India Chemicals 120521 Final

8/10/2019 India Chemicals 120521 Final

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Environmental Legislation forIndustry Chemicals in India

Produced by Finpro India forTeknologiateollisuus ry

FP00006533

May 8, 2012

Dinkar Krishnan, Finpro ChennaiRekha Salvi, Finpro ChennaiShriya Ramachandran, Finpro Delhi


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Table of Contents

Introduction of the project 3

Executive Summary 4

India REACH 5-17

India RoHS 18-24

India CLP 26-34

Interview Summary 35

Conclusions & Recommendations 37

AppendicesA. Appendix Primary Research ContactsB. Appendix Industry AssociationsC. Appendix Comparison of RoHSsD. References

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08.05.2012 2India - Environment Regulation Industry Chemicals Report 2012 Finpro ry


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Introduction of the ProjectBackground Information / Client Objectives

The Working Group for Environmental Issues of theFederation of Finnish Technology Industries

Tasks include directing influence towards the preparation and

implementation of environmental legislation acting as a consultative body in developing ways of

exerting influence over environmental issues increasing awareness of the use of environmental

aspects in the improvement of competitiveness promoting cooperation between companies,

authorities and other environmental stakeholders.Assignment Objectives / Company benefits To provide the companies with focal information of

requirements of environmental legislation on issuesrelated to products and production in India

The idea is to find out how India have reacted tochemical markings in products as defined in REACH,RoHS, CLP (GHS)

This study gives an overview where the legal aspectsare and what e.g. Finnish companies should take intoaccount when planning exports, starting ownmanufacturing or outsourcing in India. How thegovernmental actions on these issues will affect inindustry and manufacturing

Methodology

Information collection in internet and databases Interviews with governmental officials, industry experts The report s outcome will be presented in a seminar

organized by Teknologiateollisuus

Project team:Teknologiateollisuus ry

Ms. Pirjo Kaivos Ms. Mia Nores-Korkeamki Ms. Carina Wiik

Finpro study team members Mr. Matti Rasimus, Finpro Finland (Project Owner),

[email protected] Eija Tynkkynen, Finpro Beijing, (Project Manager) ,

[email protected] Finpro India study team: Rekha Salvi, Senior Consultant [email protected] Shriya Ramachandran, Marketing & Communications

Manager [email protected] Dinkar Krishnan, Analyst [email protected] www.finpro.fi/finpro-maailmalla/intia

mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]://www.finpro.fi/finpro-maailmalla/intiahttp://www.finpro.fi/finpro-maailmalla/intiahttp://www.finpro.fi/finpro-maailmalla/intiahttp://www.finpro.fi/finpro-maailmalla/intiamailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]


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Executive Summary Regulations and legislations for Chemicals Management in India

not evolved to the level comparable to the levels of European regulations such REACH Overall apathy in the industry towards regulations in Chemicals sector

REACH though companies exporting to Europe satisfy the requirements, no domestic regulations so far same as, orequivalent to REACH

RoHS enacted since June, 2011 CLP planning regulations in line with GHS (draft regulation July, 2011)

The highly fragmented Indian chemicals industry is undergoing restructuring and consolidation phase Export of Chemical through investments in Special Chemical Zones, PCPIR etc

Planned investment of about USD 33 billion

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Large Foreign and IndianChemical Companies

Medium DomesticCompanies

Very Small and SmallDomestic Companies

Highly fragmented industry

Highly fragmented nature of legislations could lead to legal complicationsfor Finnish companies

Indigenous and informal chemical industry is very strong in India, whichdrives the market and also to an extent influences the legislation in theirfavour

Efforts by central government to implement and enforce regulationsare expected to find resistance from industry bodies, making theprocess slow

It is advised to closely monitor the regulatory developments in India oncontinuous basis, to gain more understanding of how the various regulations(such as REACH, RoHS etc) are enacted and implemented

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Overview of India REACH

Indian Chemical Sector A Background

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It has quite recently adopted WEEE/RoHS regulation (June, 2011) and is in the early stages of development of thevarious associated mechanisms

Compliance to REACH, RoHS and CLP in India is currently exclusively for the EXPORTS market, especially toEurope

Companies catering to the domestic market are bound by numerous local legislations that are not as stringent as

REACH Hence this report attempts to understand the Indian Chemical industry holistically, and tries to find how the

REACH, RoHS and CLP legislations would relate to the domestic as well as export market in the future

India's response to Chemical regulations so far

Reluctant participant to most international treaties

In international forums India argues that one size fits all policy is not fair , and developing countries deserve to betreated differently

Sections operate outside global standards in local market No centralized body to monitor REACH preparedness

Many ministries such as Ministries of Chemicals & Fertilizers, Ministry of Commerce and Ministry ofEnvironment & Forests issues guidelines related to environment, safety and so on



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Industry Sector PerspectiveKey Sectors in India: Chemical Industry

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Textile/Apparel Industry :

REACH Helpdesk for Apparel Exporters An initiativesupport by GiZ, Small Industries Development Bank ofIndia SIDBI and Apparel Export Promotion Council

AEPC, India)Indian Apparel Trade with EU: Consists of 6 sub-sectorsincluding,

Knitted and woven outerwear, Bodywear, Sportsclothing, Leather clothing, Fashion accessories

Total Export from India to EU: USD 81.8 billion (Jan-Dec2010)

Leather Industry :

REACH Helpdesk for Leather Exporters provided by TUV SUDSouth Asia Pvt Ltd, on behalf of Council of Leather Exports,Ministry of Commerce & Industry, Govt of India

Annual Turnover of USD 7.5 billion, Export USD 3.84 billionEU accounts for 65.48 of India s Leather and Leather ProductsExports

Policy Framework :

Licensing requirements have been removed, except for hazardous chemicals and a few special drugs 100% FDI is allowed under the automatic route, for all chemicals except hazardous ones

Customs and Excise Duties : Peak customs rate of 7.5% on most chemicals, and excise duty of 16% on almost all chemicals

PCPIR (Petroleum, Chemicals and Petrochemicals Investment Regions) Policy : introduced to boost the development ofchemicals and petrochemicals in investment regions

USD 33 billion proposed investments

Includes SEZs, industrial parks, free trade and warehousing zones, export=oriented units or growth centres



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Overview of Regulations in IndiaOverview of Legal Instruments in India, addressing Chemicals Management

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Production

MSIHC Rules, Petroleum Act & Rules Explosives Act & Rules SMPV Rules Gas Cylinder Rules Insecticides Act & Rules Customs Act & Rules ODS (R&C) Rules

