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Implementing the Export and Import of Hazardous Waste and Hazardous Recyclable Material Regulations - Draft User GuideEnvironment Canada TABLE OF CONTENTS
LIST OF TABLES
AbbreviationsCBSA: Canada Border Services Agency CEPA 1999: Canadian Environmental Protection Act, 1999 EIHWHRMR: Export and Import of Hazardous Waste and Hazardous Recyclable Material Regulations EIHWR: Exports and Import of Hazardous Waste Regulations ID: Identification IWIC: International Waste Identification Code OECD: Organisation for Economic Co-operation and Development PIN: Product Identification Number POP: persistent organic pollutant TDGR: Transportation of Dangerous Goods Regulations TMB: Transboundary Movement Branch (Environment Canada) UN: United Nations US: United States 1. Introduction1.1 BackgroundIn Canada, all three levels of government contribute to environmental protection and have a role to play in waste management:
Through domestic regulations under the authority of the Canadian Environmental Protection Act, 1999 (CEPA 1999), the Federal Government implements the terms of international agreements to which Canada is a party. Implementing the terms of these agreements demonstrates the intention to protect Canada's environment and the health of Canadians from risks posed by unregulated traffic in hazardous wastes and hazardous recyclable materials. Canada is party to three international agreements regarding the transboundary movement of hazardous wastes and hazardous recyclable materials:
In signing these international agreements, Canada made a commitment to develop national legislation to promote the environmentally sound management of hazardous wastes and hazardous recyclable materials. This led to the development of the Export and Import of Hazardous Wastes Regulations (EIHWR), which came into force on November 26, 1992, under the former CEPA. The revised Export and Import of Hazardous Waste and Hazardous Recyclable Material Regulations (EIHWHRMR) revoked and replaced the EIHWR in November 2005. The EIHWR required modification because a number of changes have occurred both domestically and internationally since 1992. Among these was the entry into force of CEPA 1999, which included new authorities with respect to hazardous wastes and hazardous recyclable materials that did not exist under the former CEPA. By implementing these new authorities and modernizing the former control regime, the EIHWHRMR help Canada adapt to its evolving international obligations, and contribute to the protection of the environment and human health. 1.2 What Is the Purpose of This Guide?This guide is designed to help people who are involved in international movements of hazardous wastes and hazardous recyclable materials in Canada understand and implement the requirements of the EIHWHRMR (also referred to in this document as "the Regulations"). It will be useful to anyone who generates, handles, transports, treats, recycles, stores, or disposes of hazardous wastes or hazardous recyclable materials where international shipments are involved. 1.3 How Do I Use This Guide?This guide is divided into 15 sections, each dealing with a different aspect of the EIHWHRMR. Each section provides answers to the most common questions about the various provisions of the Regulations; however, in the event of a discrepancy between this guide and the Regulations, the EIHWHRMR take precedence. 2. GENERAL INFORMATION
2.1 What Is the Purpose of the Regulations?The purpose of the Regulations is to
The Regulations set out the conditions for the export, import, and transit of hazardous wastes and hazardous recyclable materials shipped across the Canadian border. This helps to ensure that shipments of wastes and recyclable materials entering into, leaving, or passing through Canada can be tracked and controlled by Environment Canada, with the assistance of other government agencies. The Regulations also ensure that exports of Canadian hazardous wastes and hazardous recyclable materials have been consented to by the receiving country before any shipment takes place. In the case of imports into Canada, the provinces provide authorization for recycling or disposal operations at authorized facilities. The Regulations are administered by the Transboundary Movement Branch (TMB) of Environment Canada. All documents required by the EIHWHRMR should be sent to TMB (see Annex D). The main goals of the Regulations include
2.2 How Do the Regulations and CEPA 1999 Work Together?Neither the CEPA 1999 waste authorities nor the conditions of the EIHWHRMR can be used exclusively; rather the two must be applied together in order to ensure compliance. CEPA 1999 builds on the government's authority to enact regulations governing the export, import, and transit of hazardous wastes and hazardous recyclable materials. It includes a number of provisions for the transboundary movement of hazardous wastes and hazardous recyclable materials. Section 185 of CEPA 1999 requires that the Minister be notified of any intended international shipment of hazardous wastes or hazardous recyclable materials. An international movement may consist of an export from Canada, an import into Canada, a transit through Canada, or a transit through a country other than Canada. The notification requirements are set out in the Regulations, and include such information as
With this information, Environment Canada is able to determine whether the proposed shipment of hazardous wastes or hazardous recyclable materials complies with regulations for the protection of human health and the environment. If the notification requirements set out in the Regulations are met, Environment Canada notifies the authorities in the jurisdiction of destination. If any authority (including those in any transit countries) objects to the proposed shipment, the shipment cannot proceed until the objection is lifted. A permit may be granted following a review of the notice and approval from the authorities in the jurisdiction of destination. Every shipment of hazardous wastes or hazardous recyclable materials must be accompanied by a copy of the movement document and permit (and any other required permit), and must be shipped according to the requirements set out in both the EIHWHRMR and the Transportation of Dangerous Goods Regulations (TDGR). The appropriate documents must also be deposited at Canada Customs. The Canadian importer or Canadian exporter of the hazardous wastes or hazardous recyclable materials must return a completed copy of the movement document to Environment Canada within three working days of the delivery of a shipment. The disposal or recycling must take place within the time specified in the Regulations, and the Canadian importer or Canadian exporter must ensure that a statement is sent to Environment Canada within 30 days of this operation, certifying that it has been completed in accordance with the permit. If, after the international shipment has begun, the wastes or materials cannot be disposed of or recycled in the manner stated in the permit, the appropriate authorities must be notified and alternate arrangements made with the consent of the countries involved. If no such arrangements can be made, the shipment may be returned after a new permit has been issued for the purposes of a return. 2.3 How Are the Regulations Set Up?The Regulations are divided into six parts:
