Environmental Legislation for Industry Chemicals in Indiateknologiateollisuus.fi/sites/default/files/file_attachments/... · Environmental Legislation for Industry Chemicals in India

Environmental Legislation for

Industry Chemicals in India

Produced by Finpro India for

Teknologiateollisuus ry

FP00006533

May 8, 2012

Dinkar Krishnan, Finpro Chennai

Rekha Salvi, Finpro Chennai

Shriya Ramachandran, Finpro Delhi

Table of Contents

Introduction of the project 3

Executive Summary 4

India REACH 5-17

India RoHS 18-24

India CLP 26-34

Interview Summary 35

Conclusions & Recommendations 37

Appendices

A. Appendix – Primary Research Contacts

B. Appendix – Industry Associations

C. Appendix – Comparison of RoHSs

D. References

39

40

41-49

50

08.05.2012 2 India - Environment Regulation Industry Chemicals Report 2012 ©

Finpro ry

Introduction of the Project

Background Information / Client Objectives

The Working Group for Environmental Issues of the

Federation of Finnish Technology Industries

Tasks include

• directing influence towards the preparation and

implementation of environmental legislation

• acting as a consultative body in developing ways of

exerting influence over environmental issues

• increasing awareness of the use of environmental

aspects in the improvement of competitiveness

• promoting cooperation between companies,

authorities and other environmental stakeholders.

Assignment Objectives / Company benefits

• To provide the companies with focal information of

requirements of environmental legislation on issues

related to products and production in India

• The idea is to find out how India have reacted to

chemical markings in products as defined in REACH,

RoHS, CLP (GHS)

• This study gives an overview where the legal aspects

are and what e.g. Finnish companies should take into

account when planning exports, starting own

manufacturing or outsourcing in India. How the

governmental actions on these issues will affect in

industry and manufacturing

Methodology

• Information collection in internet and databases

• Interviews with governmental officials, industry experts

• The report‟s outcome will be presented in a seminar

organized by Teknologiateollisuus

Project team:

Teknologiateollisuus ry

• Ms. Pirjo Kaivos

• Ms. Mia Nores-Korkeamäki

• Ms. Carina Wiik

Finpro study team members

• Mr. Matti Rasimus, Finpro Finland (Project Owner),

[email protected]

• Eija Tynkkynen, Finpro Beijing, (Project Manager) ,

[email protected]

Finpro India study team:

• Rekha Salvi, Senior Consultant [email protected]

• Shriya Ramachandran, Marketing & Communications

Manager [email protected]

• Dinkar Krishnan, Analyst [email protected]

• www.finpro.fi/finpro-maailmalla/intia


Finpro ry

mailto:[email protected]






http://www.finpro.fi/finpro-maailmalla/intia



Executive Summary

• Regulations and legislations for Chemicals Management in India –

not evolved to the level comparable to the levels of European regulations such REACH

• Overall apathy in the industry towards regulations in Chemicals sector

• REACH – though companies exporting to Europe satisfy the requirements, no domestic regulations so far same as, or

equivalent to REACH

• RoHS – enacted since June, 2011

• CLP – planning regulations in line with GHS (draft regulation – July, 2011)

• The highly fragmented Indian chemicals industry is undergoing restructuring and consolidation phase

• Export of Chemical – through investments in Special Chemical Zones, PCPIR etc

• Planned investment of about USD 33 billion

08.05.2012

Large Foreign and Indian Chemical Companies

Medium Domestic Companies

Very Small and Small Domestic Companies

Highly fragmented industry

• Highly fragmented nature of legislations could lead to legal complications

for Finnish companies

• Indigenous and informal chemical industry is very strong in India, which

drives the market and also to an extent influences the legislation in their

favour

• Efforts by central government to implement and enforce regulations

are expected to find resistance from industry bodies, making the

process slow

• It is advised to closely monitor the regulatory developments in India on

continuous basis, to gain more understanding of how the various regulations

(such as REACH, RoHS etc) are enacted and implemented

4 India - Environment Regulation Industry Chemicals Report 2012 ©

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India REACH

Overview of India REACH

Indian Chemical Sector – A Background

08.05.2012

• It has quite recently adopted WEEE/RoHS regulation (June, 2011) and is in the early stages of development of the

various associated mechanisms

• Compliance to REACH, RoHS and CLP in India is currently exclusively for the EXPORTS market, especially to

Europe

• Companies catering to the domestic market are bound by numerous local legislations that are not as stringent as

REACH

• Hence this report attempts to understand the Indian Chemical industry holistically, and tries to find how the

REACH, RoHS and CLP legislations would relate to the domestic as well as export market in the future

India's response to Chemical regulations so far

• Reluctant participant to most international treaties

• In international forums India argues that „one size fits all policy is not fair‟, and developing countries deserve to be

treated differently

• Sections operate outside global standards in local market

• No centralized body to monitor REACH preparedness

• Many ministries such as Ministries of Chemicals & Fertilizers, Ministry of Commerce and Ministry of

Environment & Forests issues guidelines related to environment, safety and so on


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Overview of Indian Chemical Industry

• The Indian chemicals industry is the twelfth-largest

industry in the world and the third largest in Asia in

terms of volume

• It is currently valued at around US$ 35 billion. India has

a diversified manufacturing base with a capacity to

produce quality chemicals for world consumers

• Government of India (GoI) plans to invest US$ 33

billion in three approved Petroleum, Chemicals and

Petrochemicals Investment Regions (PCPIRs); it also

plans to establish port-based chemical parks in special

economic zones (SEZs)

• Majority of exports – dyes, dyestuffs and alkali

chemicals

08.05.2012

• India has a strong base for innovation in its network of 200

national laboratories and 1,300 R&D units, which can be

leveraged for the shift towards an innovation-based industry

• The chemical industry in India is witnessing increased focus

towards research and development, which in turn provides

opportunities for growth of R&D hubs and industry specific

institutes

• India has emerged as an exporter of dyes, exporting dyes to

Germany, U.K., U.S., Switzerland, Spain, Turkey, Singapore

and Japan

• The export of dyes is expected to increase to US$ 2.6 billion

in 2020

High Medium Low

High Oil Refinery,

Petrochemicals Pesticides

Bulk Drugs, Dyes &

Dye-intermediaries

Medium Fertilisers, Chlor-Alkali

Low Soda Ash Paints, Inks & Printing Inks

Matrix showing India Government’s Sector-specific Priority – Risk and Volume


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Industry Sector Perspective

Key Sectors in India: Chemical Industry

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Textile/Apparel Industry:

•REACH Helpdesk for Apparel Exporters – An initiative

support by GiZ, Small Industries Development Bank of

India – SIDBI and Apparel Export Promotion Council –

AEPC, India)

