TWG 2016 in Rosslyn, VA

Transcription

1 TWG 2016 in Rosslyn, VA Battery-related environmental regulations in ASIA The Nobel Assembly has decided to award the 2016 Nobel Prize to Yoshinori Ohsumi for his discoveries of mechanisms for autophagy, a fundamental process for degrading and recycling biological cellular components. Y. Miyamoto Battery Association of Japan 1

2 The environmental regulation of the Asian region China RoHS Regulation of mercury(primary battery) Effective Utilization of Resources Act to Prevent Hg Pollution Battery rule RoHS WEEE REACH Regulation on Hg and Cd Collection of the battery Thailand RoHS ( Batteries not in scope) Vietnam WEEE Product Stewardship National Environmental Regulations No.1 of 2008 Malaysia WEEE (Some batteries in scope) 2

3 1. China 3

4 New China RoHS On January 6, the New China RoHS law was published Management Methods for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products Goes into effect 1 July Expanding product scope from electronic information products (EIP) to electrical and electronic products (EEP). It is applied to all EEP that are sold in the People s Republic of China and the product produced after July 1, Ministry of Industry and Information Technology has issued the FAQ on May 6.

5 The definition of EEP The definition of EEP They refer to the devices and accessory products with rated working electrical voltages that do not exceed DC1500V and do not exceed AC1000V and function by means of current or electromagnetic fields and generate, transmit and measure such currents and electromagnetic fields. The scope of the Law includes but not limited to the following equipment types (see Q&A12 in detail). Communication equipment, Radio & TV equipment, Computer and office equipment, Household appliances,

6 New China Restricted Substances Detailed concentration limits are set by GB/T the requirements for concentration limits for certain restricted substances in electronic and electrical products Cadmium (Cd) and its components: 0.01% Mercury and its compounds: 0.1% Lead (Pb) and its compounds: 0.1% Hexavalent chromium (Cr 6+ ) and its compounds: 0.1% Polybrominated biphenyls (PBB):0.1% Polybrominated diphenyl ether (PBDE):0.1% Other hazardous substances specified by the State It shall be noted that above maximum concentration values apply to each homogeneous material rather than a product itself.

7 New China RoHS Marking Marking Requirements for Restricted Use of Hazardous Substances in Electric and Electrical Products SJ/T All EEPs that are sold in the People s Republic of China shall be marked with Logos. Scope Marking Containing hazardous substances Not containing hazardous substances All rechargeable battery The manufacturer and importer shall determine and mark the environmental protection use period (unit in years (a)) of an EEP that contains hazardous substances in reference to SJ/Z

8 New China RoHS Hazardous Substance Marking Manufacturers and importers shall specify the names and contents of hazardous substances in the product instructions and mark them on the parts where they are contained by the format specified in Table 1.

9 No. Are batteries in New China RoHS scope? The places dealing with battery in FAQ are as follows. contents 15 Cells and accumulators are all covered in this Low, except the exceptions as clarified in this document. 44 Separate marks of hazardous substance for special auxiliary products such as cells. 45 For the EEPs having cells that cannot be taken down, only one mark is required, but the table of hazardous substances shall cover all the units of product including cells. Exceptions 1.Equipment for power generation, transmission and distribution 2.EEPs for military use 3.EEPs for use in special or extreme environment 4.EEPs for export solely 5.Temporarily imported EEPs or EEPs inbound maintenance for sale 6.Prototypes used for scientific research, R&D or testing 7.Samples, exhibits and so on used for exhibition not for sale

10 Are batteries in New China RoHS scope? BAJ would like to conclude that All batteries built in EEPs other than some exception should be considered in New China RoHS scope. Battery makers should submit the information of hazardous substances in their products to EEP makers. Regarding to the battery sold stand alone, each company should independently decide to make marking.

11 2. Vietnam 11

12 Vietnam WEEE Prime Minister on prescribing retrieval and disposal of discarded products. Decision No.50/2013 /QD-TTg (Decision 50) Issue date : Department in charge: Prime Minister on prescribing is reconsidered. Department of Policy and Legislation Waste management and Environment Improvement Department (WENID) Decision No.16/2015 /QD-TTg (Decision 16) Issue date : , Effective date : Schedule of battery collection ( ) Manufacturers shall manage collection of waste products sold out to Vietnam's market and establish points or system of points of collection.