Imports Exports

Storage Transportation

Recycling Use Disposal

Petroleum Act & Rules Explosives Act & Rules Insecticides Act & Rules ODS (R&C) Rules

MSIHC Rules, CA (EPPR) Rules, PLI Act & Rules Explosives Act & Rules SMPV Rules Gas Cylinder Rules Factories Act & Rules Insecticides Act & Rules ODS (R&C) Rules Petroleum Act & Rules

MSIHC Rules, CA (EPPR) Rules, PLI Act & Rules Explosives Act & Rules SMPV Rules Gas Cylinder Rules Factories Act & Rules Insecticides Act & Rules ODS (R&C) Rules Petroleum Act & Rules

CA (EPPR) Rules, PLI Act & Rules, Petroleum Act & Rules Factories Act & Rules Explosives Act & Rules Mines Act & Rules Insecticides Act & Rules Port Act & Rules Dock Act & Rules PFA Act & Rules ODS (R&C) Rules

ODS (R&C) Rules HW (M&H) Rules Batteries Rules

EP Act & Rules Air Act & Rules, Water Act & Rules, HW (M&H) Rules Batteries Rules Insecticides Act & Rules Explosives Act & Rules ODS (R & C) Rules 9

India - Environment Regulation Industry Chemicals Report 2012 Finpro ry


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Overview of Regulations in India

Acts and Rules related to Chemical Industry

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Environmental ManagementChemical Safety and Emergency

ManagementSpecific Chemical

Category/ContainerOthers relevant to Chemicals

Management

The Air (Prevention & Control of Pollution) Act, 1981 amended 1987

The Air (Prevention & Control of Pollution)(Union Territories) Rules, 1983

The Water (Prevention & Control ofPollution) Act, 1974, amended 1988 The Environment (Protection) Act, 1986

amended 1991 Environmental (Protection) Rules, 1986

(amended in 1999, 2001, 2002, 2002, 2002, 2003, 2004) Hazardous Wastes (Management and

Handling) Rules, 1989 amended 2000 and 2003 EIA Notification, 1994 Ozone Depleting Substances (Regulation

and Control) Rules, 2000

Batteries (Management and Handling)Rules, 2001.

Manufacture, Storage and Import ofHazardous Chemicals Rules, 1989

amended 2000 Chemical Accidents (Emergency Planning,

Preparedness and Response) Rules, 1996 Public Liability Insurance Act, 1991

amended 1992 Public Liability Insurance Rules, 1991

amended 1993

The Petroleum Act, 1934 The Petroleum Rules, 2002 The Calcium Carbide Rules, 1987 The Explosives Act, 1884

The Explosives Rules, 1983 The Gas Cylinder Rules, 2004 The Static and Mobile Pressure Vessels

(Unfired) Rules, 1981 The Insecticides Act, 1968 The Insecticides Rules, 1971 The Essential Commodities Act, 1955 The Fertiliser (Control) Order, 1985

Factories Act, 1948 The Motor Vehicles Act, 1988 The Central Motor Vehicles Rules, 1989 The Mines Act 1952

The Customs Act, 1962 The Merchant Shipping Act, 1958amended in 2002 and 2003

Merchant Shipping (carriage of Cargo)Rules 1995

The Indian Ports Act, 1908 The Dock Workers (Safety, Health and

Welfare) Act, 1986 The Dock Workers (Safety, Health and

Welfare) Rules, 1990 Drugs and Cosmetics Act, 1940 The Prevention of Food Adulteration Act,

1954

The National Disaster Management Act,2005 The Prevention of Food Adulteration

Rules, 1955 The Prevention of Terrorism Act, 2002



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India REACH Snapshot

India has not adopted REACH legislation yet, for its domestic market. However, all exporters of chemicals to EU region are required to comply with

REACH and hence, the government supports chemical industry in the compliance requirements of the companies Ministry of Commerce supports the REACH-compliance needs of Indian Chemical companies through CHEMEXCIL REACH-Help desk. Chemexcil is

Basic Chemicals, Pharmaceuticals & Cosmetics Export Promotion Council

Confederation of Indian Industry (CII) along with SSS Europe also provides REACH Support through their Help desk, for Indian companies

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No REACH legislation, or REACH-like legislation in India domestically.

REACH compliance is only for exporters to EU region

REACH directly applies to the European manufacturer and importer of chemicals and chemical containing products and requires them to demonstrate thesafety of their products put into the European markets by submitting detailed information on the intrinsic and toxicological properties of the products to thecentral chemical agency (ECHA)

Therefore, it is but natural that the EU importer shall ask his Indian supplier to furnish the required information and this is how the Indian exporters getimplicated within REACH

If the Indian exporters wish to continue uninterrupted trade with the EU, they shall have to collect all the information, as required within REACH forsubmitting to the ECHA

It is important to note that submission of information to ECHA cannot be done by the Indian exporters

It can either be done by the European importer provided he is willing to act as the registrant or if he refuses to take this responsibility and in certaincases, if the Indian exporter does not wish to share proprietary information relating to his products, he shall have to appoint an only representative

The only representative is the only legal entity authorized to pre-register on behalf of the Indian exporter

Indian REACH just like other non-EU countries



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REACH Europe India

Status

Been in force since June 2007 Not enacted so far for the domestic market.Companies exporting to Europe satisfyREACH requirements through the helpdesks established by trade associations

Impact on the Industry

Substances and articles require registrationif brought into the EU in sufficient volume.Some requirements in REACH apply alsoto articles

Articles containing Substances of VeryHigh Concern (SVHCs) more than 0.1weight-% need to be communicated to thesupply chain (REACH art.33(1)). If anarticle contains more than 0,1 weight-% ofthe SVHC and if the total amount of theSVHC in articles is more than 1 tonne anotification to ECHA is required (Reachart.7(2))

Safe use data and other safety data to beprovided pro-actively

73 SVHCs identified by April, 2012 As of April, 2012, 14 substances are

subject to authorisation. The aim of theauthorisation is that the substance wouldnot be used in Europe anymore

Large volume of data collection

Indian chemical companies, mostly smalland medium companies, complain of highcosts involved in the registration, testingand other such costs for compliance

Companies are sceptical about the capitalcosts of the compliance as well

Since most of the companies serve thedomestic market, many are not keen on thecompliance

Many large Indian companies and foreigncompanies in India have been willing toundergo the compliance process

Comparison of REACH in Europe and India



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Timeline for REACH and CLP Compliance



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India REACH: Similarities and Differencewith EU REACH

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Background from EU-REACH Perspective

Out of the 73 SVHC substances, at the moment 14 are subject to Authorisation. The SVHC list is expected to include moresubstances in the future as Member states suggest more substances for inclusion

EU buyers are have started to demand their suppliers to provide proof that the articles do not contain SVHC's. If an articlecontains an SVHC then the supplier should provide evidence/certify that all requirements in REACH are fulfilled.