•Indian Apparel Trade with EU: Consists of 6 sub-sectors

including,

• Knitted and woven outerwear, Bodywear, Sports

clothing, Leather clothing, Fashion accessories

•Total Export from India to EU: USD 81.8 billion (Jan-Dec

2010)

Leather Industry:

•REACH Helpdesk for Leather Exporters – provided by TUV SUD

South Asia Pvt Ltd, on behalf of Council of Leather Exports,

Ministry of Commerce & Industry, Govt of India

•Annual Turnover of USD 7.5 billion, Export – USD 3.84 billion

•EU accounts for 65.48 of India‟s Leather and Leather Products

Exports

Policy Framework:

• Licensing requirements have been removed, except for hazardous chemicals and a few special drugs

• 100% FDI is allowed under the automatic route, for all chemicals except hazardous ones

• Customs and Excise Duties: Peak customs rate of 7.5% on most chemicals, and excise duty of 16% on almost all chemicals

• PCPIR (Petroleum, Chemicals and Petrochemicals Investment Regions) Policy: introduced to boost the development of

chemicals and petrochemicals in investment regions

• USD 33 billion proposed investments

• Includes SEZs, industrial parks, free trade and warehousing zones, export=oriented units or growth centres


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Overview of Regulations in India

Overview of Legal Instruments in India, addressing Chemicals Management

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Production

• MSIHC Rules,

• Petroleum Act & Rules

• Explosives Act & Rules

• SMPV Rules

• Gas Cylinder Rules

• Insecticides Act & Rules

• Customs Act & Rules

• ODS (R&C) Rules

Imports Exports

Storage Transportation

Recycling Use Disposal




• ODS (R&C) Rules

• MSIHC Rules,

• CA (EPPR) Rules,

• PLI Act & Rules


• SMPV Rules


• Factories Act & Rules


• ODS (R&C) Rules


• MSIHC Rules,


• PLI Act & Rules


• SMPV Rules




• ODS (R&C) Rules



• PLI Act & Rules,




• Mines Act & Rules


• Port Act & Rules

• Dock Act & Rules

• PFA Act & Rules

• ODS (R&C) Rules

• ODS (R&C) Rules

• HW (M&H) Rules

• Batteries Rules

• EP Act & Rules

• Air Act & Rules,

• Water Act & Rules,

• HW (M&H) Rules

• Batteries Rules



• ODS (R & C) Rules 9 India - Environment Regulation Industry Chemicals Report 2012 ©

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Overview of Regulations in India

Acts and Rules related to Chemical Industry

08.05.2012

Environmental Management Chemical Safety and Emergency

Management

Specific Chemical

Category/Container

Others relevant to Chemicals

Management

• The Air (Prevention & Control of Pollution)

Act, 1981 amended 1987

• The Air (Prevention & Control of Pollution)

(Union Territories) Rules, 1983

• The Water (Prevention & Control of

Pollution) Act, 1974, amended 1988

• The Environment (Protection) Act, 1986

amended 1991

• Environmental (Protection) Rules, 1986

(amended in 1999, 2001, 2002,

• 2002, 2002, 2003, 2004)

• Hazardous Wastes (Management and

Handling) Rules, 1989 amended

• 2000 and 2003

• EIA Notification, 1994

• Ozone Depleting Substances (Regulation

and Control) Rules, 2000

• Batteries (Management and Handling)

Rules, 2001.

• Manufacture, Storage and Import of

Hazardous Chemicals Rules, 1989

• amended 2000

• Chemical Accidents (Emergency Planning,

Preparedness and Response)

• Rules, 1996

• Public Liability Insurance Act, 1991

amended 1992

• Public Liability Insurance Rules, 1991

amended 1993

• The Petroleum Act, 1934

• The Petroleum Rules, 2002

• The Calcium Carbide Rules, 1987

• The Explosives Act, 1884

• The Explosives Rules, 1983

• The Gas Cylinder Rules, 2004

• The Static and Mobile Pressure Vessels

(Unfired) Rules, 1981

• The Insecticides Act, 1968

• The Insecticides Rules, 1971

• The Essential Commodities Act, 1955

• The Fertiliser (Control) Order, 1985

• Factories Act, 1948

• The Motor Vehicles Act, 1988

• The Central Motor Vehicles Rules, 1989

• The Mines Act 1952

• The Customs Act, 1962

• The Merchant Shipping Act, 1958

amended in 2002 and 2003

• Merchant Shipping (carriage of Cargo)

Rules 1995

• The Indian Ports Act, 1908

• The Dock Workers (Safety, Health and

Welfare) Act, 1986

• The Dock Workers (Safety, Health and

Welfare) Rules, 1990

• Drugs and Cosmetics Act, 1940

• The Prevention of Food Adulteration Act,

1954

• The National Disaster Management Act,

2005

• The Prevention of Food Adulteration

Rules, 1955

• The Prevention of Terrorism Act, 2002


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India REACH Snapshot

• India has not adopted REACH legislation yet, for its domestic market. However, all exporters of chemicals to EU region are required to comply with

REACH and hence, the government supports chemical industry in the compliance requirements of the companies

• Ministry of Commerce supports the REACH-compliance needs of Indian Chemical companies through CHEMEXCIL REACH-Help desk. Chemexcil is

Basic Chemicals, Pharmaceuticals & Cosmetics Export Promotion Council

• Confederation of Indian Industry (CII) along with SSS Europe also provides REACH Support through their Help desk, for Indian companies

08.05.2012

No REACH legislation, or REACH-like legislation in India domestically.

REACH compliance is only for exporters to EU region

• REACH directly applies to the European manufacturer and importer of chemicals and chemical containing products and requires them to demonstrate the

safety of their products put into the European markets by submitting detailed information on the intrinsic and toxicological properties of the products to the

central chemical agency (ECHA)

• Therefore, it is but natural that the EU importer shall ask his Indian supplier to furnish the required information and this is how the Indian exporters get

implicated within REACH

• If the Indian exporters wish to continue uninterrupted trade with the EU, they shall have to collect all the information, as required within REACH for

submitting to the ECHA

• It is important to note that submission of information to ECHA cannot be done by the Indian exporters

• It can either be done by the European importer provided he is willing to act as the registrant or if he refuses to take this responsibility and in certain

cases, if the Indian exporter does not wish to share proprietary information relating to his products, he shall have to appoint an “only representative”

• The “only representative” is the only legal entity authorized to pre-register on behalf of the Indian exporter

Indian REACH – just like other non-EU countries


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08.05.2012

REACH Europe India

Status

• Been in force since June 2007 • Not enacted so far for the domestic market.

Companies exporting to Europe satisfy

REACH requirements through the help

desks established by trade associations

Impact on the Industry

• Substances and articles require registration

if brought into the EU in sufficient volume.