13 No. I List of the waste products and schedule All Type of batteries are regulated by low. DESCRIPTION ACCUMULATOR AND BATTERY Accumulators of all types Batteries of all types SCHEDULE OF COLLECTION AND DISPOSAL 01/7/2016 II ELECTRIC AND ELECTRONIC EQUIPMENT 01/7/2016 III DIFFERENT KINDS OF LUBRICANTS 01/7/2016 IV INNER TUBE, TYRE 01/7/2016 V VEHICLE 01/01/2018

14 Method for collection and disposal Waste products shall be collected in the following manners: Manufacturers directly carry out or enter into cooperation with one another to carry out the collection through the point of collection. Manufacturers work with or authorize waste transportation or treatment organizations with appropriate competence. Waste transportation and treatment organizations with appropriate competence directly carry out the collection in accordance with regulations without any of the manufacturer s collaboration or authorization.

15 Position letter to Regulatory agencies BAJ submitted a position letter to Decision 50( ). Its contents are as follows. Specific selection of batteries Being limited to the batteries categorized as hazardous. Expansion of Government s Roles. Setting up of collection point and collection of waste products. Promoting the development of infrastructures for recycling. BAJ s opinion were not reflected in Decision 50 and Decision16.

16 Issues BAJ visited to Vietnam for the purpose of confirming WEEE situations at Nov We discussed the following issues with participants of WENID public comment workshop for Decision 16. Enforcement It is anticipated that WEEE will flow to informal sectors who are not complied with the regulation and pay high purchase prices for WEEE. Fairness If a company would establish the collection points with bearing costs, then the wastes of many manufacturers will be taken to the collection points.

17 A example of collection point The collection complied with Decision No.16/2015 /QD-TTg has begun. BAJ inspected a collection point at a public facility Hanoi. Joint investment of IT manufacturers with the aid of global recycle consulting company Computers, tablets and smart phone are collected The items and quantities are recorded

18 Conclusion The environmental regulation and the recycling system related to batteries have been gradually established in Asian countries. The regulation and system has diversity. The New China RoHS went into effect. The Vietnam WEEE went into effect. BAJ will respond to the movements of environmental regulations of each country in cooperation with local industrial and trade associations, with scientific and economic justification.

19 Thank you for your kind attention. 19

20 Appendix (1) Excerpts of the places dealing with battery are as follows. Q15. For the cells and accumulators for different applications, how to judge whether they are covered in the Methods? A: Except the dedicated cells and accumulators covered in the exceptions to the Methods as clarified in this document, other types of cells and accumulators are all covered in Methods. Exceptions 1.Equipment for power generation, transmission and distribution 2.EEPs for military use 3.EEPs for use in special or extreme environment 4.EEPs for export solely 5.Temporarily imported EEPs or EEPs inbound maintenance for sale 6.Prototypes used for scientific research, R&D or testing 7.Samples, exhibits and so on used for exhibition not for sale

21 Appendix (2) Q44. SJ/T requires in 6.3 that, where choose Fig.2 (Orage Symbol) for marking, enterprises shall replace the number with actual term of environmental use of the product, and give a detailed description of use conditions for achieving the term of environmental use and special marks for auxiliary products. Please further explain the use condition and special marks for auxiliary products. A:(The explanation for used condition is omitted.) Special marks for auxiliary products refer to use of separate marks of hazardous substance concentration restricted by manufacturers or importer for special auxiliary products such as printer consumables and cells.

22 Appendix (3) Q45. Now many EEPs having cells that cannot be taken down, so only one mark is required in such cases? A: For the EEPs having cells that cannot be taken down, only one mark indicating restricted use of hazardous substances is required, but the table of concentration of hazardous substances shall cover all the units of product including cells. BAJ would like to conclude that Battery makers should submit the information of hazardous substances in their products to EEP makers. All butteries built in EEPs other than exception should be considered in New China RoHS scope. Regarding to the battery sold stand alone, each company should independently decide to make marking.