India Chemicals 120521 Final

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
08.05.2012
Introduction of the project
Executive Summary
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
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
08.05.2012
Methodology
Information collection in internet and databases
Interviews with governmental officials, industry experts
The reports outcome will be presented in a seminar
organized by Teknologiateollisuus
Project team:
Teknologiateollisuus ry
Ms. Pirjo Kaivos
Ms. Mia Nores-Korkeamki
Ms. Carina Wiik
Finpro study team members
Mr. Matti Rasimus, Finpro Finland (Project Owner),
matti.rasimus@finpro.fi
Eija Tynkkynen, Finpro Beijing, (Project Manager) ,
eija.tynkkynen@finpro.fi
Finpro India study team:
Rekha Salvi, Senior Consultant rekha.salvi@finpro.fi
Shriya Ramachandran, Marketing & Communications
Manager shriya.ramachandran@finpro.fi
Dinkar Krishnan, Analyst dinkar.krishnan@finpro.fi
www.finpro.fi/finpro-maailmalla/intia

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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
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
Large Foreign and Indian

Chemical Companies
Medium Domestic
Companies
Very Small and Small

Domestic Companies
Highly fragmented industry

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India REACH
Overview of India REACH

Indian Chemical Sector A Background
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
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
Matrix showing India Governments Sector-specific Priority Risk and Volume

High
High
Oil Refinery,
Petrochemicals
Medium
Fertilisers, Chlor-Alkali
Low
Soda Ash
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Medium
Pesticides
Low
Bulk Drugs, Dyes &
Dye-intermediaries
Paints, Inks & Printing Inks

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Industry Sector Perspective

Key Sectors in India: Chemical Industry
Textile/Apparel Industry:
Leather 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)
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 Indias 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
Imports
Exports
MSIHC Rules,
Petroleum Act & Rules
Explosives Act & Rules
SMPV Rules
Gas Cylinder Rules
Insecticides Act & Rules
Customs Act & Rules
ODS (R&C) Rules
Production
MSIHC Rules,
CA (EPPR) Rules,
PLI Act & Rules
SMPV Rules
Gas Cylinder Rules
Factories Act & Rules
ODS (R&C) Rules
Recycling

ODS (R&C) Rules
Storage
MSIHC Rules,
CA (EPPR) Rules,
PLI Act & Rules
SMPV Rules
Gas Cylinder Rules
ODS (R&C) Rules
Transportation
CA (EPPR) Rules,
PLI Act & Rules,
Mines Act & Rules
Port Act & Rules
Dock Act & Rules
PFA Act & Rules
ODS (R&C) Rules
Use
ODS (R&C) Rules

HW (M&H) Rules
Batteries Rules
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Disposal
EP Act & Rules
Air Act & Rules,
Water Act & Rules,
HW (M&H) Rules
Batteries Rules
ODS (R & C) Rules
Overview of Regulations in India

Acts and Rules related to Chemical Industry
Environmental 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.
Chemical Safety and Emergency

Management
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
Specific Chemical
Category/Container
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
Others relevant to Chemicals

Management
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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
10
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
Indian REACH just like other non-EU countries
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
No REACH legislation, or REACH-like legislation in India domestically.

REACH compliance is only for exporters to EU region
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Comparison of REACH in Europe and India
REACH
Europe
India
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
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
Status
Impact on the Industry
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Timeline for REACH and CLP Compliance
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India REACH: Similarities and Difference

with EU REACH
Approach for Indian Companies for REACH Compliance
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
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
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
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India REACH: CHEMEXCIL Initiative
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
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-toface 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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India RoHS
Overview of India RoHS

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
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
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 EWASTE Report)
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India RoHS/WEEE Snapshot

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
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
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)
b)
c)
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)
(ii)
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
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Batteries
Radio Active Waste
Micro & Small Enterprises as defined under the Micro, Small &
Enterprises Development Act, 2006
See Appendix 2 for a comparison listing.

