1. Trilateral Working Group Meeting Latin America Battery Association
October 20th, 2016
Rosslyn, VA
T. García / H. Alvarenga

2. Agenda
Countries of Interest
Mexico
Chile
Ecuador
Argentina

3. Mexico All kind of batteries are consider special Handling waste.
Only big generator (more than 10 Ton per year) are obligated to establish handling plans.
Generator is who use the battery and has to dispose it. Producer and distributor are not consider generators.
Lead-Acid, Ni-Cd, Mercury oxide and Silver oxide batteries are consider Hazardous waste.
Mexican Regulation to control battery importation because of Hg and Cd content (according to Battery Directive)
To be published for public consultation
Hg Inventory (MINAMATA Convention) is been developed
Mexico can use the 2nd version of the Hg toolkit inventory
Mexico city has a huge waste problem (About 13,000 tons per day)
No areas for landfill disposal
Searching for incineration solutions and they will look that all companies pay for that. We expect to be in the list of the industries.

4. Chile - General Information
Regulation
Name
Ley de fomento del Reciclaje y la Responsabilidad Extendida del Productor
“Recycling Promotion and EPR Law”
Congress Approval
April 5th, 2016
Presidential Approval
April 12th, 2016
Publication
May 17th, 2016
Enforcement
By Supreme Decrees to be issued for each Priority Products
Regulation for the creation of Supreme Decrees
One year for drafting the Regulation for the creation of each Supreme Decree publication after Law publication in Official Gazette
Supreme Decrees Enforcement
TBD – Estimated mid of 2018

5. Chile - Impact on business
Regulation
Type of law
Framework law establishing general requirements for target product categories (priority products)
Scope
Initial set of general product categories (Priority Products)
Lubricant oil
Electric and Electronic Equipment
Automotive Batteries
Packaging (in general)
Tires
Primary and Secondary batteries (HS 8506/8507)
Scope extended
Supreme Decrees might expand into subcategories each priority product main category.
Subject regulated
Importers, local manufacturers, distributors and end consumers (different degrees of responsibility for each one)

6. Chile - Impact on Business
Regulation
Collection target
Not defined by the law, TBD for each Priority Product by each Supreme Decree. Estimated for batteries, initial 4% (average of sales)
Collection target estimated
4% (baseline)
10/15% (323tn) by 2019
25/30% (774tn) by 2023
Labeling
Authority might require the use a particular label to promote recycling – TBD
Hazardous Substances
Authority might require product certification to assure heavy metals content maximum concentration - TBD

7. Ecuador – General Information
Current Obligations – Battery Certification
Primary Batteries
RTE-105 as of June 2014
Scope: IN: CZ/ALK ; OUT: Button Cells
Applicable Standard: IEC60086 parts 1 and 2
Heavy Metals: Hg 5ppm, Cd, 20ppm
Secondary Batteries
RTE-115 as of June 2014
Scope: IN: Lead Acid, Li-ion, NiCd, NiMH; OUT: Products with batteries
Conformity Assessment
Self Declaration of Conformity + Third Party Testing Lab
Foreign Test Houses
Must be members of ILAC
Local testing capability
None
Approval Certificate validity
2 years
Checking point
Customs
Every importation lot
Collection target estimation is based on AMPHOS XXI LCA study for batteries in Chile that was prepared for the Ministry of Environment. Certainly it is going to be used as the starting point of discussion at the time of drafting the Batteries Supreme Decree.

8. Ecuador – General Information
Current Obligations – Battery Stewardship Program
Legal requirement
Ministerial Agreement 022 as of April 2013
Scope
Primary batteries: Oxide Mercury
Secondary batteries: NiCd, NiMH, NiFe, Li-ion
Conformity Assessment
Implementation of a national individual or collective Battery Stewardship Program
Collection Target
5% First year + 5% annual increments until getting to 85% collection rate.
Local battery processing capability
None
Final disposal
Not allowed
Exportation
Allowed
Degree of Battery Industry Compliance
Very low
Checking point
Market
Collection target estimation is based on AMPHOS XXI LCA study for batteries in Chile that was prepared for the Ministry of Environment. Certainly it is going to be used as the starting point of discussion at the time of drafting the Batteries Supreme Decree.