SSS, who supports the Help desk in India, based upon its assessment process can provide a certificate of SVHC free articleand in case article contains SVHC then it can facilitate the compliance process as required with REACH and then issue a

certificate of REACH compliance article, that can be then issued to various buyers SSS certified products and chemicals are presently being acknowledged and accepted by over 2000 EU buyers

Approach for Indian Companies for REACH Compliance

SVHC have posed new challenges to article suppliers. Here articles suppliers mean non-EU article exporters, EU importers andmanufacturers of articles.

Under REACH, an article is defined as an object which during production is given a special shape, surface or design, whichdetermines its function to a greater degree that does its chemical composition. e.g. automobile, garments, tires, plasticsproducts, electrical products, handicraft, toys, electronics. Thus, the limitation on SVHCs set out in the REACH regulation, has abroad scope, affecting lots of industries.



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India REACH: Challenges & Outlook

Challenges

The major impact on Indian exporters of chemical substances so far is the high cost of registration, by way of sharing datageneration costs with the lead registrants, running into millions of Euros

Exporters of chemical preparations to Europe also have to bear the burden of getting the ingredient substances registered(again at high cost)

Regarding the impact of REACH on Indian articles like apparel, leather articles, electrical and electronic components, autocomponents, handicrafts, etc, being exported to Europe, there is a grey list of very toxic substances. These SVHCs shall

attract enhanced control and regulation when used for manufacturing of articles like apparel, leather products, autocomponents, dyes, paints, electrical and electronic components and products, metal parts and components, plastic products,etc


Outlook

The implications on the export of articles shall be two-fold:

Manufacturers and exporters of articles shall have to look for alternative safer chemicals; which would amount toincorporating major changes in their product profile

The search for safer substitutes that are not readily available will involve a lot of R&D, trials and expense

These implications are further compounded by the fact that the SVHC list shall keep increasing with time. It is eventuallyexpected to contain 500 to 600 substances

In the case of India-REACH, exporters have to appoint an OR (Only Representative) in the destination country to undertakeboth the registration formalities as well as legal liability on behalf of the exporter


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India REACH: CHEMEXCIL Initiative

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Through a MoU with SSS, the CII Standards and Conformity Assessment Task Force has decided to launch a nation-widecapacity building programme across various export sectors (leather, garments, auto components, etc) to strengthen the supplychain in meeting REACH and other similar regulations

As a first step, experts from the European Chemical Agency (the nodal organization for REACH) have been invited as keyspeakers in two back to back symposiums on REACH Regulations and their impact on Indian industry, in Delhi and Mumbai

The symposiums, being organized jointly by CII and the Union Ministry of Chemicals and Fertilizers, will be the first face-to-face interaction of ECHA officials with Indian industry and other stakeholders

This will be followed by extended outreach programmes targeting impacted sectors over the next year. As deadlines are fastapproaching, the symposiums would provide an ideal forum to obtain clarifications and enhance understanding on coverageas well as compliance issues


CHEMEXCIL, the Chemicals & Cosmetics Export Promotion Council, has set up a REACH help desk and a web portal toprovide the latest updates to exporters. In order to provide professional assistance, CHEMEXCIL has appointed SustainabilitySupport Services, (Europe) AB. Sweden, (SSS) to represent its member-exporters in European Union as Only Representative

This arrangement has helped over 700 Indian companies go through the pre-registration and registration deadlines


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India RoHS


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Overview of India RoHS

RoHS (Restriction of Hazardous Substance) legislation was previously enacted in the European Union, Japan, China, Korea,and California. WEEE (Waste Electrical and Electronic Equipment) legislation was enacted in the EU, Korea, 25 US states,and five Canadian provinces

India has long been plagued by the problem of backyard recycling. India's new legislation is an attempt to address that

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India is the latest country to enact RoHS and WEEE legislation. Hazardous substance and electronic waste legislation is hereto stay and is expanding worldwide

India is now on the list, and its new legislation laid by the Ministry of Environment and Forests, Government of India (coveringboth RoHS and WEEE requirements) is known as the E-Waste (Management and Handling) Rules, 2011. India's WEEErequirements will take effect in May 2012, and its RoHS requirements two years later

(Http://moef.nic.in/downloads/rules-and-regulations/1035e_eng.pdf )

This treats WEEE and RoHS identically in terms of scope, exclusions etc, and there is a considerable similarity with the EU

WEEE and RoHS legislation, although these are treated as totally separate legislation in the EU. The requirements aresimilar to the EU's requirements

The new waste rule will significantly change the way electronic waste is handled in India. Producers, collection centers,dismantlers, and recyclers, to remain operating, will have to apply for a government-issued "Grant of Authorization" by July31, 2012. Onsite storage of electronic waste will be limited to 180 days

The new RoHS rule will limit the amount of hazardous substances present in electronic products produced and imported inIndia ( source CII Reach Help desk and CPCB GUIDELINES FOR ENVIRONMENTALLY SOUND MANAGEMENT OF E-WASTE Report)

http://moef.nic.in/downloads/rules-and-regulations/1035e_eng.pdfhttp://moef.nic.in/downloads/rules-and-regulations/1035e_eng.pdfhttp://moef.nic.in/downloads/rules-and-regulations/1035e_eng.pdfhttp://moef.nic.in/downloads/rules-and-regulations/1035e_eng.pdfhttp://moef.nic.in/downloads/rules-and-regulations/1035e_eng.pdfhttp://moef.nic.in/downloads/rules-and-regulations/1035e_eng.pdfhttp://moef.nic.in/downloads/rules-and-regulations/1035e_eng.pdfhttp://moef.nic.in/downloads/rules-and-regulations/1035e_eng.pdfhttp://moef.nic.in/downloads/rules-and-regulations/1035e_eng.pdfhttp://moef.nic.in/downloads/rules-and-regulations/1035e_eng.pdfhttp://moef.nic.in/downloads/rules-and-regulations/1035e_eng.pdfhttp://moef.nic.in/downloads/rules-and-regulations/1035e_eng.pdfhttp://moef.nic.in/downloads/rules-and-regulations/1035e_eng.pdfhttp://moef.nic.in/downloads/rules-and-regulations/1035e_eng.pdfhttp://moef.nic.in/downloads/rules-and-regulations/1035e_eng.pdfhttp://moef.nic.in/downloads/rules-and-regulations/1035e_eng.pdf


