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Indian regulators and the electronics industry are focusing on improving market surveillance for e-waste laws and hazardous substances standards, with new regulations coming into effect in 2012. Market surveillance has also intensified in Turkey for all types of electrical and electronic products. Find out below how to stay compliant or gain quick market access in India and Turkey.

India focus on e-waste and hazardous substances

Even though E-Waste & hazardous substances regulations, similar to EU RoHS, have been in place in India for a few years, market surveillance has been proving quite challenging on this immense market. But with over 19,000 tonnes of electronic waste generated in Mumbai alone, in 2009, the Indian Government has made the implementation of its E-waste & hazardous substances regulations one of its top priorities.

In May 2010, the Indian Ministry of Environment and Forests, proposed a draft notification of its E-waste (Management and Handling) Rules 2010, aimed at creating an effective mechanism to supervise the generation, collection, storage, transportation, import and export of EEE. The draft rules focused mainly on setting up requirements for viable recycling, treatment and disposal of E-waste, but it also included a chapter on reducing the amount of hazardous substances used in EEE manufacturing.

After a period of stakeholder consultation, the new E-Waste (Management and Handling) Rules 2011 have been published and will come into effect from May 1, 2012. The Rules cover two primary areas - similar to the EU WEEE and RoHS Directives. The Indian E-waste Rules 2011 limits the use of 20 substances in EEE for sale in India.  Additionally, it bans several substances, including some flame retardants, that currently have no viable alternatives. As in the EU, the Indian Government requires manufacturers and importers to provide written documentation supporting compliance to the E-Waste Rules. The new piece of legislation will prove challenging at first for manufacturers and importers, as the new rules on documenting compliance require the disclosure of information that component makers may regard as proprietary. In light of the liabilities and penalties that manufacturers and importers may face if their products fail to meet the new compliance criteria, more and more companies have now introduced precautionary measures, by implementing screening procedures for products and submitting relevant raw materials, components and final products to precision testing in dedicated third party labs.

Turkey - alignment with EU legislation

Typically all consumer EEE destined for the Turkish market needs to be accompanied by its CE declaration of conformity, as well as LVD and EMC test reports, in accordance with their product category standards. Products must also strictly follow the applicable CE marking rules.

Starting with 2012, Turkish Customs officers have intensified checks of EEE imported to Turkey and are increasingly denying entry to products that are not accompanied by all the required documentation. The Turkish Industry Ministry has also intensified its market surveillance, randomly collecting E&E products already on sale and submitting them to tests to determine their compliance to relevant standards. Products that do not pass testing are immediately removed from the market and their manufacturers or importers are being fined.
 
As with all other EEE, batteries of all types and for all purposes are also under intense scrutiny from Customs and market surveillance agencies. To gain access to the Turkish market, batteries have to be accompanied by the relevant test reports.

CE declaration of conformity is also mandatory for all gas appliances (ovens, heaters, etc.) and all the applicable tests have to be performed by authorized third party labs that have worldwide recognized authorization numbers. 

Together with an increased market surveillance, the Turkish Government has also increased its efforts to support local manufacturers to achieve compliance with ecodesign norms and other EU legislations, such as RoHS, REACH, WEEE and EuP, etc. Through the Ellen projects, the Government offers economic advantages to manufacturers that manufacture and test their products in accordance with relevant regulations, within a specific timetable. SGS Turkey is one of the partners of the Ellen projects.

SGS can support your company with achieving quick market access in India and Turkey, as well as on any other market worldwide. For more information on our service portfolio visit the SGS E&E web page.

Dr. Asish Chakraborty
Manager-Technical (Multilabs)
SGS India
t: +33 6626 6100 101

Muge Okumus
E&E Section Manager
SGS Turkey
t: +90 212 368 40 00

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