Note: There are no time limitations for exemptions, no defined
procedure for requesting exemption and no criteria that can be
used for justification
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
self-declaration
India - Environment Regulation Industry ChemicalsbyReport
2012 using documentation
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with EU RoHS (Contd)
Table A: (mentioned in Business Size Affected Column in slide no: 21)
Business Size
Micro
Small
Business Area
Investment
Manufacturing
< INR 2.5 million
Approx<35K
Services
< INR 1.0 million
Approx <14K
Manufacturing
< INR 2.5 50 million
Approx 35K 700 K
Services
< INR 1.0 20 million
Approx 14K 280K
Manufacturing
< INR 50 100 million
Approx < 700K - 1.4

million
Services
INR 20 50 million
Approx 280K j700K
Medium
(Continued in Appendix C in Slide No: 40)
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with EU RoHS (Contd)
Categories of E-Waste covered under the rule e-waste (Management and Handling) Rules, 2010 Schedule 1
Sl. No.
E-Waste Categories
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
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
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

Status of GHS Implementation in India
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)
Indias 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
Some of the salient points of Indias 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
08.05.2012

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26

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,
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.
08.05.2012

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27

Legislations in India that relate to CLP
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
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)
08.05.2012

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28

Schedules Under Motor Vehicles Act 1988
Schedules 1 : How to identify Toxic, Flammable , Explosive Chemicals

Schedules 2 : List of Hazardous Chemicals
Schedules 3 : Classification of Chemicals based on UN Numbers
Emergency Information Panel (EIP)
Schedules 3
Sl.
No.
1
2
3
4
5
6
7
8
9
10
11
12
Chemicals
Schedule
1
Schedule
2
Schedule
3
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
08.05.2012
1.
2.
3.
4.
5.
6.
Correct Technical Name

U N Number
HAZCHEM Code
Class Labels
Emergency Dial
Special Advice ,if any

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29
Classification and Labelling in India

Class Labels of Dangerous Goods under Motor Vehicles Act - 1988
CLASS-1 : EXPLOSIVES
e.g. TNT, Symbol-Exploding bomb with orange background
CLASS-2.1 : FLAMMABLE GASES

e.g. LPG, Hydrogen, Symbol-white
background
CLASS-2.2 : NON-FLAMMABLE GASES

e.g. Chlorine, Nitrogen, Symbol-black
background
flame
cylinder
with
with
red
green
CLASS-3 : FLAMMABLE LIQUIDS

e.g. Petrol, Symbol-white flame with red background
08.05.2012

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30

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
08.05.2012

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CLASS-7:RADIOACTIVE SUBSTANCES
e.g. Uranium, Radium
CLASS-8 :CORROSIVE
e.g. Hydrochloric Acid, Sulphuric acid, Caustic Soda
The Manufacture, Storage and Import of Hazardous Chemicals Rules, 1989

(Schedule-I), Indicative Criteria and List of Toxic Chemicals
Sl. No.
08.05.2012
Degree of
Toxicity
Oral Toxicity
LD 50 (mg/kg)
Dermal
Toxicity LD 50
(mg/kg)
Inhalation
Toxicity LC 50
(mg/l)
Extremely
Toxic
<5
<40
<0.5
Highly Toxic
>5 50
>40 2000
>0.5 2.0
Toxic
>50 200
>200 1000
>2 10

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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
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Interview Summary
Conclusions
Recommendations
Interview Summary
Some quotes
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)
08.05.2012

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35
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
08.05.2012

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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
08.05.2012

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Appendix B Industry Associations

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
08.05.2012

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39
Appendix C Comparison of EU RoHS and

India RoHS (Continuation from Slide No: 21)
Exempti
on Nr
1(a)
1(b)
1(c)
1(d)
Description
In Europe
Scope and dates of applicability

In India
EU-RoHS Recast
Mercury in single capped (compact) fluorescent

lamps not exceeding (per burner):
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

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
No limitation of use until

31 Dec 2011
Limited to 7 mg
No timescale specified
Expires on 31st December,

2012; 2.5mg shall be used
per burner after 31st
December, 2012

50 W and <150 W: maximum 5mg
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
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)
08.05.2012