Some requirements in REACH apply also

to articles

• Articles containing Substances of Very

High Concern (SVHCs) more than 0.1

weight-% need to be communicated to the

supply chain (REACH art.33(1)). If an

article contains more than 0,1 weight-% of

the SVHC and if the total amount of the

SVHC in articles is more than 1 tonne a

notification to ECHA is required (Reach

art.7(2))

• Safe use data and other safety data to be

provided pro-actively

• 73 SVHCs identified by April, 2012

• As of April, 2012, 14 substances are

subject to authorisation. The aim of the

authorisation is that the substance would

not be used in Europe anymore

• Large volume of data collection

• Indian chemical companies, mostly small

and medium companies, complain of high

costs involved in the registration, testing

and other such costs for compliance

• Companies are sceptical about the capital

costs of the compliance as well

• Since most of the companies serve the

domestic market, many are not keen on the

compliance

• Many large Indian companies and foreign

companies in India have been willing to

undergo the compliance process

Comparison of REACH in Europe and India


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08.05.2012

Timeline for REACH and CLP Compliance


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India REACH: Similarities and Difference

with EU REACH

08.05.2012

• Background from EU-REACH Perspective

• Out of the 73 SVHC substances, at the moment 14 are subject to Authorisation. The SVHC list is expected to include more

substances in the future as Member states suggest more substances for inclusion

• EU buyers are have started to demand their suppliers to provide proof that the articles do not contain SVHC's. If an article

contains an SVHC then the supplier should provide evidence/certify that all requirements in REACH are fulfilled.

• SSS, who supports the Help desk in India, based upon its assessment process can provide a certificate of “SVHC free” article

and in case article contains SVHC then it can facilitate the compliance process as required with REACH and then issue a

certificate of REACH compliance article, that can be then issued to various buyers

• SSS certified products and chemicals are presently being acknowledged and accepted by over 2000 EU buyers

Approach for Indian Companies for REACH Compliance

SVHC have posed new challenges to article suppliers. Here articles suppliers mean non-EU article exporters, EU importers and

manufacturers of articles.

Under REACH, an article is defined as an object which during production is given a special shape, surface or design, which

determines its function to a greater degree that does its chemical composition. e.g. automobile, garments, tires, plastics

products, electrical products, handicraft, toys, electronics. Thus, the limitation on SVHCs set out in the REACH regulation, has a

broad scope, affecting lots of industries.


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India REACH: Challenges & Outlook

Challenges

• The major impact on Indian exporters of chemical substances so far is the high cost of registration, by way of sharing data

generation costs with the lead registrants, running into millions of Euros

• Exporters of chemical preparations to Europe also have to bear the burden of getting the ingredient substances registered

(again at high cost)

• Regarding the impact of REACH on Indian articles like apparel, leather articles, electrical and electronic components, auto

components, handicrafts, etc, being exported to Europe, there is a grey list of very toxic substances. These SVHCs shall

attract enhanced control and regulation when used for manufacturing of articles like apparel, leather products, auto

components, dyes, paints, electrical and electronic components and products, metal parts and components, plastic products,

etc


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Outlook

• The implications on the export of articles shall be two-fold:

• Manufacturers and exporters of articles shall have to look for alternative safer chemicals; which would amount to

incorporating major changes in their product profile

• The search for safer substitutes that are not readily available will involve a lot of R&D, trials and expense

• These implications are further compounded by the fact that the SVHC list shall keep increasing with time. It is eventually

expected to contain 500 to 600 substances

• In the case of India-REACH, exporters have to appoint an OR (Only Representative) in the destination country to undertake

both the registration formalities as well as legal liability on behalf of the exporter

India REACH: CHEMEXCIL Initiative

08.05.2012

• Through a MoU with SSS, the CII Standards and Conformity Assessment Task Force has decided to launch a nation-wide

capacity building programme across various export sectors (leather, garments, auto components, etc) to strengthen the supply

chain in meeting REACH and other similar regulations

• As a first step, experts from the European Chemical Agency (the nodal organization for REACH) have been invited as key

speakers in two back to back symposiums on REACH Regulations and their impact on Indian industry, in Delhi and Mumbai

• The symposiums, being organized jointly by CII and the Union Ministry of Chemicals and Fertilizers, will be the first face-to-

face interaction of ECHA officials with Indian industry and other stakeholders

• This will be followed by extended outreach programmes targeting impacted sectors over the next year. As deadlines are fast

approaching, the symposiums would provide an ideal forum to obtain clarifications and enhance understanding on coverage

as well as compliance issues


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• CHEMEXCIL, the Chemicals & Cosmetics Export Promotion Council, has set up a REACH help desk and a web portal to

provide the latest updates to exporters. In order to provide professional assistance, CHEMEXCIL has appointed Sustainability

Support Services, (Europe) AB. Sweden, (SSS) to represent its member-exporters in European Union as „Only

Representative‟

• This arrangement has helped over 700 Indian companies go through the pre-registration and registration deadlines

India RoHS

Overview of India RoHS

• RoHS (Restriction of Hazardous Substance) legislation was previously enacted in the European Union, Japan, China, Korea,

and California. WEEE (Waste Electrical and Electronic Equipment) legislation was enacted in the EU, Korea, 25 US states,

and five Canadian provinces

• India has long been plagued by the problem of backyard recycling. India's new legislation is an attempt to address that

problem

08.05.2012

• India is the latest country to enact RoHS and WEEE legislation. Hazardous substance and electronic waste legislation is here

to stay and is expanding worldwide

• India is now on the list, and its new legislation laid by the Ministry of Environment and Forests, Government of India (covering

both RoHS and WEEE requirements) is known as the E-Waste (Management and Handling) Rules, 2011. India's WEEE

requirements will take effect in May 2012, and its RoHS requirements two years later

• (Http://moef.nic.in/downloads/rules-and-regulations/1035e_eng.pdf )

• This treats WEEE and RoHS identically in terms of scope, exclusions etc, and there is a considerable similarity with the EU

WEEE and RoHS legislation, although these are treated as totally separate legislation in the EU. The requirements are

similar to the EU's requirements

• The new waste rule will significantly change the way electronic waste is handled in India. Producers, collection centers,

dismantlers, and recyclers, to remain operating, will have to apply for a government-issued "Grant of Authorization" by July

31, 2012. Onsite storage of electronic waste will be limited to 180 days

• The new RoHS rule will limit the amount of hazardous substances present in electronic products produced and imported in

India ( source CII Reach Help desk and CPCB GUIDELINES FOR ENVIRONMENTALLY SOUND MANAGEMENT OF E-

WASTE Report)


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http://moef.nic.in/downloads/rules-and-regulations/1035e_eng.pdf















