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Introduction
The National Environment Agency (NEA) of Singapore is seeking the views of the public on the proposed restriction of hazardous substances (RoHS) in Electrical and Electronic Equipment (EEE) in Singapore. This control restricts the level of six hazardous substances in EEE- Lead (Pb), Mercury (Hg), Cadmium (Cd), Hexavalent Chromium (Cr VI), Polybrominated Biphenyls (PBBs) and Polybrominated Diphenyl Ethers (PBDEs) in 6 EEE in Singapore and they are: mobile phones, mobile computers, refrigerators, air conditioners, panel TVs and washing machines. The consultation period will last 4 weeks from 27 January 2015 to 24 February 2015.
Background
2 Hazardous substances, including heavy metals, are present in many EEE. Due to its high replacement rate and short life cycle, EEE also contributes to a fast growing waste stream. Hence, as part of NEA’s effort in environmental sustainability and overall plan to tackle the e-waste issues, we are implementing measures to reduce heavy metals in the incineration ash and landfill via a number of measures, including upstream control and encouraging recycling. The restriction of hazardous substances in EEE is an upstream control that NEA is implementing to reduce the amount of heavy metals entering our waste stream.
Key Features of proposed RoHS in EEE in Singapore
3 The proposed RoHS controls in Singapore (SG-RoHS) are modelled after the European Union (EU) Directive on the Restriction of Hazardous Substances (RoHS), but with some modifications. Some of the key features of the proposed controls in Singapore are:
a) Scope: Limited to the 6 categories of EEE viz mobile phones, mobile computers, refrigerators, air conditioners, panel TVs and washing machines. These 6 EEE are restricted to finished EEE that are meant for local sale to consumers. EEE designed solely for specialized/industrialized uses are excluded under the control.
b) Restricted substances and Application Exemptions: Both restricted substances and exemptions would be identical to that of the EU- RoHS Directive which restrict 6 hazardous substances in EEE- Lead (Pb), Mercury (Hg), Cadmium (Cd), Hexavalent Chromium (Cr VI), Polybrominated Biphenyls (PBBs) and Polybrominated Diphenyl Ethers (PBDEs) by setting maximum concentrations of 0.1% for each hazardous substance (except for cadmium, which is limited to 0.01%) by weight of homogeneous material in the EEE. NEA would adopt the full list of applications that are exempted from the restrictions under the latest EU-RoHS (EU-RoHS 2).
c) Implementation date: After the publication of RoHS, NEA would allow for a one year grace period after the gazette before it is effected. This grace period is intended for companies to meet contractual agreements, comply with the SG-RoHS requirements and for suppliers to source for alternatives. The implementation date of SG – RoHS i) for locally manufactured EEE that will be sold in Singapore would be the manufactured date and ii) for imported EEE to be sold in Singapore would be the importation date.
d) Demonstration of Compliance: Manufacturers /importers /distributors are to ensure that the 6 EEE are RoHS compliant, and declare its conformity at import stage. Non-RoHS compliant EEE are not allowed to be sold and shall be re-exported. The 6 EEE placed on the market must be in compliance with RoHS requirements. Manufacturers/Traders are required to prepare and keep a declaration form and a technical documentation in accordance to EN 50581:2012 standard (or otherwise prove compliance to requirements). As part of enforcement process, NEA may request for the manufacturer/trader’s declaration of conformity and records in the form of a RoHS technical file. Companies that are unable to show evidence of compliance may be subject to product withdrawal and penalty.
Public Consultation
4 Interested parties may access the EU-RoHS Directive and the draft implementation framework for SG-RoHS here and provide your feedback. Feedback can also be submitted to joanna_hy_lim@nea.gov.sg. The consultation exercise will end on 24 February 2015.
5 To ensure that the consultation is productive and focused, respondents are requested to observe these guidelines when providing their feedback:
· Please identify yourself as well as the organization you represent (if any) so that we may follow up with you to clarify any issues, if necessary.
· Please be clear and concise in your comments.
· Please focus your comments on the draft implementation plan and how it can be improved.
· As far as possible, please substantiate your points with illustrations, examples, data or alternative suggestions.
6 This draft implementation framework is released only for the purpose of consultation and does not represent the final implementation framework.
7 All comments received during the consultation exercise will be reviewed thoroughly and, if accepted, will be incorporated into the final implementation framework.
Feedback Channel
8 Your feedback is important to us. Should you have further queries regarding the product of concern, you may write in to or submit your feedback through this email address: Joanna_hy_lim@nea.gov.sg, with the subject heading "Consultation on Proposed RoHS in EEE in Singapore".
Summary of Responses
9 We regret that we will not be able to separately address or acknowledge every comment we receive. Instead, we will consolidate and publish a summary of the key comments received, together with our responses, on the reach website after the consultation exercise closes. The summary will maintain confidentiality of the respondents’ identities.
The National Environment Agency
27 January 2015