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40
Appendix C (Contd.)
Exempti
on Nr
Description
In Europe

In India
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
2(a)(2)

diameter 9 mm and 17 mm (e.g. T5)

after 31 Dec 2011
2(a)(3)

diameter >17 mm and 28 mm (e.g. T8) 5 mg
2(a)(4)

diameter >28 mm (e.g. T12)
2(a)(5)

diameter 9 mm and 17 mm (e.g. T5)
2(b)
2(b)(1)
2(b)(2)
Mercury in other fluorescent lamps not exceeding

(per lamp):
Linear halophosphate lamps with tube >28mm
(e.g. T10 and T12)
Non-Linear halophosphate lamps (all diameters)
15mg

3.5 mg may be used per lamp
after 31 Dec 2011
after 31 Dec 2011
after 31 Dec 2011
Expires on 13 Apr 2012

Expires on 13 Apr 2016
Limited to 4 mg
Limited to 3 mg
EU-RoHS Recast
Limited to 3.5 mg
No weight reduction to
3.5 mg specified
No weight reduction to
5 mg specified
Expires on 31st Dec,

2012: 3.5 mg/lamp
after 31st Dec, 2012
No expiry date
specified
No expiry date
specified
Expires on 13 April,
2012
Expires on 13 April,
2016
No limitations of use until 31

Dec 2011
Limited to 15 mg
2(b)(3)
after 31 Dec 2011
No limitation of use until 31 Dec
Limited to 15 mg
Lamps for other general lighting and special
2011
2(b)(4)
No Timescale
purposes (e.g. induction lamps)
specified
India - Environment Regulation
Industry
after 31 Dec
2011 Chemicals Report 2012
08.05.2012
Finpro ry
Non-Linear tri-band phosphor lamps with tube
diameter >17 mm (e.g. T9)
41
Appendix C (Contd.)
Exemptio
n Nr
Description
In Europe
3(a)
Mercury in cold cathode fluorescent lamps

and external electrode fluorescent lamps
(CCFL and EEFL) for special purposes not
exceeding (per lamp):
Short length (500mm)
3(b)
Medium length (> 500 mm and 1500 mm)
3(c)
Long length (>1500 mm)
4(a)
Mercury in other low pressure discharge

lamps (per lamp)
4(b)
4(b)-I
Mercury in High Pressure Sodium (vapour)

lamps in general lighting purposes not
exceeding (per burner) in lamps with
improved colour rendering index Ra>60:
P 155 W
4(b)-II
155 W < P 405W
4(b)-III
P > 405 W
08.05.2012

In India
No limitation of use until 31 Dec 2011

3.5 mg may be used per lamp after 31
Dec 2011
5 mg may be used per lamp after 31 Dec
2011
Limited to 3.5 mg
No timescale
specified
Limited to 5 mg
No timescale
specified

13 mg may be used per lamp after 31
Dec 2011
15 mg may be used per lamp after 31
Dec 2011
Limited to 13 mg
No timescale
specified
No weight limit
No timescale
specified

Limited to 30 mg
30 mg may be used per burner after 31
No timescale
Dec 2011
specified
Limited to 40 mg
No timescale
Dec 2011
specified
Limited to 40 mg
No timescale
India - Environment
Regulation
Industry
Chemicals
Report
2012
Dec 2011
specified
Finpro ry
EU-RoHS Recast
42
Appendix C (Contd.)
Exemptio
n Nr
4(c)
Description
In Europe
4(c)-I
Mercury in other High Pressure Sodium

(vapour) lamps for general lighting purposes
not exceeding (per burner):
P 155 W
4(c)-II
155 W < P 405W
4(c)-III
P > 405 W
4(d)
Mercury in High Pressure Mercury (vapour)

lamps (HPMV)
5(a)
Lead in glass of cathode ray tubes
5(b)
6(a)
6(b)
6(c)
7(a)