India RoHS/WEEE Snapshot

• India RoHS restricts the same six substances at the same maximum concentrations as in the EU but the scope of products is

different as explained below

• There is little information provided in the legislation regarding the process for compliance with India RoHS but the RoHS

requirements enter into force two years after this legislation is enacted, which is in May, 2014

08.05.2012

INDIA WEEE

• The responsibilities of the various entities, producers, consumers, collection centers, dismantlers and recyclers are defined

together with the procedures for obtaining registration and authorisation from the pollution control entities including sample

forms

• Storage of e-waste is permitted only for a period of 180 days, however this can be extended to a year should there be no

recycling facility in that state, or if one is being developed

• Labelling is same to that used in EU, except the black bar under the crossed outwheelie bin is not required

INDIA RoHS

Substances Use

Lead (Pb)> <1000 ppm Electrical and electronics industry in solder, lead-acid batteries, electronic components, cable sheathing and in the

glass of cathode-ray tubes

Mercury (Hg): < 1000 ppm Lamps, sensors, relays and so on

Cadmium (Cd): < 100 ppm electronic equipment, car batteries, and pigments, electroplated coatings, special solders, electric contacts, relays

and switched, PVC stabiliser etc

Hexavalent Chromium (Cr VI) <

1000 ppm

While some forms of chromium are non-toxic, Chromium VI can produce toxic effects. Found in passivation

coatings on metals and in corrosion resistant paints

Polybrominated Biphenyls (PBB):

1000 ppm

These are flame retardants found in electronic and electrical appliances. They have been found in indoor dust and

air through evaporation from plastics

Polybrominated Diphenyl Ethers

(PBDE): < 1000 ppm

These are also flame retardants found in electronic and electrical appliances. Combustion of printed wiring boards

release toxic emissions


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India RoHS: Similarities and Differences

with EU RoHS

India RoHS EU RoHS and EU RoHS II (recast)

Legislation Joint for WEEE and RoHS Separate for WEEE and RoHS

Legislation

Adopted

May 1st, 2012 EU RoHS: February 13th, 2003

EU RoHS II (recast): July 1st, 2011

Legislation

Entered into force

May 1st, 2012 EU RoHS: July 1st, 2006

EU RoHS II (recast): January 2nd, 2013

Legal

Responsibility

Producers

Consumers

Collection Centres

Dismantlers

Recyclers

Producers

Distributors

Business end users

Treatment facilities for WEEE

Exporters of WEEE

Business Size

Affected

Does not apply to Micro & Small Enterprises as defined under the

Micro, Small and Medium Enterprises Act, 2006 (See Table A in

slide no: 23)

All sizes in the categories above

In Scope (i) IT & Telecommunications Equipment

All from EU RoHS Cat 3 ‟IT & Telecoms Equipment‟, except:

Calculators

Printer cartridges

Product for collection, storage, processing presentation or

communicating information electronically

Other equipment for transmitting sound images or other info by

telecommunications

ii. Consumer electrical & electronics

From EU RoHS Cat 1 ‟Large Household Appliances‟

Refrigerators

Washing machines

Air-con (not centralised air-con plant)

From EU RoHS Cat 4 ‟Consumer Equipment‟:

Television sets (all types)

Note: These are inclusive lists, there is no ‟anything else‟ comment.

Current:

1.Large household appliances

2.Small household appliances

3.IT and telecommunications equipment

4.Consumer equipment

5.Lighting equipment, (including electric light bulbs and household

luminaries)

6.Electrical and electronic tools (with the exception of large-scale

stationary industrial tools)

7.Toys, leisure and sports equipment

10. Automatic dispensers

Following the pending recast:

8. Medical devices (with the exception of all implanted and

infected products)

9. Monitoring and control instruments

11. Anything else not covered in categories 1-10


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India RoHS: Similarities and Difference with

EU RoHS (Contd…)

India RoHS EU RoHS

Out of Scope a) Batteries

b) Radio Active Waste

c) Micro & Small Enterprises as defined under the Micro, Small &

Enterprises Development Act, 2006

Currently:

a)Military & National Security

b)Electricity not primary power source

c)Primary function does not need electricity

d)Part of another type of equipment that is out of scope

e)Batteries

Following the pending recast:

a)Military equipment

b)Equipment designed to be sent into space

c)Part of another type of equipment that is out of scope

d)Large-scale stationary industrial tools

e)Large-scale fixed installations

f)Transport

g)Non-road mobile machinery for professional use

h)Active implantable medical devices

i)Photovoltaic panels

j)R&D equipment for B2B only

Enforcement Not specified By national enforcement bodies, e.g. in the UK

WEEE: Environment Agency, (SEPA, NID ofE)

RoHS: NMO (National Measurements Office)

Penalties Not Specified WEEE/RoHS:

Fines and costs, plus imprisonment in some EU States. The size of

fines varies considerably between EU Member States.

RoHS Exemptions (i) See Appendix 2 for a comparison listing.

(ii) Note: There are no time limitations for exemptions, no defined

procedure for requesting exemption and no criteria that can be

used for justification

A procedure exists for exemption requests which includes defined

criteria that can be used for justification. Time limitations are defined

Compliance

Approach

WEEE: Application to the State Pollution Control Board or local Pollution

Control Committee

RoHS: The approach is unclear for RoHS but it is required to include

information on RoHS substances in instruction manuals

WEEE – MS individually interpret the directive, requirements vary

considerably and include registration, membership of compliance

schemes

RoHS – EU-wide consistent interpretation, although there are some

areas where EU States have different interpretations. Compliance

by self-declaration using documentation 08.05.2012 21

India - Environment Regulation Industry Chemicals Report 2012 ©

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with EU RoHS (Contd…)

08.05.2012

Business Size Business Area Investment

Micro Manufacturing < INR 2.5 million Approx<£35K

Services < INR 1.0 million Approx <£14K

Small Manufacturing < INR 2.5 – 50 million Approx £35K – 700 K

Services < INR 1.0 – 20 million Approx £14K – 280K

Medium

Manufacturing < INR 50 – 100 million Approx < £700K - £1.4

million

Services INR 20 – 50 million Approx £280K – j£700K

Table A: (mentioned in ‘Business Size Affected’ Column in slide no: 21)

(Continued in Appendix C in Slide No: 40)


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with EU RoHS (Contd…)

08.05.2012

Categories of E-Waste covered under the rule e-waste (Management and Handling) Rules, 2010 – Schedule 1

Sl. No. E-Waste Categories

1 IT and Telecommunication Equipment:

Centralised data processing:

Mainframes, minicomputers

Personal computing:

Personal computers (CPU with input and output devices)

Laptop (CPU with input and output devices)

