global environmental legislation guide - National Marine ...

Hong Kong for the reduction of VOC emissions from coating operations on commercialships. This approach relies on defining a set of coating categories which are assignedmaximum VOC limits to each (product based limits). Following a request of those writing theregulation, paint manufacturers have submitted relevant coating categories, definitions andchallenging VOC limits relevant to the Chinese shipbuilding industry.A draft regulation is expected in early 2012. The industry will then have one or two monthsto leave their comments. Following this period, the final draft will be sent to the ChineseMinistry of Environmental Protection for approval. A final regulation is expected in 2012.The yacht market is excluded from this regulation as it only applies to the large commercialshipyards of China. It is unclear whether superyachts are within the scope of the newregulation. At a later stage, coatings applied to oil rigs and similar structures withinshipyards will also be regulated. The drafters have indicated that additional categories andVOC limits relevant to this sector will be added to the pollution regulation at this time.Issues for the recreational marine and superyacht industriesThe Chinese regulations differ from the EU rules (which are based at the average approach),by demanding so-called product based limits. This affects the quality aspects of therecreational marine and superyacht industries.ActionsICOMIA will in close coordination with the paint industry approach the Chineseauthorities in order to lobby the “averaging approach” in the upcoming Chineseshipyard pollution regulation.b. Progress of China RoHS (June 2011) (see EU recasts of RoHS Directives2002/95/EC and 2002/96/EC)Continuous regulatory work has and will be carried out on the subject RoHS by the Chineseauthorities. The following Chinese RoHS standards were adopted in May 2011 and will comeinto force 1 August 2011:Standards on the requirements of concentration limits for certain restrictedsubstances in electrical and electronic productsStandards on electrical and electronic products - measurement of six regulatedsubstances (lead, mercury, cadmium, hexavalent chromium, polybrominatedbiphenyls, polybrominated diphenyl ethers)As of July 2011, Chinese authorities are working on the following RoHS standards whichshould be published shortly:Marking for control of pollution caused by electrical and electronic equipment whichwould replace SJ/T 11364-2006Guidance of risk assessment for substances of certain hazardous substancescontained in electrical and electronic equipmentGeneral rules of the screening of restricted substances in electrical and electronicequipment - X-ray fluorescence spectrometry6