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India RoHS/WEEE Snapshot

India RoHS restricts the same six substances at the same maximum concentrations as in the EU but the scope of products isdifferent as explained below

There is little information provided in the legislation regarding the process for compliance with India RoHS but the RoHSrequirements enter into force two years after this legislation is enacted, which is in May, 2014

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INDIA WEEE

The responsibilities of the various entities, producers, consumers, collection centers, dismantlers and recyclers are definedtogether with the procedures for obtaining registration and authorisation from the pollution control entities including sampleforms

Storage of e-waste is permitted only for a period of 180 days, however this can be extended to a year should there be norecycling facility in that state, or if one is being developed

Labelling is same to that used in EU, except the black bar under the crossed outwheelie bin is not required

INDIA RoHS

Substances Use

Lead (Pb)>


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India RoHS: Similarities and Differenceswith EU RoHS

India RoHS EU RoHS and EU RoHS II (recast)

Legislation Joint for WEEE and RoHS Separate for WEEE and RoHS

LegislationAdopted

May 1 st, 2012 EU RoHS: February 13 th, 2003EU RoHS II (recast): July 1 st , 2011

LegislationEntered into force

May 1 st, 2012 EU RoHS: July 1 st , 2006EU RoHS II (recast): January 2 nd, 2013

LegalResponsibility

ProducersConsumersCollection CentresDismantlersRecyclers

ProducersDistributorsBusiness end usersTreatment facilities for WEEEExporters of WEEE

Business SizeAffected

Does not apply to Micro & Small Enterprises as defined under theMicro, Small and Medium Enterprises Act, 2006 (See Table A inslide no: 23)

All sizes in the categories above

In Scope (i) IT & Telecommunications Equipment All from EU RoHS Cat 3 IT & Telecoms Equipment , except:

CalculatorsPrinter cartridges

Product for collection, storage, processing presentation orcommunicating information electronicallyOther equipment for transmitting sound images or other info by

telecommunicationsii. Consumer electrical & electronicsFrom EU RoHS Cat 1 Large Household Appliances

RefrigeratorsWashing machines

Air-con (not centralised air-con plant)From EU RoHS Cat 4 Consumer Equipment :

Television sets (all types)Note: These are inclusive lists, there is no anything else comment.

Current:1.Large household appliances2.Small household appliances3.IT and telecommunications equipment

4.Consumer equipment5.Lighting equipment, (including electric light bulbs and householdluminaries)6.Electrical and electronic tools (with the exception of large-scalestationary industrial tools)7.Toys, leisure and sports equipment10. Automatic dispensersFollowing the pending recast:8. Medical devices (with the exception of all implanted andinfected products)9. Monitoring and control instruments11. Anything else not covered in categories 1-10



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India RoHS: Similarities and Difference withEU RoHS (Contd)

India RoHS EU RoHS

Out of Scope a) Batteriesb) Radio Active Wastec) Micro & Small Enterprises as defined under the Micro, Small &

Enterprises Development Act, 2006

Currently:a)Military & National Securityb)Electricity not primary power sourcec)Primary function does not need electricityd)Part of another type of equipment that is out of scopee)BatteriesFollowing the pending recast:a)Military equipmentb)Equipment designed to be sent into spacec)Part of another type of equipment that is out of scope

d)Large-scale stationary industrial toolse)Large-scale fixed installationsf)Transportg)Non-road mobile machinery for professional useh)Active implantable medical devicesi)Photovoltaic panels

j)R&D equipment for B2B only

Enforcement Not specified By national enforcement bodies, e.g. in the UKWEEE: Environment Agency, (SEPA, NID ofE)RoHS: NMO (National Measurements Office)

Penalties Not Specified WEEE/RoHS:Fines and costs, plus imprisonment in some EU States. The size offines varies considerably between EU Member States.

RoHS Exemptions (i) See Appendix 2 for a comparison listing.(ii) Note: There are no time limitations for exemptions, no defined

procedure for requesting exemption and no criteria that can beused for justification

A procedure exists for exemption requests which includes definedcriteria that can be used for justification. Time limitations are defined

ComplianceApproach

WEEE: Application to the State Pollution Control Board or local PollutionControl Committee

RoHS: The approach is unclear for RoHS but it is required to includeinformation on RoHS substances in instruction manuals

WEEE MS individually interpret the directive, requirements varyconsiderably and include registration, membership of complianceschemes

RoHS EU-wide consistent interpretation, although there are some

areas where EU States have different interpretations. Complianceby self-declaration using documentation



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India RoHS: Similarities and Differenceswith EU RoHS (Contd)

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Business Size Business Area Investment

MicroManufacturing < INR 2.5 million Approx


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India RoHS: Similarities and Differenceswith EU RoHS (Contd)

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Categories of E-Waste covered under the rule e-waste (Management and Handling) Rules, 2010 Schedule 1

Sl. No. E-Waste Categories

1 IT and Telecommunication Equipment:Centralised data processing:Mainframes, minicomputersPersonal computing:Personal computers (CPU with input and output devices)Laptop (CPU with input and output devices)Notebook, Notepad etc.,

Printers including cartridgesCopying equipmentElectrical and electronic typewritersPocket and desk calculators

And other products and equipment for the collection, storage, processing, presentation or communication of information byelectronic meansUser terminals and systemsFacsimileTelexTelephonesPay telephonesCordless telephonesCellular telephones

Answering systems And other products or equipment of transmitting sound, images or other information by telecommunications

2 Consumer electrical and electronics:Television sets (including LCD & LED), Refrigerator, Washing Machine, Air-conditioners

(For Schedule II and III, please go to the hyperlink given in Slide 19)23India - Environment Regulation Industry Chemicals Report 2012 Finpro ry


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India RoHS: Challenges and Outlook

Challenges Lack of clarity on how RoHS would be adopted by companies (include producers, distributors, collection centres,

refurbishers, dismantlers, recyclers, consumers, or bulk consumers) involved in the manufacture, sale, purchase andprocessing of electrical and electronic equipment or components