In India

Dec 2011
Dec 2011
Dec 2011
Expires on 12 April 2015
Limited to 25 mg
No timescale
specified
Limited to 30 mg
No timescale
specified
Limited to 40 mg
No timescale
specified
No timescale
specified
EU-RoHS Recast
Expires on 13th
April, 2015
Lead in glass of fluorescent tubes not

exceeding 0.2% by weight
Lead as an alloying element in steel for
machining purposes and in galvanized steel
containing up to 0.35% lead by weight
Lead as an alloying element in aluminium
containing up to 0.4% lead by weight
Copper alloy containing up to 4% lead by
weight
Lead in high melting temperature type solders
(i.e. lead based alloys containing 85% by
weight or more lead
08.05.2012

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43
Appendix C (Contd.)
Exemptio
n Nr
7(b)
7(c)-I
7(c)-II
Description
In Europe

In India
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
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)
EU-RoHS Recast
Lead in solders for servers, storage and storage

array systems, network infrastructure equipment
for switching, signalling, transmission, and
network management for telecommunications
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
Lead in electric ceramic in capacitors for a rated
voltage of 125 V AC or 250 V DC or higher
Cadmium and its compounds in one shot pellet

type thermal cut-offs
08.05.2012

After that date may be used in spare
parts for EEE placed on the market
before 1 Jan 2012
No expiry date

Finpro ry
Expires on 1st Jan,

2013, after that may
be used in spare
parts for EEE
placed on the
market before 1st
Jan, 2013
Expires on 1st Jan,

2012, after that may
be used in spare
parts for EEE
placed on the
market before 1st
Jan, 2012
44
Appendix C (Contd.)
Exemptio
n Nr
8(b)
9
9(b)
10
Description
In Europe

In India
EU-RoHS Recast
Cadmium and its compounds in electrical contacts
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
Lead in bearing shells and bushes for refrigerant containing
compressors for heating, ventilation, air conditioning and
refrigeration (HVACR) applications
Item of EU RoHS Annex no Longer Applicable
11(a)
Lead used in C-press compliant pin connector systems
11(b)
Lead used in other than C-press compliant pin connector

systems
12
Lead as a coating material for the thermal conduction module

C-ing
13(a)
Lead in white glasses used for optical applications
13(b)
Cadmium and lead in Filter glasses and glasses used for

reflectance standards
08.05.2012
May be used in spare

parts for EEE placed on
the market before 24
Sept 2010
After that date may be
used in spare parts for
EEE placed on the
market before 1 Jan
2013
parts for EEE placed on
Sept 2010
No Expiry Date
No expiry date
No conditions for
use
No conditions for
use

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45
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
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
17
18(a)
18(b)
19
20
21
Lead halide as radiant agent in high intensity discharge (HID)

lamps used for professional reprography applications
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)
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)
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
Lead oxide in glass used for boding front and rar substrates of
flat fluorescent lamps used for Liquid Crystal Displays (LCDs)
Lead and Cadmium in printing inks for the application of
enamels on glasses, such as brosilicate and soda lime glasses
08.05.2012
In Europe

In India
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
Expires on 1 Sept 2013
No expiry date
Expired on 1 Jan 2011
No expiry date
Expired on 1 June 2011
No expiry date
No expiry date

Finpro ry
EU-RoHS Recast
These may only be

used in spare parts
for EEE placed on
the market before
1st Jan, 2011
46
Appendix C (Contd.)
Exemptio
n Nr
22
23
24
25
Description
In Europe

In India
Exemption expired in EU, not included in India
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
Lead oxide in the glass envelope of black light blue lamps
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
31
May only be used

in spare parts for
EEE placed on
the market before
24th Sep, 2010
Lead in solders for the soldering to machined through hole

dicoidal and planar array ceramic multilayer capacitors
Lead oxide in surface conduction electron emitter displays
(SED) used in structural elements, notably in the seal frit and
frit ring
26
30
EU-RoHS Recast
No definition in India
WEEE/RoHS to
which to refer
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
Lead in soldering materials in mercury free flat fluorescent
lamps (which e.g. are used for liquid crystal displays, design or
industrial lighting)
08.05.2012

