clearly
have economic and technological
advantages over
their European competitors once a mercury ban is
fully passed in the
EU. | | |
