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Brazil - Revised Battery Take-Back Rule Includes New Focus on Products Containing Batteries

August 14, 2008

Brazil - Batteries, Product Take-Back, Restricted Substances Overview

CONAMA’s latest revisions to its 1999 battery content and take-back rule include a new focus on products containing batteries. The latest version (the “Draft”), as currently written, would impose new obligations on manufacturers and importers of products containing batteries - in addition to battery manufacturers and importers - that include registration, testing and management plan requirements. The Draft would also impose more stringent heavy metal content limits on batteries, and would keep all batteries, regardless of content, out of household waste bins. Approved by the CONAMA Technical Committee on Health, Environmental Sanitation and Waste Management at its July meeting, the Draft will now be considered by the Legal Affairs Committee at its next meeting. If approved, it will likely be back before the Plenary session for a vote next month. Absent any changes, the Draft will potentially impose significant requirements on numerous consumer products.



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