The real problem India faces is a thriving backyard recycling industry (informal sector). E-waste is collected by recyclersabroad and then sold to waste traders in India

The complexity of e-waste flows within India and inadequate record-keeping (maintenance of registry) make anestimation of the quantities and composition of e-waste within India, making enforcement of legislation difficult

The draft rule does not specify how it will ensure that informal recyclers reduce their operations to dismantling andcollection activities. Furthermore, the underlying incentives that can result in the informal sector being able to outbid theformal sector remain unaddressed

A lack of awareness of the hazards of improper e-waste disposal, at the consumer-level, collector-level or recycler-levelor disposer-level

Inadequate monitoring and enforcement mechanisms

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Outlook Many electronic companies are willing to comply with the requirements

It is expected that Indian companies will be more open to complying with RoHS than REACH

The various regulations that are at various stages of enactment and implementation tries to achieve the broaderobjectives similar to EU and the US regulations. Considering all the challenges mentioned above, it will be a tough taskfor the government and regulatory bodies to achieve full adherence and compliance



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Overview of India CLP

08.05.2012

India is expected to publish by mid-2012 rules governing the labelling of hazardous chemicals, in line with the UN GHSrequirements

The draft rules were released in July, 2011 for comments from interested groups. Ministry of Environment and Forests is nowworking on the final document (Rule called as Hazardous Substances (Classification, Packaging and Labelling) Rules, 2011;draft notification dated 8 th July, 2011. http://moef.nic.in/downloads/rules-and-regulations/SO523_E_new.pdf )

India s approach would be to implement new rules that are entirely in agreement with the UN or partially fulfil the UN mandate

India currently uses a combination of lists and laws to classify chemicals and govern their storage and handling

For example, one current law is the Manufacture, Storage and Transport of Hazardous Chemical Rules of 1989 whose rulesdo not conform to GHS. But efforts are to be made to radically revise these rules to avoid conflict and confusion with the newGHS rules that would be introduced

Status of GHS Implementation in India

Some of the salient points of India s new HS (CPL) rules are:

Responsibilities in the supply chain to be prescribed

All dangerous goods will have to have a UN number and proper shipping name according to their assigned hazard

classification and composition Suitable labelling and packaging will have to be used, along with updated safety data sheets

People engaged in the handling, storage and transport of dangerous goods will have to be trained

The consultation of the draft law has received a great deal of technical specifications, including how inflammable liquids andmixtures of gases must be dealt with and more detailed definitions of what constitutes a toxic dose and how to determinelevels of flammability

http://moef.nic.in/downloads/rules-and-regulations/SO523_E_new.pdfhttp://moef.nic.in/downloads/rules-and-regulations/SO523_E_new.pdfhttp://moef.nic.in/downloads/rules-and-regulations/SO523_E_new.pdfhttp://moef.nic.in/downloads/rules-and-regulations/SO523_E_new.pdfhttp://moef.nic.in/downloads/rules-and-regulations/SO523_E_new.pdfhttp://moef.nic.in/downloads/rules-and-regulations/SO523_E_new.pdfhttp://moef.nic.in/downloads/rules-and-regulations/SO523_E_new.pdfhttp://moef.nic.in/downloads/rules-and-regulations/SO523_E_new.pdfhttp://moef.nic.in/downloads/rules-and-regulations/SO523_E_new.pdfhttp://moef.nic.in/downloads/rules-and-regulations/SO523_E_new.pdfhttp://moef.nic.in/downloads/rules-and-regulations/SO523_E_new.pdfhttp://moef.nic.in/downloads/rules-and-regulations/SO523_E_new.pdfhttp://moef.nic.in/downloads/rules-and-regulations/SO523_E_new.pdfhttp://moef.nic.in/downloads/rules-and-regulations/SO523_E_new.pdfhttp://moef.nic.in/downloads/rules-and-regulations/SO523_E_new.pdfhttp://moef.nic.in/downloads/rules-and-regulations/SO523_E_new.pdf


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Evolution

Similar to REACH, CLP legislation also is not yet present in India as of now (Rule in the draft stage)

Only exporters of Chemicals to EU region comply to REACH and CLP requirements

However, agencies such as Chemexcil and REACH Support Helpdesk are assisting Indian companies to comply to theserequirements

Moreover, these agencies are helping create awareness among the domestic industry participants to move towards thesecompliance requirements

Various activities for implementing the GHS system in India is underway

Instead of CLP, there are a host of legislations and acts that determine the classification, labeling and packaging especiallythose that deal with Chemicals. Some of these regulations are,

08.05.2012

Central motor Vehicle Rule-1989 and some relevant Statutory Provisions R-129 : Transportation of Hazardous Goods nature R-129A : Spark Arrestor Provision

R-130 : Manner of display of class labels R-131 : Responsibility of Consignor for safe transportation of Hazardous Goods R-132 : Responsibility of Transporter & Owner for safe transportation of Hazardous Goods R-133 : Responsibility of Driver for safe transportation of Hazardous Goods R-134 : Emergency Information Panel. R-135 : Drivers to be instructed. R-136 : Report of accidents by Driver to Police Station.

R-137 : Display of Class Labels.27India - Environment Regulation Industry Chemicals Report 2012 Finpro ry


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08.05.2012

Manufacture, Storage & Import of Hazardous Chemicals -1989 (Under Environment Protection Act) Quantity based approach in management of Hazards Rules On-Site plans for installations having hazardous substances more than Threshold Quantities Safety Report for Bulk Storages

Legislations in India that relate to CLP

Other Legislations The Hazardous Wastes (Management & Handling) Rules 1989 Motor Vehicles Act - 1988 & Rules thereunder ( Safety in transportation of Hazardous substances) The petroleum and Explosive Act - 1984 & Rules ( Safety in handling of Petroleum and Petrochemical including bulk storages) Factories Act -1948 ( Safety In Manufacturing Activity)

The Emergency Planning , Preparedness & Response For Chemical Accidents Rules-1995

The Public Liability Insurance Act & Rules- 1991 ( Payment Of Compensation To The Outsiders In Respect Of Major IncidentsIn Factories)



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08.05.2012

Schedules 1 : How to identify Toxic, Flammable , Explosive Chemicals Schedules 2 : List of Hazardous Chemicals Schedules 3 : Classification of Chemicals based on UN Numbers

