RoHS = Mini-REACH?

The RoHS Recast is just about to be finally approved. During the legislative process, industry had favored the alternative to include this substance-related directive within the REACH regulation. The Europeean legislation did not move into this direction.
The draft directive now rather looks like a Mini-REACH. Why?
Looking at the new rules of the RoHS recast and at the alternatively available arrangements of the authorization and restriction processes of REACH, the result is the following comparison:

Same or similar rules in RoHS recast and REACH

1. Personal Scope:  Manufacturers and importers
2. Objective Scope: The Reach Regulation with respect to articles also
    includes all electrical and electronic products
3. Ban of substances: is controlled by authorization or
    restriction under REACH
4. Exemptions (products and restriction of substances):
    can be integrated in the REACH regulation.
5. Criteria for decision for exemptions, new banned substances,
    authorization and restrictions: by far  the same

Different rules in RoHS recast and REACH

1. The RoHS directive has a protective purpose:
    Recycling worker’s health and environmental aspects of handling
    and recycling
2. The ban of substance of the RoHS directive leads to a general,
    product-related ban of sales, even for products from outside the EU.
    REACH regulates only information duties within
    the supply chain (art. 33). Restrictions can also define that products
    containing certain hazardous substances are not allowed
    to be placed on the market.
    For these items only, separate rules would have been necessary
    to be included in the from the RoHS directive.

Do these differences justify a separate directive like RoHS additionally to the REACH regulation?  Rather not! A reduction of the amount of legislation and a harmonization of procedures without changes in the objectives and in the interest of the industries concerned would have been possible.  Too bad…