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NEA’S RESPONSES TO COMMENTS RECEIVED FROM THE PUBLIC CONSULTATION ON THE PROPOSED CONTROL OF 2 GROUPS OF CHEMICALS AND 9 MERCURY-ADDED PRODUCTS
1The National Environment Agency (NEA) has concluded its public consultation on the proposed control of 2 groups of chemicals under review by the Stockholm Convention and 9 mercury-added products adopted under the Minamata Convention. The 4-week consultation exercise was open for public comments from 18 Jan 2024 to 15 Feb 2024.
2NEA received 39 responses from this consultation exercise. Overall, the respondents were supportive of the proposed control of the 2 groups of chemicals and 9 mercury-added products under the Second Schedule of the Environmental Protection and Management Act (EPMA) and the Schedule of the EPM (HS) Regulations, with some providing feedback. NEA’s responses to the key feedback are summarised in the table below.
| S/N | Key Feedback | NEA's Response |
| 1 | There may be difficulty in finding substitutions for certain applications using the two groups of chemicals. Lead time is also required to phase-out the chemicals and for requalification of products/processes that use those alternatives. | NEA will only prohibit the import, export, production and use of the two groups of chemicals after the chemicals are officially adopted by Parties for listing in Annex A of the Stockholm Convention and their entry into force. These chemicals are likely to be tabled for adoption at the Conference of the Parties meeting to be held in April/May 2025, and the ban is expected to take effect at least 1 year later. Companies are advised to develop alternatives early in anticipation of the potential ban on the production and use of these chemicals. Prior to the ban under the Stockholm Convention, companies will be allowed to continue to import, export, manufacture or sell these chemicals with a valid Hazardous Substances (HS) Licence from NEA, or store or use these chemicals with a valid HS Permit from NEA. The Persistent Organic Pollutant Review Committee (POPRC) of the Stockholm Convention is currently carrying out a review and may allow time-limited exemptions for certain uses that do not have viable alternatives. Industry may request for NEA to register for such exemptions, if applicable. |
| 2 | Consider excluding the two groups of chemicals from control if they exist as impurities or are present in consumer products. | Unintentional trace quantities of the chemicals present as contaminants will be exempted from the proposed regulatory control, as allowed for and in alignment with the provisions under Stockholm Convention. NEA may require relevant supporting documentation (e.g. safety datasheets, analytical reports) to be furnished when such cases surface. For chemicals that are present in consumer products, our domestic controls will be aligned with the obligations of the Stockholm Convention when the chemicals are listed in Annex A of the Stockholm Convention. This includes the type of products or articles that are adopted for exemption. |
3NEA would like to thank all stakeholders who participated in the consultation exercise. We look forward to your active participation again in our future public consultation.
Aim
The National Environment Agency (NEA) is seeking feedback on the proposed control of 2 groups of chemicals and 9 mercury-added products as hazardous substances (HS) under the Second Schedule of the Environmental Protection and Management Act (EPMA) and the Schedule of the (EPM (HS) Regulations)1. This consultation will last 4 weeks from 18 Jan 2024 to 15 Feb 2024.
Background
2 Singapore is party to the Stockholm Convention (SC), which aims to eliminate and restrict the production and use of persistent organic pollutants, and the Minamata Convention (MC), which aims to protect human health and the environment from man-made emissions and releases of mercury and mercury compounds. NEA, as the Competent Authority for the SC and the MC, controls chemicals listed under the respective Conventions to ensure that the international obligations are complied with.
Proposed Control on 2 Groups of Chemicals
3 The following 2 groups of chemicals have several industrial usages and have been assessed by the Persistent Organic Pollutants Review Committee (POPRC) of SC to be highly toxic, persistent and can bio-accumulate to cause long lasting harmful effect in the environment:
a. Medium chain chlorinated paraffins (MCCPs) i.e. Chlorinated paraffins with carbon chain lengths in the range C14–17 and chlorination levels at or exceeding 45 per cent chlorine by weight
b. Long-chain perfluorocarboxylic acids (LC-PFCAs) with carbon lengths of 9 to 21, their salts and related compounds
4 In anticipation that POPRC is likely to recommend for their adoption into Annex A of the SC for elimination at the 12th Conference of Parties (COP) held in 2025. NEA intends to pre-emptively impose regulatory controls over the import, export, manufacture, offer for sale, transport, purchase, storage and/or use of these chemicals to ensure the environmentally sound management of these chemicals. Prior to the ban of LC-PFCAs and MCCPs under SC, companies will be allowed to import, export, manufacture or sell these chemicals with a valid HS Licence from NEA, or store or use these chemicals with a valid HS Permit from NEA. The POPRC is also conducting further assessment on the usage of MCCPs and LC-PFCAs and may recommend limited exemptions for certain uses that do not have viable alternatives.
Proposed Control on 9 Mercury-Added Products
5 In addition, Parties to the MC have agreed to list 9 mercury-added products under Annex A of the MC, which are listed below, for them to be phased out by end 2024. These mercury-added products can release mercury, which is highly toxic, persistent, and can also bio-accumulate to cause long lasting harmful effects to the environment. As such, NEA intends to control these 9 mercury-added products as HS and to phase them out by end 2024. Therefore, the manufacture, import and export of the 9 mercury-added products will not be allowed from 1 Jan 2025.
a. Compact fluorescent lamps with an integrated ballast (CFL.i) for general lighting purposes that are ≤ 30 watts with a mercury content not exceeding 5 mg per lamp burner
b. Cold cathode fluorescent lamps and external electrode fluorescent lamps of all lengths for electronic displays
c. Strain gauges to be used in plethysmographs
d. The following electrical and electronic measuring devices except those installed in large-scale equipment or those used for high precision measurement, where no suitable mercury free alternative is available:
•Melt pressure transducers, melt pressure transmitters and melt pressure sensors
e. Mercury vacuum pumps
f. Tyre balancers and wheel weights
g. Photographic film and paper
h. Propellant for satellites and spacecraft
i. Very high accuracy capacitance and loss measurement bridges and high frequency radio frequency switches and relays in monitoring and control instruments with a maximum mercury content of 20 mg per bridge switch or relay [except those used for research and development purposes]
6 NEA intends to gazette the regulatory changes by Jun 2024. This would be followed by a six-month transitional period before the changes come into force by Jan 2025.
Request for Feedback
7 This proposal is released for the purpose of consultation. Comments received during the consultation exercise will be reviewed and may be considered in developing the final measures. Parties wishing to provide feedback may do so at https://form.gov.sg/65a634b2f2138c00121a161f or send an email to Primus_ONG@nea.gov.sg and Nikki_LEE@nea.gov.sg by 15 Feb 2024.
8 In order to ensure that the consultation is productive and focused, respondents are requested to adhere to the following guidelines when providing their feedback:
a. Identify yourself as well as the organisation you represent (if any) so that NEA may follow up with you to clarify on any issue where necessary.
b. Be clear and concise in your comments.
c. Focus your comments on the proposal and how it can be improved.
d. Substantiate your points with illustrations, examples, data or alternative suggestions.
1 More information on the licensing regime under EPMA and EPM(HS) Regs can be found at https://www.nea.gov.sg/our-services/pollution-control/chemical-safety/hazardous-substances/management-of-hazardous-substances