Notebook, Notepad etc.,

Printers including cartridges

Copying equipment

Electrical and electronic typewriters

Pocket and desk calculators

And other products and equipment for the collection, storage, processing, presentation or communication of information by

electronic means

User terminals and systems

Facsimile

Telex

Telephones

Pay telephones

Cordless telephones

Cellular telephones

Answering systems

And other products or equipment of transmitting sound, images or other information by telecommunications

2 Consumer electrical and electronics:

Television sets (including LCD & LED), Refrigerator, Washing Machine, Air-conditioners

(For Schedule II and III, please go to the hyperlink given in Slide 19)


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India RoHS: Challenges and Outlook

Challenges

• Lack of clarity on how RoHS would be adopted by companies (include producers, distributors, collection centres,

refurbishers, dismantlers, recyclers, consumers, or bulk consumers) involved in the manufacture, sale, purchase and

processing of electrical and electronic equipment or components

• The real problem India faces is a thriving backyard recycling industry (informal sector). E-waste is collected by recyclers

abroad and then sold to waste traders in India

• The complexity of e-waste flows within India and inadequate record-keeping (maintenance of registry) make an

estimation of the quantities and composition of e-waste within India, making enforcement of legislation difficult

• The draft rule does not specify how it will ensure that informal recyclers reduce their operations to dismantling and

collection activities. Furthermore, the underlying incentives that can result in the informal sector being able to outbid the

formal sector remain unaddressed

• A lack of awareness of the hazards of improper e-waste disposal, at the consumer-level, collector-level or recycler-level

or disposer-level

• Inadequate monitoring and enforcement mechanisms

08.05.2012

Outlook

• Many electronic companies are willing to comply with the requirements

• It is expected that Indian companies will be more open to complying with RoHS than REACH

• The various regulations that are at various stages of enactment and implementation tries to achieve the broader

objectives similar to EU and the US regulations. Considering all the challenges mentioned above, it will be a tough task

for the government and regulatory bodies to achieve full adherence and compliance


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India CLP

Overview of India CLP

08.05.2012

• India is expected to publish by mid-2012 rules governing the labelling of hazardous chemicals, in line with the UN GHS

requirements

• The draft rules were released in July, 2011 for comments from interested groups. Ministry of Environment and Forests is now

working on the final document (Rule called as Hazardous Substances (Classification, Packaging and Labelling) Rules, 2011;

draft notification dated 8th July, 2011. http://moef.nic.in/downloads/rules-and-regulations/SO523_E_new.pdf)

• India‟s approach would be to implement new rules that are entirely in agreement with the UN or partially fulfil the UN mandate

• India currently uses a combination of lists and laws to classify chemicals and govern their storage and handling

• For example, one current law is the Manufacture, Storage and Transport of Hazardous Chemical Rules of 1989 whose rules

do not conform to GHS. But efforts are to be made to radically revise these rules to avoid conflict and confusion with the new

GHS rules that would be introduced

Status of GHS Implementation in India

• Some of the salient points of India‟s new HS (CPL) rules are:

• Responsibilities in the supply chain to be prescribed

• All dangerous goods will have to have a UN number and proper shipping name according to their assigned hazard

classification and composition

• Suitable labelling and packaging will have to be used, along with updated safety data sheets

• People engaged in the handling, storage and transport of dangerous goods will have to be trained

• The consultation of the draft law has received a great deal of technical specifications, including how inflammable liquids and

mixtures of gases must be dealt with and more detailed definitions of what constitutes a toxic dose and how to determine

levels of flammability


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http://moef.nic.in/downloads/rules-and-regulations/SO523_E_new.pdf
















Evolution

• Similar to REACH, CLP legislation also is not yet present in India as of now (Rule in the draft stage)

• Only exporters of Chemicals to EU region comply to REACH and CLP requirements

• However, agencies such as Chemexcil and REACH Support Helpdesk are assisting Indian companies to comply to these

requirements

• Moreover, these agencies are helping create awareness among the domestic industry participants to move towards these

compliance requirements

• Various activities for implementing the GHS system in India is underway

• Instead of CLP, there are a host of legislations and acts that determine the classification, labeling and packaging especially

those that deal with Chemicals. Some of these regulations are,

08.05.2012

Central motor Vehicle Rule-1989 and some relevant Statutory Provisions

• R-129 : Transportation of Hazardous Goods nature

• R-129A : Spark Arrestor Provision

• R-130 : Manner of display of class labels

• R-131 : Responsibility of Consignor for safe transportation of Hazardous Goods

• R-132 : Responsibility of Transporter & Owner for safe transportation of Hazardous Goods

• R-133 : Responsibility of Driver for safe transportation of Hazardous Goods

• R-134 : Emergency Information Panel.

• R-135 : Drivers to be instructed.

• R-136 : Report of accidents by Driver to Police Station.

• R-137 : Display of Class Labels.


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08.05.2012

Manufacture, Storage & Import of Hazardous Chemicals -1989 (Under Environment Protection Act)

• Quantity based approach in management of Hazards

• Rules On-Site plans for installations having hazardous substances more than Threshold Quantities

• Safety Report for Bulk Storages

Legislations in India that relate to CLP

Other Legislations

• The Hazardous Wastes (Management & Handling) Rules – 1989

• Motor Vehicles Act - 1988 & Rules thereunder ( Safety in transportation of Hazardous substances)

• The petroleum and Explosive Act - 1984 & Rules ( Safety in handling of Petroleum and Petrochemical including bulk storages)

• Factories Act -1948 ( Safety In Manufacturing Activity)

• The Emergency Planning , Preparedness & Response For Chemical Accidents Rules-1995

• The Public Liability Insurance Act & Rules- 1991 ( Payment Of Compensation To The Outsiders In Respect Of Major Incidents

In Factories)


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08.05.2012

• Schedules –1 : How to identify Toxic, Flammable , Explosive Chemicals

• Schedules –2 : List of Hazardous Chemicals

• Schedules –3 : Classification of Chemicals based on UN Numbers

Schedules Under Motor Vehicles Act – 1988

Sl.