Schedules Under Motor Vehicles Act 1988

Sl.No. Chemicals Schedule1 Schedule2 Schedule312345

6789101112

ToxicFlammableFlammable gasesHighly flammable liquidsFlammable liquids

ExplosiveCorrosiveOxidizingReactiveGasses compressedInfectious substancesRadioactive substance

Y-YYY

Y------

YY---

YYYY---

----Y

YYY-YYY

Schedules 3 1. Correct Technical Name2. U N Number

3. HAZCHEM Code4. Class Labels5. Emergency Dial6. Special Advice ,if any

Emergency Information Panel (EIP)



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Classification and Labelling in India

08.05.2012

CLASS-1 : EXPLOSIVES e.g. TNT, Symbol-Exploding bomb with orange background

Class Labels of Dangerous Goods under Motor Vehicles Act - 1988

CLASS-2.1 : FLAMMABLE GASES e.g. LPG, Hydrogen, Symbol-white flame with red

background

CLASS-2.2 : NON-FLAMMABLE GASESe.g. Chlorine, Nitrogen, Symbol-black cylinder with green

background

CLASS-3 : FLAMMABLE LIQUIDSe.g. Petrol, Symbol-white flame with red background



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08.05.2012

CLASS-4 : FLAMMABLE SOLIDSe.g. Calcium carbide, sulphur, Symbol-black flame with red &

white vertical stripes background


CLASS-5.1 ORGANIC PEROXIDEe.g. Hydrogen Peroxide, Symbol-black flame above circle , yellowbackground

CLASS-5.2 OXIDIZING AGENTe.g. KMnO4

CLASS- 6 POISON (TOXIC)GASe.g. Chlorine, H2S, CS2; Symbol-black skull with crossbones

with white background



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08.05.2012

CLASS-7:RADIOACTIVE SUBSTANCESe.g. Uranium, Radium


CLASS-8 :CORROSIVEe.g. Hydrochloric Acid, Sulphuric acid, Caustic Soda

Sl. No. Degree ofToxicity Oral ToxicityLD 50 (mg/kg)

Dermal

Toxicity LD 50(mg/kg)

Inhalation

Toxicity LC 50(mg/l)

1 ExtremelyToxic

0.5 2.0

3 Toxic >50 200 >200 1000 >2 10

The Manufacture, Storage and Import of Hazardous Chemicals Rules, 1989(Schedule-I), Indicative Criteria and List of Toxic Chemicals



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India CLP Snapshot

Current Way of Adherence to CLP

Appoint an Only representative (OR) who is a European legal entity Provide the OR with necessary technical information to finalize the CLP notification dossier OR shall compile the CLP notification in the IUCLID Software The CLP notification dossier shall then be submitted to the ECHA through the REACH-IT system



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Interview SummaryConclusionsRecommendations


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Interview Summary

Some quotes

08.05.2012

The major concerns and thrust areas of environmental pollution, at present, are hazardous waste handling, its storage anddisposal and minimisation of volatile organic compounds, besides ensuring proper operation and maintenance of pollutioncontrol devices.Various ministries are involved in implementation of respective Acts and Rules related to chemicals management. It is,therefore, necessary to have more inter-ministerial commissions and coordination mechanisms.

Suppliers in unorganized sector have little knowledge of REACH. Unlike mass manufacturers like China, testing perconsignment for fashion garments is much more difficult and costly. India specialises in fashion garments, with lot of valueadditions and embellishments. Compliance requires testing of these embellishments also.

A manufacturer supplying small lots of such products to EU will incur very high testing charges. REACH regulations will have along lasting implication on the Indian apparel industry.

There is a recommendation to, in future, merge all related regulations for having uniform standards. India is contemplatingREACH specific to India. But so far it has not been enacted. Small and medium companies in the sector are completelyunaware of REACH and such regulations. They are also sceptical of the high costs involved, as they operate on very lowmargins already

The REACH and CLP market in China is much more matured than in India, as China is hosts a large number of Europeanbusinesses. India has seen an increase over the last few years in the awareness and sensitivity towards product relatedenvironmental issues.

Some of the priority actions proposed for India are, prepare Indian chemical inventory (none exists today), improve co-ordination at central government level amongst ministries, create laboratory infrastructure, augment human resources (-- Comments from industry experts)



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Conclusions & Recommendation

Identified that the chemical sector in India requires to go a long way towards REACH and CLP regulations

RoHS regulations have been enacted. However, full scale implementation and compliance is expected toface stiff challenges from the industry

Large number of small and medium companies in the sector makes data gathering difficult one of thekey reasons why implementation of such comprehensive regulations have been difficult in India

Some of the administrative hurdles of the regulations many ministries such as Ministry of Commerceand Industry, Ministry of Chemicals and Fertilizers, Ministry of Environment & Forests, Ministry of Financeetc, deliberating on the hierarchy and decision-making authority on chemicals management in India

India has its own set of legislations and regulations which are getting evolved. Many government agenciessuch as the Pollution Control Boards (Central and state level) are enforcing many of these regulations in astrict manner now

It needs to be seen how the many regulations will evolve into a comprehensive legislation similar toREACH

It is advised to closely monitor the regulatory developments in India on continuous basis, to gain moreunderstanding of how the various regulations (such as REACH, RoHS etc) are enacted and implemented



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Appendices


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Appendix A Primary Research Contacts

Mr. J. S. Kamyotra, Member Secretary, Central Pollution Control Board (CPCB) Ms. Chandrima Chatterjee, Director, Economic & Consultancy, Apparel Export Promotion Council (APEC)

Mr Vivek Gupta, Chemical Engineer, IIT Delhi

Dr Rashmi Naidu, Director (Technical Services), REACH Support , For Sustainability Support Services (Europe) AB

Mr. Sanjay Bansal, Director, Department of Chemicals & Petrochemicals, Ministry of Chemicals & Fertilizers,Government of India

Mr. Rajaram Vijayan, IIT Kharagpur, ex-Frost & Sullivan, ex-Novozymes, lifetime member of Indian Institute of

Chemical Engineers



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Appendix B Industry Associations

08.05.2012

Industry Associations

Indian Chemical CouncilSir Vithaldas Chambers, 16-Mumbai Samachar Marg,Mumbai 400023Phone: 91 22 22047649/ 22846852Fax: 91 22 22048057Website: www.icmaindia.com

Alkali Manufacturers Association of India3rd Floor, Pankaj Chambers,Preet Vihar Commercial Complex,VikasMarg,New Delhi 110092Phone: 91 11 22432003, 22410150, 55253401Fax: 91 11 22468249