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47
Appendix C (Contd.)
Exemptio
n Nr
32
33
34
35
36
37
38
39
40
Description
In Europe

In India
EU-RoHS Recast
Lead oxide in seal frit used for making window assemblies for
Argon and Krypton laser tubes
Lead in solders for the soldering to thin copper wires or 100m
diameter and less in power transformers
Lead in cermet-based trimmer potentiometer elements
Cadmium in photoresistors for analogue optocouplers applied

in professional audio equipment
Mercury used as a cathode sputtering inhibitor in DC plasma

displays with a content up to 30 mg per display
Lead in the plating layer of high voltage diodes on the basis of a
zinc borate glass body
Cadmium and cadmium oxide in thick film pastes used on
aluminium bonded beryllium oxide
Cadmium in colour converting II-VI LEDs (<10g Cd per mm2
of light-emitting area) for use in solid state illumination of
display systems
Cadmium in photoresistors for analogue optocouplers applied
in professional audio equipment
08.05.2012
Old exemption expired

31 Dec 2009
Replacement
exemption proposed by
EC Feb
Not yet included
Expired on 1 July 2010
No expiry date
Expires on 1 July 2014
No expiry date
Approved by Council
16 May 2011, not yet in
force, will expire on 31
Dec 2013
Not yet included

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48
Appendix D
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
08.05.2012

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49
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Environmental Legislation for

Industry Chemicals in India

Introduction of the project

Conclusions & Recommendations

India - Environment Regulation Industry Chemicals Report 2012

Introduction of the Project

India - Environment Regulation Industry Chemicals Report 2012

Highly fragmented nature of legislations could lead to legal complications

Large Foreign and Indian

Very Small and Small

Highly fragmented industry

India - Environment Regulation Industry Chemicals Report 2012

Overview of India REACH

India's response to Chemical regulations so far

India - Environment Regulation Industry Chemicals Report 2012

Overview of Indian Chemical Industry

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

Matrix showing India Governments Sector-specific Priority Risk and Volume

Paints, Inks & Printing Inks

India - Environment Regulation Industry Chemicals Report 2012

Industry Sector Perspective

REACH Helpdesk for Apparel Exporters An initiative

REACH Helpdesk for Leather Exporters provided by TUV SUD

India - Environment Regulation Industry Chemicals Report 2012

Overview of Regulations in India

Petroleum Act & Rules

ODS (R&C) Rules

India - Environment Regulation Industry Chemicals Report 2012

Overview of Regulations in India

Chemical Safety and Emergency

The Petroleum Act, 1934

Others relevant to Chemicals

India - Environment Regulation Industry Chemicals Report 2012

Factories Act, 1948

India REACH Snapshot

Indian REACH just like other non-EU countries

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

India - Environment Regulation Industry Chemicals Report 2012

India REACH Snapshot

Been in force since June 2007

Not enacted so far for the domestic market.

Substances and articles require registration

Indian chemical companies, mostly small

Impact on the Industry

India - Environment Regulation Industry Chemicals Report 2012

India REACH Snapshot

India - Environment Regulation Industry Chemicals Report 2012

India REACH: Similarities and Difference

Background from EU-REACH Perspective

India - Environment Regulation Industry Chemicals Report 2012

India REACH: Challenges & Outlook

India - Environment Regulation Industry Chemicals Report 2012

India REACH: CHEMEXCIL Initiative

India - Environment Regulation Industry Chemicals Report 2012

Overview of India RoHS

India - Environment Regulation Industry Chemicals Report 2012

India RoHS/WEEE Snapshot

Lead (Pb)> <1000 ppm

Mercury (Hg): < 1000 ppm

Lamps, sensors, relays and so on

Cadmium (Cd): < 100 ppm

Hexavalent Chromium (Cr VI) <

Polybrominated Biphenyls (PBB):

Polybrominated Diphenyl Ethers