No. Chemicals

Schedule

1

Schedule

2

Schedule

3

1

2

3

4

5

6

7

8

9

10

11

12

Toxic

Flammable

Flammable gases

Highly flammable liquids

Flammable liquids

Explosive

Corrosive

Oxidizing

Reactive

Gasses compressed

Infectious substances

Radioactive substance

Y

-

Y

Y

Y

Y

-

-

-

-

-

-

Y

Y

-

-

-

Y

Y

Y

Y

-

-

-

-

-

-

-

Y

Y

Y

Y

-

Y

Y

Y

Schedules – 3 1. Correct Technical Name

2. U N Number

3. HAZCHEM Code

4. Class Labels

5. Emergency Dial

6. Special Advice ,if any

Emergency Information Panel (EIP)


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Classification and Labelling in India

08.05.2012

CLASS-1 : EXPLOSIVES

• e.g. TNT, Symbol-Exploding bomb with orange background

Class Labels of Dangerous Goods under Motor Vehicles Act - 1988

CLASS-2.1 : FLAMMABLE GASES

• e.g. LPG, Hydrogen, Symbol-white flame with red

background

CLASS-2.2 : NON-FLAMMABLE GASES

e.g. Chlorine, Nitrogen, Symbol-black cylinder with green

background

CLASS-3 : FLAMMABLE LIQUIDS

e.g. Petrol, Symbol-white flame with red background


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08.05.2012

CLASS-4 : FLAMMABLE SOLIDS

e.g. Calcium carbide, sulphur, Symbol-black flame with red &

white vertical stripes background


CLASS-5.1 ORGANIC PEROXIDE

e.g. Hydrogen Peroxide, Symbol-black flame above circle , yellow

background

CLASS-5.2 OXIDIZING AGENT

e.g. KMnO4

CLASS- 6 POISON (TOXIC)GAS

e.g. Chlorine, H2S, CS2; Symbol-black skull with crossbones

with white background


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08.05.2012

CLASS-7:RADIOACTIVE SUBSTANCES

e.g. Uranium, Radium


CLASS-8 :CORROSIVE

e.g. Hydrochloric Acid, Sulphuric acid, Caustic Soda

Sl. No. Degree of

Toxicity

Oral Toxicity

LD 50 (mg/kg)

Dermal

Toxicity LD 50

(mg/kg)

Inhalation

Toxicity LC 50

(mg/l)

1 Extremely

Toxic

<5 <40 <0.5

2 Highly Toxic >5 – 50 >40 – 2000 >0.5 – 2.0

3 Toxic >50 – 200 >200 – 1000 >2 – 10

The Manufacture, Storage and Import of Hazardous Chemicals Rules, 1989

(Schedule-I), Indicative Criteria and List of Toxic Chemicals


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India CLP Snapshot

Current Way of Adherence to CLP

• Appoint an „Only representative‟ (OR) who is a European legal entity

• Provide the OR with necessary technical information to finalize the CLP notification dossier

• OR shall compile the CLP notification in the IUCLID Software

• The CLP notification dossier shall then be submitted to the ECHA through the REACH-IT system


Finpro ry

Interview Summary

Conclusions

Recommendations

Interview Summary

Some quotes

08.05.2012

„‟The major concerns and thrust areas of environmental pollution, at present, are hazardous waste handling, its storage and

disposal and minimisation of volatile organic compounds, besides ensuring proper operation and maintenance of pollution

control devices.

Various ministries are involved in implementation of respective Acts and Rules related to chemicals management. It is,

therefore, necessary to have more inter-ministerial commissions and coordination mechanisms.‟‟

„„Suppliers in unorganized sector have little knowledge of REACH. Unlike mass manufacturers like China, testing per

consignment for fashion garments is much more difficult and costly. India specialises in fashion garments, with lot of value

additions and embellishments. Compliance requires testing of these embellishments also.

A manufacturer supplying small lots of such products to EU will incur very high testing charges. REACH regulations will have a

long lasting implication on the Indian apparel industry.‟‟

„‟There is a recommendation to, in future, merge all related regulations for having uniform standards. India is contemplating

REACH specific to India. But so far it has not been enacted. Small and medium companies in the sector are completely

unaware of REACH and such regulations. They are also sceptical of the high costs involved, as they operate on very low

margins already‟‟

„The REACH and CLP market in China is much more matured than in India, as China is hosts a large number of European

businesses. India has seen an increase over the last few years in the awareness and sensitivity towards product related

environmental issues. ‟‟

„‟Some of the priority actions proposed for India are,

• prepare Indian chemical inventory (none exists today),

• improve co-ordination at central government level amongst ministries,

• create laboratory infrastructure,

• augment human resources‟‟ (-- Comments from industry experts)


Finpro ry

Conclusions & Recommendation

• Identified that the chemical sector in India requires to go a long way towards REACH and CLP regulations

• RoHS regulations have been enacted. However, full scale implementation and compliance is expected to

face stiff challenges from the industry

• Large number of small and medium companies in the sector makes data gathering difficult – one of the

key reasons why implementation of such comprehensive regulations have been difficult in India

• Some of the administrative hurdles of the regulations – many ministries such as Ministry of Commerce

and Industry, Ministry of Chemicals and Fertilizers, Ministry of Environment & Forests, Ministry of Finance

etc, deliberating on the hierarchy and decision-making authority on chemicals management in India

• India has its own set of legislations and regulations which are getting evolved. Many government agencies

such as the Pollution Control Boards (Central and state level) are enforcing many of these regulations in a

strict manner now

• It needs to be seen how the many regulations will evolve into a comprehensive legislation similar to

REACH

• It is advised to closely monitor the regulatory developments in India on continuous basis, to gain more

understanding of how the various regulations (such as REACH, RoHS etc) are enacted and implemented


Finpro ry

Appendices

Appendix A – Primary Research Contacts

• Mr. J. S. Kamyotra, Member Secretary, Central Pollution Control Board (CPCB)

• Ms. Chandrima Chatterjee, Director, Economic & Consultancy, Apparel Export Promotion Council (APEC)

• Mr Vivek Gupta, Chemical Engineer, IIT Delhi

• Dr Rashmi Naidu, Director (Technical Services), REACH Support, For Sustainability Support Services (Europe) AB

• Mr. Sanjay Bansal, Director, Department of Chemicals & Petrochemicals, Ministry of Chemicals & Fertilizers,

Government of India

• Mr. Rajaram Vijayan, IIT Kharagpur, ex-Frost & Sullivan, ex-Novozymes, lifetime member of Indian Institute of

Chemical Engineers


Finpro ry

Appendix B – Industry Associations

08.05.2012

Industry Associations

• Indian Chemical Council

Sir Vithaldas Chambers, 16-Mumbai Samachar Marg,

Mumbai –400023

Phone: 91 22 22047649/ 22846852

Fax: 91 22 22048057

Website: www.icmaindia.com

• Alkali Manufacturers Association of India

3rd Floor, Pankaj Chambers,

Preet Vihar Commercial Complex,

VikasMarg,

New Delhi –110092

Phone: 91 11 22432003, 22410150, 55253401

Fax: 91 11 22468249

Website: www.ama-india.org

• Indian Specialty Chemical Manufacturers' Association

1156, Bole Smruti, Suryavanshi Kshatriya Sabhagriha Marg,

Off. Veer SavarkarMarg, Dadar(West)