9. Ecuador – General Information
Current Obligations – Battery Certification & Stewardship Program
Regulation
RTE-105 (1R)
Enforcement
December 28th, 2016
Scope
Primary and Secondary Batteries
Scope Exeptions
Car batteries
Batteries included in products
Heavy Metals Limits
Hg <= 5ppm
Cd <= 20ppm
Safety Requirements – Primary
IEC parts 1,2,3,4 and 5 depending on the battery type, or
ANSI C18.1 part 1 and ANSI C18.1 part 2, or
NTE INEN 807 (parts 1,2,3,4 and 5 depending on the batter type)
Safety Requirements – Secondary
NiCd (cylindrical, prismatic and button)
IEC and IEC62133
Sealed NiCd (prismatic)
IEC60622 and EN
Non-sealed NiCd (prismatic)
IEC60623, EN and EN
NiMH (cylindrical, prismatic and button)
IEC and IEC62133
Lithium (portable applications)
IEC61960 and IEC62133
Lithium (industrial applications)
IEC62620
VRLA
IEC , EN and EN

10. Ecuador- INEN RTE-105 (1R) – Conformity Assessment Procedure
Certification Schemes
Third Party Certification
Scheme 5, NTE INEN-ISO/IEC 17067
Surveillance evidence
Marking approval evidence
Importer’s registration (local)
Hazardous Waste Generator registration (Ministerial Agreement 022)
First Party Certification (SDoC)
Manufacturer’s SDoC, NTE INEN-ISO/IEC
Hazardous waste Generator registration (Ministerial Agreement 022)
Local testing capability
None
Foreign testing labs
Must be members of ILAC
Checking Point
Customs

11. Argentina – General Information
Current Obligations – Battery Certification
Primary batteries
Law as of December 2006
Scope
All primary batteries except Lithium
Includes batteries coming with products
Local testing capability
INTI (National Institute of Industrial Technology)
Applicable Standard
IEC60086
Heavy Metals
Hg < 5ppm, Cd <15ppm, Pb < 200ppm
Checking point
Customs

12. Argentina – General Information
Current Obligations – Battery Stewardship Program
National Level
Do not exist
Provincial Level
Only Buenos Aires City
Resolution 262 as of October 2008
Collection target
None
Capilarity
10 collection points
Stewardship Program
Individual or collective
Conformity Assessment
Medium

13. Argentina – General Information
Future Obligations – Battery Stewardship Program
Legal framework
Presidential Decree
Publication
December 2016, estimated
Nature of the progam
50% Public / 50% Private
Public
Primary collection and temporary storage
40,000 collection points
150 temporary storage facilities
Private
Reverse logistics for treatment/disposal
Scope
Primary and Secondary batteries (including button cells).
Out of Scope: secondary batteries from cellular phones, IT and telecommunciations devices.
Program estimated efficiency
0.5% = 18tn/year
Treatment
Final disposal (3 provincies)
Open loop recycling (Steel and/or Cement Industry)
Exportation (Europe mostly – SNAM)

14. Argentina – General Information
Future Obligations – Battery Stewardship Program
Require for Battery Industry
To grouped behind a collective organization
To finance 50% of the stewardship program by taking care of reverse logistics and treatment/final disposal
Extended requirement
Off the record Ministry of Environment wants Battery Industry to own the whole Stewardship Program
Obstacles – Law perspective
There is not any national stewarship law
Batteries are considered hazardous waste
Big provinces ban domestic importation of hazardous waste
Hazardous waste logistics cost +4 times more than regular logistics
Collection bins and TSF must comply with HW law
Obstacles – Political perspective
Provinces must adhere to this new program and municipalities must implement it. +40% of the country is run by the opposition political party.
Program estimated efficiency
0.5% = 18tn/year
Treatment
Final disposal (3 provincies)
Open loop recycling (Steel and/or Cement Industry)
Exportation (Europe mostly – SNAM)
Costs
UNKNOWN