Website: www.ama-india.org

Indian Specialty Chemical Manufacturers' Association1156, Bole Smruti, Suryavanshi Kshatriya Sabhagriha Marg,Off. Veer SavarkarMarg, Dadar(West)Mumbai 400 028Tel: 91 22 2446 5003

Website: www.iscma.in39India - Environment Regulation Industry Chemicals Report 2012 Finpro ry


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Appendix C Comparison of EU RoHS andIndia RoHS (Continuation from Slide No: 21)

Exemption Nr

Description Scope and dates of applicability

In Europe In India EU-RoHS Recast

1 Mercury in single capped (compact) fluorescentlamps not exceeding (per burner):

1(a) For general lighting purposes


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Appendix C (Contd.)Exempti

on Nr Description

Scope and dates of applicability In Europe In India EU-RoHS Recast

2(a)(1) Tri-band phosphor with normal lifetime and a tubediameter 17 mm and 28 mm (e.g. T8) 5 mg

Expires on 31 st Dec 20113.5 mg may be used per lampafter 31 Dec 2011

Limited to 3.5 mgNo timescale specified

2(a)(4) Tri-band phosphor with normal lifetime and a tubediameter >28 mm (e.g. T12)


No weight reduction to3.5 mg specifiedNo timescale specified

Expires on 31st Dec,2012: 3.5 mg/lampafter 31st Dec, 2012

2(a)(5) Tri-band phosphor with normal lifetime and a tubediameter 9 mm and 17 mm (e.g. T5)


No weight reduction to5 mg specifiedNo timescale specified

2(b)Mercury in other fluorescent lamps not exceeding(per lamp):

2(b)(1) Linear halophosphate lamps with tube >28mm

(e.g. T10 and T12) Expires on 13 Apr 2012

No expiry date

specified

Expires on 13 April,

20122(b)(2)

Non-Linear halophosphate lamps (all diameters)15mg

Expires on 13 Apr 2016 No expiry datespecified

Expires on 13 April,2016

2(b)(3) Non-Linear tri-band phosphor lamps with tubediameter >17 mm (e.g. T9)

No limitations of use until 31Dec 201115 mg may be used per lampafter 31 Dec 2011

Limited to 15 mgNo timescale specified

2(b)(4) Lamps for other general lighting and special

purposes (e.g. induction lamps)

No limitation of use until 31 Dec2011

15 mg may be used per lampafter 31 Dec 2011

Limited to 15 mgNo Timescalespecified



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Appendix C (Contd.)Exemptio

n Nr Description


3 Mercury in cold cathode fluorescent lampsand external electrode fluorescent lamps(CCFL and EEFL) for special purposes notexceeding (per lamp):

3(a) Short length (500mm) No limitation of use until 31 Dec 20113.5 mg may be used per lamp after 31Dec 2011

Limited to 3.5 mg No timescalespecified

3(b) Medium length (> 500 mm and 1500 mm) No limitation of use until 31 Dec 20115 mg may be used per lamp after 31 Dec

2011

Limited to 5 mgNo timescale

specified 3(c) Long length (>1500 mm) No limitation of use until 31 Dec 2011

13 mg may be used per lamp after 31Dec 2011

Limited to 13 mgNo timescalespecified

4(a) Mercury in other low pressure dischargelamps (per lamp)

No limitation of use until 31 Dec 201115 mg may be used per lamp after 31Dec 2011

No weight limitNo timescalespecified

4(b) Mercury in High Pressure Sodium (vapour)lamps in general lighting purposes not

exceeding (per burner) in lamps withimproved colour rendering index Ra>60:

4(b)-I P 155 W No limitation of use until 31 Dec 201130 mg may be used per burner after 31Dec 2011


4(b)-II 155 W < P 405W No limitation of use until 31 Dec 201140 mg may be used per burner after 31Dec 2011


4(b)-III P > 405 W No limitation of use until 31 Dec 2011

40 mg may be used per burner after 31Dec 2011

Limited to 40 mg

No timescalespecified 08.05.2012 42India - Environment Regulation Industry Chemicals Report 2012 Finpro ry


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n Nr Description


4(c) Mercury in other High Pressure Sodium(vapour) lamps for general lighting purposesnot exceeding (per burner):

4(c)-I P 155 W No limitation of use until 31 Dec 201125 mg may be used per burner after 31Dec 2011


4(c)-II 155 W < P 405W No limitation of use until 31 Dec 201130 mg may be used per burner after 31Dec 2011


4(c)-III P > 405 W No limitation of use until 31 Dec 201140 mg may be used per burner after 31Dec 2011


4(d) Mercury in High Pressure Mercury (vapour)lamps (HPMV)

Expires on 12 April 2015 No timescalespecified

Expires on 13th April, 2015

5(a) Lead in glass of cathode ray tubes

5(b)Lead in glass of fluorescent tubes notexceeding 0.2% by weight

6(a)

Lead as an alloying element in steel for

machining purposes and in galvanized steelcontaining up to 0.35% lead by weight

6(b)Lead as an alloying element in aluminiumcontaining up to 0.4% lead by weight

6(c) Copper alloy containing up to 4% lead byweight

7(a)Lead in high melting temperature type solders(i.e. lead based alloys containing 85% byweight or more lead



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n Nr Description


7(b)Lead in solders for servers, storage and storagearray systems, network infrastructure equipmentfor switching, signalling, transmission, andnetwork management for telecommunications

7(c)-I

Electrical and electronic components containinglead in a glass or ceramic other than dielectricceramic in capacitors, e.g. piezoelectronicdevices, or in a glass or ceramic matrixcompound

7(c)-II Lead in electric ceramic in capacitors for a ratedvoltage of 125 V AC or 250 V DC or higher

7(c)-III Lead in dielectric ceramic in capacitors for arated voltage of less than 125 V AC or 250 V AC

Expires on 1 Jan 2013 After that date may be used in spareparts for EEE placed on the marketbefore 1 Jan 2013

No expiry date

Expires on 1st Jan,2013, after that maybe used in spareparts for EEEplaced on themarket before 1stJan, 2013

7(c)-IV Lead in PZT based dielectric ceramic materialsfor capacitors being part of integrated circuits ordiscrete semi-conductors

Approved by council 16 May 2011,not yet in force

Not yet included

8(a)Cadmium and its compounds in one shot pellettype thermal cut-offs

Expires on 1 Jan 2012 After that date may be used in spareparts for EEE placed on the marketbefore 1 Jan 2012