Mumbai –400 028

Tel: 91 22 2446 5003

Website: www.iscma.in


Finpro ry

Appendix C – Comparison of EU RoHS and

India RoHS (Continuation from Slide No: 21) Exempti

on Nr Description

Scope and dates of applicability

In Europe In India EU-RoHS Recast

1 Mercury in single capped (compact) fluorescent

lamps not exceeding (per burner):

1(a) For general lighting purposes

<30 W: maximum 3.5mg/burner

Expires on 31st Dec 2011

3.5 mg may be used per

burner after 31 Dec 2011

until 31 Dec 2012

2.5 mg shall be used per


Limited to 5 mg

No Timescale specified

Expires on 31st December,

2012; 2.5mg shall be used

per burner after 31st

December, 2012

1(b) For general lighting purposes

≥30 W and <50 W: maximum 3.5mg per burner


3.5 mg may be used per


until 31 Dec 2012

Limited to 5 mg

No Timescale specified

1(c) For general lighting purposes

≥50 W and <150 W: maximum 5mg

1(d) For general lighting purposes

≥150 W:maximum 15mg

1(e)

For general lighting purposes with circular or

square structural shape and tube diameter ≤

17mm : maximum 7 mg per burner

No limitation of use until

31 Dec 2011

Limited to 7 mg

No timescale specified

1(f) For special purposes: maximum 5mg

2(a)

Mercury in the double-capped linear fluorescent

lamps for general lighting purposes not

exceeding (per lamp)


Finpro ry

Appendix C (Contd.)

Exempti

on Nr Description



2(a)(1) Tri-band phosphor with normal lifetime and a tube

diameter <9 mm (e.g. T2): 5 mg


4 mg may be used per lamp

after 31 Dec 2011

Limited to 4 mg



diameter ≥ 9 mm and ≤ 17 mm (e.g. T5)



after 31 Dec 2011

Limited to 3 mg



diameter >17 mm and ≤ 28 mm (e.g. T8) 5 mg


3.5 mg may be used per lamp

after 31 Dec 2011

Limited to 3.5 mg



diameter >28 mm (e.g. T12)



after 31 Dec 2011

No weight reduction to

3.5 mg specified


Expires on 31st Dec,

2012: 3.5 mg/lamp

after 31st Dec, 2012


diameter ≥ 9 mm and ≤ 17 mm (e.g. T5)



after 31 Dec 2011

No weight reduction to

5 mg specified


2(b) Mercury in other fluorescent lamps not exceeding

(per lamp):

2(b)(1) Linear halophosphate lamps with tube >28mm

(e.g. T10 and T12) Expires on 13 Apr 2012

No expiry date

specified

Expires on 13 April,

2012

2(b)(2) Non-Linear halophosphate lamps (all diameters)

15mg Expires on 13 Apr 2016

No expiry date

specified

Expires on 13 April,

2016

2(b)(3) Non-Linear tri-band phosphor lamps with tube

diameter >17 mm (e.g. T9)

No limitations of use until 31

Dec 2011


after 31 Dec 2011

Limited to 15 mg


2(b)(4) Lamps for other general lighting and special

purposes (e.g. induction lamps)

No limitation of use until 31 Dec

2011


after 31 Dec 2011

Limited to 15 mg

No Timescale

specified


Finpro ry

Appendix C (Contd.)

Exemptio

n Nr Description



3 Mercury in cold cathode fluorescent lamps

and external electrode fluorescent lamps

(CCFL and EEFL) for special purposes not

exceeding (per lamp):

3(a) Short length (≤500mm) No limitation of use until 31 Dec 2011

3.5 mg may be used per lamp after 31

Dec 2011

Limited to 3.5 mg

No timescale

specified

3(b) Medium length (> 500 mm and ≤ 1500 mm) No limitation of use until 31 Dec 2011

5 mg may be used per lamp after 31 Dec

2011

Limited to 5 mg

No timescale

specified

3(c) Long length (>1500 mm) No limitation of use until 31 Dec 2011

13 mg may be used per lamp after 31

Dec 2011

Limited to 13 mg

No timescale

specified

4(a) Mercury in other low pressure discharge

lamps (per lamp)

No limitation of use until 31 Dec 2011

15 mg may be used per lamp after 31

Dec 2011

No weight limit

No timescale

specified

4(b) Mercury in High Pressure Sodium (vapour)

lamps in general lighting purposes not

exceeding (per burner) in lamps with

improved colour rendering index Ra>60:

4(b)-I P ≤ 155 W No limitation of use until 31 Dec 2011

30 mg may be used per burner after 31

Dec 2011

Limited to 30 mg

No timescale

specified

4(b)-II 155 W < P ≤ 405W No limitation of use until 31 Dec 2011


Dec 2011

Limited to 40 mg

No timescale

specified

4(b)-III P > 405 W No limitation of use until 31 Dec 2011


Dec 2011

Limited to 40 mg

No timescale

specified


Finpro ry

Appendix C (Contd.)

Exemptio

n Nr Description



4(c) Mercury in other High Pressure Sodium

(vapour) lamps for general lighting purposes

not exceeding (per burner):

4(c)-I P ≤ 155 W No limitation of use until 31 Dec 2011


Dec 2011

Limited to 25 mg

No timescale

specified

4(c)-II 155 W < P ≤ 405W



Dec 2011

Limited to 30 mg

No timescale

specified

4(c)-III P > 405 W



Dec 2011

Limited to 40 mg

No timescale

specified

4(d) Mercury in High Pressure Mercury (vapour)

lamps (HPMV) Expires on 12 April 2015

No timescale

specified

Expires on 13th

April, 2015

5(a) Lead in glass of cathode ray tubes

5(b) Lead in glass of fluorescent tubes not

exceeding 0.2% by weight

6(a)

Lead as an alloying element in steel for

machining purposes and in galvanized steel

containing up to 0.35% lead by weight

6(b) Lead as an alloying element in aluminium

containing up to 0.4% lead by weight

6(c) Copper alloy containing up to 4% lead by

weight

7(a)

Lead in high melting temperature type solders

(i.e. lead based alloys containing 85% by

weight or more lead


Finpro ry

Appendix C (Contd.)

Exemptio

n Nr Description



7(b)

Lead in solders for servers, storage and storage

array systems, network infrastructure equipment

for switching, signalling, transmission, and

network management for telecommunications

7(c)-I

Electrical and electronic components containing

lead in a glass or ceramic other than dielectric

ceramic in capacitors, e.g. piezoelectronic

devices, or in a glass or ceramic matrix

compound

7(c)-II Lead in electric ceramic in capacitors for a rated

voltage of 125 V AC or 250 V DC or higher

7(c)-III Lead in dielectric ceramic in capacitors for a

rated voltage of less than 125 V AC or 250 V AC

Expires on 1 Jan 2013

After that date may be used in spare

parts for EEE placed on the market

before 1 Jan 2013

No expiry date

Expires on 1st Jan,

2013, after that may

be used in spare

parts for EEE

placed on the

market before 1st

Jan, 2013

7(c)-IV

Lead in PZT based dielectric ceramic materials

for capacitors being part of integrated circuits or

discrete semi-conductors

Approved by council 16 May 2011,

not yet in force Not yet included

8(a) Cadmium and its compounds in one shot pellet

type thermal cut-offs


After that date may be used in spare

parts for EEE placed on the market

before 1 Jan 2012

No expiry date

Expires on 1st Jan,

2012, after that may

be used in spare

parts for EEE

placed on the

market before 1st

Jan, 2012


Finpro ry

Appendix C (Contd.)