15. EOF

16. Backup Slides

17. Chile - Impact on Business
Regulation
Take back & Recycling Programs
Can be implemented gradually, but must assure national coverage.
Gradualism will be allowed based on:
General Social and Economic Impact Assessment
Consensus among public, private and civil associations
Public consultation with a minimum duration of 30 days
Regulated subjects must
Be registered in the National Register of Pollutant Emissions and Transfer
Organize and be financially responsible for the nationwide take-back of priority products by means of individual or collective waste management organizations
Subscribe an insurance to assure correct operation of the waste management system (TB&R)
Recycling fee
Priority Products to be collected and treated must be accepted for free by the corresponding TB&R system. In other words, end consumers can not be charged for the recycling of the product.

18. Chile - Impact on Business
IMPORTANT
Reporting obligation
Even though Supreme Decrees for each Priority Product would not be ready; Authorities might required annual performance reports on:
Quantity of products sold
Voluntary TB&R activities and costs
Quantity of collected, treated and disposed products
Whether the TB&R system is individual or collective
Penalties
Serious Violations
Not achieving collection quotas
Not counting with mandatory insurance
Not implementing and adequate TB&R system

19. Ecuador – RTE-105 (1R) – Scope Extended
Tariff Code
Description
85.06
Primary batteries
/ /
Alkaline cylindrical and button cell and others
/ /
Zinc Chloride / Ammonium Chloride
Button cell
Other
/ /
Mercury Oxide
/ / /
Silver Oxide
/ / /
Lithium
/ / /
Zinc Air
VRLA
NiCd
NiFe
NiMH
Li-ion
Others

20. Ecuador - INEN RTE-105 (1R) – Marking Requirements
Battery Type
Marking Requirements
Primary
IEC parts 1,2,3,4 and 5 depending on the battery type, or
ANSI C18.1 part 1 and Part 2, or
NTE INEN 807 parts 1,2,3,4, and 5 depending on the battery type or
ANSI C18.3M part 2 and Part 2
Secondary
NiCd (cylindrical, prismatic and button)
IEC and IEC62133
Sealed NiCd (prismatic)
IEC60622 and EN
Non-sealed NiCd (prismatic)
IEC60623, EN and EN
NiMH (cylindrical, prismatic and button)
IEC and IEC62133
Lithium (portable applications)
IEC61960 and IEC62133
Lithium (industrial applications)
IEC62620
VRLA
IEC , EN and EN
Language
Spanish
Use of sticker or label
Allowed
Label contents
Importer’s record (Tax ID, Address)
Battery type, battery model, caution messages and user instructions

21. Ecuador - INEN RTE-105 (1R) – Testing Methods
Mercury
US EPA 7471B or equivalent
Cadmium
ASTM E536-04a

22. Argentina - Battery Collection Plan 2016 - 2018
Introduction of the Industry Integrated Management System for approval
Industry IMS approval by MMA and the provinces
Implementation of Industry’s IMS
2016
2017
2018
Enero
Marzo
Mayo
Julio
Septiembre
Noviembre
Febrero
Abril
Junio
Agosto
Octubre
Diciembre
Provinces adhere to the national decree
Partial implementation of Industry’s IMS
Collection Program Development
NBP starts (public part, primary collection up to each TSF) Manufacturing and importation restrictions based on membership to the BIT
Government to take care of promotion, eduacation, collection bin delivery, initial primary collection and storage at each TSF
Presidential Decree
Resolution MAyDS
Implementation of Importer’s Registry