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C&E Recycling Portal
GmbH & Co. KG

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49090 Osnabrück
Tel. +49 541605-1093
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eMail: info@ce-weee.com

 

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German-Chinese Environmental Symposium in Osnabrück (27.9.2007)
Focus on China-RoHS, China-WEEE, and European Environmental Issues
 
The first German-Chinese environmental symposium sponsored by the new company C & E Recycling Portal GmbH & Co. KG (C&ERP) and SGS Deutschland GmbH was held on September 27. Exactly one year ago, C&ERP emerged from a joint venture between Hellmann Process Management GmbH & Co. KG, Osnabrück and CHEARI, the Chinese association of household appliance manufacturers. C&ERP, with locations in Osnabrück and Peking, offers all of its services in German, English, and Chinese.
A number of renowned Chinese and German experts arrived for the first joint environmental symposium to discuss the proposed China-WEEE[1]China shortly. At this time, it is not possible to say when the new law will come into force. as well as the new China-RoHS (the European guideline 2002/95/EC “Restriction of the Use of Hazardous Substances” – abbreviated as RoHS – formed the basis for China-RoHS). Mr. Liang Feng, Director of Resources Comprehensive Utilization Division Department of Environment & Resources Conservation, presented the Chinese government proposal to return and recycle used electric and electronic low-heat appliances in front of nearly 100 international guests. He stated that a draft law developed over 5 years is based on international experience while also considering national circumstances. The basic idea is to make manufacturers responsible for recycling used electric and electronic appliances; at the same time, the Chinese government would have to facilitate a recycling system. In the introductory phase, the new law would mainly affect all video terminals, cooling units, washing machines, air conditioners, and computers. Manufacturers would be responsible for financing the recycling process for these types of used appliances. According to Mr. Feng, there will be state funding for the construction of recycling facilities. A registration system for all affected devices similar to the European system will be established in
 
In a second key presentation, Mr. Wen Lei, Vice Director of the Department of System Reform and Market of the MII (Ministry of Information Industry), introduced the China-RoHS in force since March 1, 2007. It affects all electric appliances brought to the Chinese market, with the exception of military and exported electric and electronic appliances[2]. The key points are as follows:
        Electric appliances brought to market must be identified with the “Environmental Friendly Using Period” if they fall under the area of application and are listed in the “Key Administrative Catalogue” (each product in this catalogue must be certified according to CCC[3] before being sold or imported to China).
        The names and ingredients of hazardous substances contained in electric appliances brought to the Chinese market must be identified.
        Manufacturers and importers of electric appliances must explicitly identify the names of hazardous substances on product packaging.
        Hazardous substances contained in electric appliances must conform to relevant national and industry standards.
        The products listed in the “Key Administrative Catalogue” (product catalogue expected to be published in 2008) are subject to CCC certification.
 
 
According to Mr. Lei, three standards have been published to date. They include the identification standards (see Figure 1), threshold value standards, and standards regarding test methods for hazardous substances. He indicated that the requirements for concentration limits are formulated more clearly than those in the European RoHS. This is because China-RoHS has various classifications on which the concentration limits for hazardous substances are based (see Table 1), a fact that has been verified by attending European experts.
 

Standard Classification
Definition of the Material Type
(Requirements for Concentration Limits)
EIP-A
Homogenous materials for the composition of electric appliances (allowable Pb, Hg, Cr VI, PBB, PBDE equals 0.1 % of weight, allowable Cd equals 0.01 % of weight)
EIP-B
Metal coating of each individual component in the electric appliances (Pb, Hg, Cd, Cr VI should not be added intentionally)
EIP-C
Small parts or materials that cannot be removed from the electric appliances; the size of such products is usually less than or equal to 4 mm3 (Pb, Hg, Cr VI, PBB, PBDE may not exceed 0.1 % of the weight, Cd may not exceed 0.01 % of the weight)

Table 1: Concentration limit requirements (if the classifications overlap or do not appear reasonable, the sequence EIP-A, EIP-B, EIP-C should be followed).
 
At the end of his presentation, Mr. Lei told the affected manufacturers attending the symposium: “Keep up to date with the definitions in the “Key Administrative Catalogue”, get involved in finding substitutes for hazardous substances, and find out whether your products are listed in the catalogue as well as the effective date of the catalogue.” After the introduction into the details of China-RoHS, the Chinese expert Quan Pan, director of the materials analysis and test institute for electric household appliances, explained the extremely comprehensive CCC certification process and the tests according to China-RoHS. However, he emphasised that as long as the “Key Administrative Catalogue” has not been published, manufacturers only have to identify the content and location of hazardous substances and use corresponding identification (see Figure 1).
 
Whether corresponding standard European test methods will be recognised when affected appliances are imported into China was not clear after the presentations. According to statements made by attending European market experts, this would be a key requirement for the free flow of goods. They indicated that the acceptance of test methods according to the ISO standard is an essential prerequisite for open markets.
 
In their speeches, both Nadine Michael, C&ERP, and Dr. Udo Krischke, SGS, emphasised that both Chinese and European manufacturers who want to bring their devices to the European or Chinese markets face a huge challenge in order to meet all current regulations related to electric and electronic appliances. This is why both C&ERP and SGS offer a comprehensive range of services from consulting and conformity with the law to test methods. Furthermore, representatives from these companies are involved in numerous committees and will continue to promote the harmonisation of WEEE and RoHS with their Chinese counterparts via the C&ERP recycling platform.
 