No expiry date

Expires on 1st Jan,2012, after that maybe used in spareparts for EEEplaced on themarket before 1st

Jan, 201208.05.2012 44India - Environment Regulation Industry Chemicals Report 2012 Finpro ry


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n Nr Description


8(b) Cadmium and its compounds in electrical contacts

9Hexavalent chromium as an anticorrosion agent of the carbonsteel cooling system in absorption refrigerators up to 0.75% byweight in the cooling solution

9(b)Lead in bearing shells and bushes for refrigerant containingcompressors for heating, ventilation, air conditioning andrefrigeration (HVACR) applications

10 Item of EU RoHS Annex no Longer Applicable

11(a) Lead used in C-press compliant pin connector systems

May be used in spareparts for EEE placed onthe market before 24Sept 2010

No Expiry Date

11(b) Lead used in other than C-press compliant pin connectorsystems

Expires on 1 Jan 2013 After that date may beused in spare parts forEEE placed on themarket before 1 Jan2013

No expiry dateNo conditions foruse

12 Lead as a coating material for the thermal conduction moduleC-ing

May be used in spareparts for EEE placed onthe market before 24Sept 2010

No conditions foruse

13(a) Lead in white glasses used for optical applications

13(b)Cadmium and lead in Filter glasses and glasses used forreflectance standards



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n Nr Description


14

Lead in solders consisting of more than two elements for theconnection between the pins and the package ofmicroprocessors with a lead content of more than 80% and lessthan 85% by weight

Expired on 1 Jan 2011 After that date may beused in spare parts forEEE placed on themarket before 1 Jan2011

No expiry dateNo conditions foruse

These may only beused in spare partsfor EEE placed onthe market before1st Jan, 2011

15 Lead in solders to complete a viable electrical connectionbetween semiconductor die and carrier within integrated circuitflip chip packages

16 Lead in linear incandescent lamps with silicate coated tubes Expires on 1 Sept 2013 No expiry date 17

Lead halide as radiant agent in high intensity discharge (HID)lamps used for professional reprography applications

18(a)

Lead as activator in the fluorescent powder (1% lead by weightor less) of discharge lamps when used as speciality lamps fordiazoprinting reprography, lithography, insect traps,photochemical and curing processes containing phosphorssuch as SMS ((Sr,Ba) 2 MgSi 2 O 7:Pb)

Expired on 1 Jan 2011 No expiry date

18(b)

Lead as activator in the fluorescent powder (1% lead by weight

or less ) of discharge lamps when used as sun tanning lampscontaining phosphors such as BSP (BaSi 2 O 5:Pb)

19 Lead with PbBiSn-Hg and PblnSn-Hg in specific compositionsas main amalgam and with PbSn-Hg as auxiliary amalgam invery compact energy saving lamps

Expired on 1 June 2011 No expiry date

20 Lead oxide in glass used for boding front and rar substrates offlat fluorescent lamps used for Liquid Crystal Displays (LCDs)

Expired on 1 June 2011 No expiry date

21 Lead and Cadmium in printing inks for the application ofenamels on glasses, such as brosilicate and soda lime glasses



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n Nr Description


22 Exemption expired in EU, not included in India

23 Lead in finishes of fine pitch components other than connectorswith a pitch of 0.65 mm and less

May be used in spareparts of EEE placed onthe market before 24Sept 2010

No conditions foruse

May only be usedin spare parts forEEE placed onthe market before24 th Sep, 2010

24 Lead in solders for the soldering to machined through holedicoidal and planar array ceramic multilayer capacitors

25 Lead oxide in surface conduction electron emitter displays(SED) used in structural elements, notably in the seal frit andfrit ring

26 Lead oxide in the glass envelope of black light blue lamps Expired on 1 June 2011 No expiry date

27 Lead alloys as solder for transducers used in high powered(designated to operated for several hours at acoustic powerlevels of 125 dB SPL and above) loudspeakers

Expired on 24 Sept2011

No expiry date

28 Exemption expired in EU, not included in India

29 Lead bound in crystal glass as defined in Annex I (Categories1,2,3 and 4) of Council Directive 69/493/EEC

No definition in India

WEEE/RoHS towhich to refer

30

Cadmium alloys as electrical/ mechanical solder joints toelectrical conductors located directly on the voice coil intransducers used in high-powered loudspeakers with soundpressure levels of 100dB(A) and more

31 Lead in soldering materials in mercury free flat fluorescentlamps (which e.g. are used for liquid crystal displays, design orindustrial lighting)



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Appendix C (Contd.)

Exemption Nr

Description Scope and dates of applicability

In Europe In India EU-RoHS Recast

32Lead oxide in seal frit used for making window assemblies for

Argon and Krypton laser tubes

33 Lead in solders for the soldering to thin copper wires or 100mdiameter and less in power transformers

34 Lead in cermet-based trimmer potentiometer elements

35 Cadmium in photoresistors for analogue optocouplers appliedin professional audio equipment

Old exemption expired31 Dec 2009Replacement

exemption proposed byEC Feb

Not yet included

36 Mercury used as a cathode sputtering inhibitor in DC plasmadisplays with a content up to 30 mg per display

Expired on 1 July 2010 No expiry date

37 Lead in the plating layer of high voltage diodes on the basis of azinc borate glass body

38Cadmium and cadmium oxide in thick film pastes used onaluminium bonded beryllium oxide

39Cadmium in colour converting II-VI LEDs (


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Appendix D

08.05.2012

References

Ministry of Chemicals and Fertilizers (http://chemicals.nic.in) Ministry of Environment and Forests (http://moef.nic.in/index.php) Chemexcil (http://www.chemexcil.gov.in) http://www.indianchemicalportal.com/chemical-associations/ http://chemexcil-reachhelp.com/index.php http://www.leatherindia.org/reach-related-services-to-members.asp Other relevant news and articles

http://www.leatherindia.org/reach-related-services-to-members.asphttp://www.leatherindia.org/reach-related-services-to-members.asphttp://www.leatherindia.org/reach-related-services-to-members.asphttp://www.leatherindia.org/reach-related-services-to-members.asphttp://www.leatherindia.org/reach-related-services-to-members.asphttp://www.leatherindia.org/reach-related-services-to-members.asphttp://www.leatherindia.org/reach-related-services-to-members.asphttp://www.leatherindia.org/reach-related-services-to-members.asphttp://www.leatherindia.org/reach-related-services-to-members.asphttp://www.leatherindia.org/reach-related-services-to-members.asp


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