Exemptio

n Nr Description



8(b) Cadmium and its compounds in electrical contacts

9

Hexavalent chromium as an anticorrosion agent of the carbon

steel cooling system in absorption refrigerators up to 0.75% by

weight in the cooling solution

9(b)

Lead in bearing shells and bushes for refrigerant containing

compressors for heating, ventilation, air conditioning and

refrigeration (HVACR) applications

10 Item of EU RoHS Annex no Longer Applicable

11(a) Lead used in C-press compliant pin connector systems

May be used in spare

parts for EEE placed on

the market before 24

Sept 2010

No Expiry Date

11(b) Lead used in other than C-press compliant pin connector

systems


After that date may be

used in spare parts for

EEE placed on the

market before 1 Jan

2013

No expiry date

No conditions for

use

12 Lead as a coating material for the thermal conduction module

C-ing


parts for EEE placed on


Sept 2010

No conditions for

use

13(a) Lead in white glasses used for optical applications

13(b) Cadmium and lead in Filter glasses and glasses used for

reflectance standards


Finpro ry

Appendix C (Contd.)

Exemptio

n Nr Description



14

Lead in solders consisting of more than two elements for the

connection between the pins and the package of

microprocessors with a lead content of more than 80% and less

than 85% by weight

Expired on 1 Jan 2011

After that date may be

used in spare parts for

EEE placed on the

market before 1 Jan

2011

No expiry date

No conditions for

use

These may only be

used in spare parts

for EEE placed on

the market before

1st Jan, 2011

15

Lead in solders to complete a viable electrical connection

between semiconductor die and carrier within integrated circuit

flip chip packages

16 Lead in linear incandescent lamps with silicate coated tubes Expires on 1 Sept 2013 No expiry date

17 Lead halide as radiant agent in high intensity discharge (HID)

lamps used for professional reprography applications

18(a)

Lead as activator in the fluorescent powder (1% lead by weight

or less) of discharge lamps when used as speciality lamps for

diazoprinting reprography, lithography, insect traps,

photochemical and curing processes containing phosphors

such as SMS ((Sr,Ba) 2 MgSi 2 O 7:Pb)

Expired on 1 Jan 2011 No expiry date

18(b)

Lead as activator in the fluorescent powder (1% lead by weight

or less ) of discharge lamps when used as sun tanning lamps

containing phosphors such as BSP (BaSi 2 O 5:Pb)

19

Lead with PbBiSn-Hg and PblnSn-Hg in specific compositions

as main amalgam and with PbSn-Hg as auxiliary amalgam in

very compact energy saving lamps

Expired on 1 June 2011 No expiry date

20 Lead oxide in glass used for boding front and rar substrates of

flat fluorescent lamps used for Liquid Crystal Displays (LCDs) Expired on 1 June 2011 No expiry date

21 Lead and Cadmium in printing inks for the application of

enamels on glasses, such as brosilicate and soda lime glasses


Finpro ry

Appendix C (Contd.)

Exemptio

n Nr Description



22 Exemption expired in EU, not included in India

23 Lead in finishes of fine pitch components other than connectors

with a pitch of 0.65 mm and less


parts of EEE placed on


Sept 2010

No conditions for

use

May only be used

in spare parts for

EEE placed on

the market before

24th Sep, 2010

24 Lead in solders for the soldering to machined through hole

dicoidal and planar array ceramic multilayer capacitors

25

Lead oxide in surface conduction electron emitter displays

(SED) used in structural elements, notably in the seal frit and

frit ring

26 Lead oxide in the glass envelope of black light blue lamps Expired on 1 June 2011 No expiry date

27

Lead alloys as solder for transducers used in high powered

(designated to operated for several hours at acoustic power

levels of 125 dB SPL and above) loudspeakers

Expired on 24 Sept

2011 No expiry date

28 Exemption expired in EU, not included in India

29 Lead bound in crystal glass as defined in Annex I (Categories

1,2,3 and 4) of Council Directive 69/493/EEC

No definition in India

WEEE/RoHS to

which to refer

30

Cadmium alloys as electrical/ mechanical solder joints to

electrical conductors located directly on the voice coil in

transducers used in high-powered loudspeakers with sound

pressure levels of 100dB(A) and more

31

Lead in soldering materials in mercury free flat fluorescent

lamps (which e.g. are used for liquid crystal displays, design or

industrial lighting)


Finpro ry

Appendix C (Contd.)

Exemptio

n Nr Description



32 Lead oxide in seal frit used for making window assemblies for

Argon and Krypton laser tubes

33 Lead in solders for the soldering to thin copper wires or 100µm

diameter and less in power transformers

34 Lead in cermet-based trimmer potentiometer elements

35 Cadmium in photoresistors for analogue optocouplers applied

in professional audio equipment

Old exemption expired

31 Dec 2009

Replacement

exemption proposed by

EC Feb

Not yet included

36 Mercury used as a cathode sputtering inhibitor in DC plasma

displays with a content up to 30 mg per display Expired on 1 July 2010 No expiry date

37 Lead in the plating layer of high voltage diodes on the basis of a

zinc borate glass body

38 Cadmium and cadmium oxide in thick film pastes used on

aluminium bonded beryllium oxide

39

Cadmium in colour converting II-VI LEDs (<10µg Cd per mm2

of light-emitting area) for use in solid state illumination of

display systems

Expires on 1 July 2014 No expiry date

40 Cadmium in photoresistors for analogue optocouplers applied

in professional audio equipment

Approved by Council

16 May 2011, not yet in

force, will expire on 31

Dec 2013

Not yet included


Finpro ry

Appendix D

08.05.2012

References

• Ministry of Chemicals and Fertilizers (http://chemicals.nic.in)

• Ministry of Environment and Forests (http://moef.nic.in/index.php)

• Chemexcil (http://www.chemexcil.gov.in)

• http://www.indianchemicalportal.com/chemical-associations/

• http://chemexcil-reachhelp.com/index.php

• http://www.leatherindia.org/reach-related-services-to-members.asp

• Other relevant news and articles


Finpro ry

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