Ms. Kathrin Gause, a speaker from the Federal Ministry of the Environment, and Mr. Jürgen Wituschek from the Federal Ministry of Economics, also asked for improved harmonisation within Europe. However, they also said that Germany considers the overall results to be positive after collecting experience with the ElektroG (electric and electronic appliances law) for more than a year. According to Ms. Gause, a trend-setting, cost-effective system has been created for both manufacturers and consumers. When she was asked why Germany has not published any monitoring results, Ms. Gause confirmed that there are, in fact, problems with data collection via the EAR foundation. The 2006 figures are not expected to be published until the end of 2007. The representative from the Federal Ministry of Economics, commenting on the question of whether the increase in environmental regulations could lead to market restrictions, criticised the WEEE and RoHS standards being discussed in China. He indicated that regulations need to be harmonised as far as possible and the high technical measurement and certification standards of individual states need to be recognised in order to facilitate free global trade. Any other approaches could easily reach protectionist proportions.
 
The results of the event, which were positive overall, were summarised by symposium manager Dr. Beate Kummer: “We will require more regular exchanges with Chinese experts in the future. When new recycling regulations are implemented in China, mistakes and false starts in our European system should be taken into account. But above all, we need to work on global harmonised regulations; this is the main challenge facing our political representatives in the EU and China.”


[1] China-WEEE: Chinese draft based on the WEEE directive 2002/96/EC Waste Electrical and Electronic Equipment
[2] All affected products can be viewed at http://www.mii.gov.cn/col/col1221/.
[3] CCC certification: Compulsory Product Certification


Chinese companies seek advice from German service-providers (25.05.2007)
- Joint venture as consultants in EU environmental law -
 
 
At the end of 2006, Hellmann Process Management (HPM) of Osnabrück (Germany), entered into a joint venture agreement with Beijing Cheari Ltd., a Chinese group dedicated to the manufacture of electrical equipment and electronic devices. The new joint venture business, known as C & E Recyclingportal GmbH & Co.KG or C&ERP, is to be managed by André Pohl and Xuwei Bing, the CEOs of HPM and Beijing Cheari Ltd. respectively. The fledgling company’s management team returned from its successful extensive trip to China with a long list of new tasks to perform: “Our Chinese colleagues expect C&ERP to guide them through the jungle of European environmental law,” says Mr Pohl. “One thing that we have learnt from our trip is that Chinese firms are highly interested in developments in Europe. However, many of these developments appear nigh-on incomprehensible from the distant vantage point of our partners in Asia.” The complex formulation of the European Directives WEEE and RoHS, along with the new REACH regulation, are already causing headaches among importers, says Pohl, adding that there is, for this reason, a demand for competent advice. The recently-founded firm C&ERP is already frequently in contact in this respect with several major Chinese manufacturers (including aigo, Midea Ltd. and KONKA Ltd.).
 
The differing levels of application of European environmental law in the various member states raise further questions. Chinese manufacturers of electrical goods likewise find it incomprehensible that the EU member states have not agreed on a uniform registration system for the circulation and importing of electrical equipment and electronic devices. In their view, this hinders imports and creates higher costs. C&ERP thus sees itself as a communications platform, backed up by long experience in the application of various compliance schemes. Markus Tiemann, who acts as HPM’s contact person for the firm’s Chinese partners, explained at a congress on recycling held in China during his visit there the various registration requirements imposed by the member states of the EU. The upshot of this is that it is difficult to harmonise 27 different takes on environmental issues. The current revision of WEEE is, however, dealing with just such enhanced harmonisation. The European Commission has even expressed its interest in receiving practical information on the subject! International consultants are therefore in a position to be able to help exercise some influence.
Experience with the European Battery Directive has, in the view of the experts at C&ERP, also shown that the implementation of new environmental rules is likely to take several years to achieve its corresponding objectives. HPM and C&ERP are therefore both confident that WEEE will eventually achieve success. C&ERP, with its long experience of recycling issues and the European market, is now, thanks to its partnership with HPM, also in a position to help non-European manufacturers successfully to break into the EU market.
China is also now beginning to tackle the related environmental issues, as shown in the coming into force on March 1st 2007 of the so-called “China RoHS”. This event takes on special importance in the light of the particularly close commercial ties that exist between German industry and the Chinese market. It is to be expected that the familiar prohibitions on use arising from EU-RoHS will result in even stricter controls, including on German imports of electrical and electronic goods.
 

HPM plans to hold a major congress in Osnabrück in October, with the presence of Chinese management, to discuss the subject of “China RoHS”.


Signing of the Joint Venture`s contract (2.10.2006)

 „This is a milestone in our company history,“ said André Pohl, general manager of Hellmann Process Management. He mentioned that signing the contracts with a Chinese partner for the new company C & E Recycling Portal GmbH & Co. KG (C&ERP) is another step towards more international business dealings.

At the end of 2006 the contracts were signed between Hellmann Process Management GmbH & Co. KG, Osnabrück (Germany) and Beijing Cheari Ltd. A large Chinese delegation was there watching the act for future cooperation. André Pohl was appointed as one of the general managers of C&ERP, he will lead the new company beside Xuwei Bing, Vice Director of Beijing Cheari Ltd. The whole managing board stated that the new company will have a lot of positive effects for the location Osnabrück: „We will not only get some new employees, we will also have some new cooperation with other service partners regarding recycling solutions.“ Xuwei Bing added: „We decided to work with Hellmann, because we need a competent and experienced partner in WEEE to fullfil all the future tasks.“

The new company will be the European “service platform” for Chinese manufacturers of electrical and electronic equipment in Europe. On the one hand the new Joint Venture will represent the interests of the Chinese companies in Europe and will fulfil the challenges of WEEE/RoHS guidelines. On the other hand C&ERP will buy logistics and recycling services on the European market. Beside that C&ERP will be the communication platform for the Chinese manufacturers handling all the work which is necessary for registrations in the EU member states. In the future secondary raw material will be transported through C&ERP to China to replace primary raw material in electrical and electronic equipment.

  

 

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