The Weekly Pulse: 24th – 28th October
What’s HOT in our Regulatory World at the moment?
What are our clients looking at?
This week’s trending sources in C2P
- Maine (USA): PFAS in Products Program, Draft Rule, 2022
- China: Adjusted List of Products Subject to Compulsory Certification and Network Licensing, Announcement No. 31, 2022
- UK: Persistent Organic Pollutants (Amendment) (EU Exit), Draft Regulations, October 2022
What is our Content Team talking about?
Maine (USA) – Recording from October 27, 2022 Meeting on PFAS in Products Now Available – Kelly Bugiera
The Maine Department of Environmental Protection (Department) invited stakeholders to participate in their second stakeholder meeting in order to review the intentionally added PFAS in Products registration program concept draft rule. This was held on October 27, 2022.
The discussion was to be focused on amendments to the concept draft rule which are based on comments that were received about the initial concept draft.
The discussion was also intended to include a review of how the Department is planning to proceed with rule development that is intended to clarify reporting requirements and program implementation pursuant to Maine law 38 M.R.S. §1614.
The recording from the October 27, 2022 Stakeholder Engagement Meeting on PFAS in Products has been published and a link can be found here.
Written comments on this current concept draft rule will be accepted until November 10, 2022. These should be submitted to the following email address: PFASProducts@Maine.gov
What are our Knowledge Partners talking about?
UK RoHS Exemption Fee Confirmed – Rina
The UK Department for Environment, Food and Rural Affairs (DEFRA) have confirmed that UK RoHS exemption applications shall be charged at £39, 721 as a one-off fee.
This shall apply to all exemptions submitted as of 6 April 2023, with refunds for any applications withdrawn calculated on a pro-rata basis.
This decision comes after reviewing of the public consultation where 54 responses were received with an overwhelming majority of stakeholders disagrees with this proposal.
Concern was raised over the impact to the availability of equipment sold within Great Britain (GB), divergence from EU law and competitive disadvantage to GB manufacturers, among other issues.
However, due to managing public money principles the UK government has seen fit to introduce the fee.
Given the feedback received, the UK Government will consider whether it would be appropriate to recognise exemption decision taken in other territories.
With the UK government consulting with industry on this prospect, with no date for such an activity set as yet.
The implementation in less than six months will shock many in terms of its speedy implementation.
Only one respondent agreed that such an implementation date would be suitable, with the vast majority of respondents highlighting issues with these costs not being factored into their financial planning and other legislative costs anticipated in 2023. DEFRA’s analysis indicates that only one exemption in 2023 is anticipated to be subject to the fee, with others due in 2024-2027.
This may be due to the majority of exemption renewals expected in early 2023, however the basis for this number is not shared as part of the report.
What are our Clients asking about?
For b2b packaging in France, is the Triman logo mandatory on packaging? If not currently, will it be? And if it is, does it have to be on all packaging components or just the outer?” – Answer by Freida Gubbins
The new mandatory harmonised sorting label is currently specific to household packaging.
We are not yet aware of any proposals to make the mark mandatory for B2B packaging.
We have a detailed overview of the upcoming labelling changes under the section on France in the source “Compliance and Risks: Packaging Labelling Legislation in Europe: A Regulatory Update, White Paper, April 2022“.
Further details on the labelling requirement are available in English in the CITEO guide, which can be found in C2P under the heading “CITEO: New Sorting Label for Household Packaging in France, Guidance Document, April 2022“.
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This information is based on the most viewed regulations on C2P this month.
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