Ten schedules form part of the Regulations:
Schedules 1 and 2 specify the disposal and recycling operations that are subject to the Regulations. These operations are meant to implement the disposal and recycling operations set out under both the Basel Convention and OECD Decision C(2001)107/Final. Schedules 3, 4, and 7 list hazardous wastes and hazardous recyclable materials that are subject to the Regulations. The identification numbers must be provided as part of the notification under the Regulations. Schedules 5 and 6 list constituents that may be contained in waste or material at concentrations that would render them hazardous. The identification numbers must be provided as part of the notification under the Regulations. Schedule 10 lists the names of persistent organic pollutants (POPs) and the triggers for the declaration of POPs within a hazardous waste or hazardous recyclable material.1 2.4 Who Is Affected by the Regulations?The Regulations affect all persons and organizations involved in some aspect of the import, export, or transit of hazardous wastes or hazardous recyclable materials in Canada. The Regulations define the responsibilities of exporters, importers, and carriers. 2.5 Which Authorities Are Involved?The Regulations are administered by Environment Canada. The competent authority for all Canadian imports, exports, and transits is the Environment Canada's TMB, which is also the contact point for the competent authorities in other countries. Provincial and foreign authorities need not be contacted directly during the notification process; rather, they will respond to a notice by contacting Environment Canada, who will then forward the response to the notifier. The role of Environment Canada includes
Two other federal agencies are involved in the compliance and administration of the Regulations. One is Transport Canada, since shipments may be subject to the TDGR; the other is the Canada Border Services Agency (CBSA), which helps to control hazardous wastes and hazardous recyclable materials crossing the border by ensuring that the proper documents accompany each shipment. The shipment of hazardous wastes or hazardous recyclable materials must also conform with provincial/territorial laws and regulations. All imports into Canada are subject to provincial/territorial review and confirmation that the wastes, materials, and facilities involved are authorized for a particular disposal or recycling operation (the licensing of disposal and recycling facilities is a provincial/territorial responsibility). The provinces/territories may also have their own environmental legislation relating to the transportation of dangerous goods and waste management, including recyclables. As with any shipment of hazardous wastes or hazardous recyclable materials, the appropriate local authorities, such as the police or emergency-response officials, may be involved if a transportation accident occurs. 3. INTERPRETATION AND DEFINITIONSThe Regulations set out important interpretations and definitions, among them the definitions of hazardous waste and hazardous recyclable material. These definitions are outlined in detail in the User Guide to Hazardous Waste and Hazardous Recyclable Material Classification. Other important definitions are set out in Section 4 of the EIHWHRMR, and are included in Annex A of this guide. Authorized Facilities and Authorized Carriers Authorization for facilities and carriers must be made in a form that is applicable and acceptable to the responsible jurisdiction, either through regulation, legislation, or permit. The regulatee must submit notification to Environment Canada containing the registration number issued by either the province/territory of import or the country of export/import. Some provinces/territories may exempt certain facilities from this requirement if the hazardous wastes or hazardous recyclables are not regulated by the jurisdiction in which the facilities are located. In such cases, the facilities are considered authorized. 4. GENERAL PROVISIONS
4.1 Can I Ship Hazardous Waste to or from Any Country?No. Consistent with the Basel Convention, hazardous waste cannot be disposed of or recycled in the Antarctic (south of 60° South latitude) or destined for a country that is not party to the Convention, unless Canada has an agreement with the country through a bilateral or multilateral agreement. Use the following table to determine whether a shipment from a particular country may be allowed, if all of the other applicable conditions set out in the Regulations are met. Table 1 : Permitted Shipments
It is important to note that parties to the Basel Convention are made up of both OECD and non-OECD countries. See Annex B for a list of parties to the Basel Convention and Annex C for a list of OECD countries. 4.2 Which Operations Are Considered Disposal or Recycling?Schedules 1 and 2 of the Regulations specify the processes that are considered disposal and recycling operations, respectively. Storage pending either of these operations is also considered to be disposal or recycling for the purposes of the Regulations. It is important to note that the operations described in these lists may not be environmentally acceptable practices in all countries or provinces. These operations are meant to implement the disposal and recycling operations identified under both the Basel Convention and OECD Decision C(2001)107/Final. The proposed Regulations do not control the export, import, or transit of products being returned to manufacturers, or the return of containers with residues for refill. They do, however, apply to residuals exported or imported for disposal or recycling. 5. NOTIFICATION
5.1 What Is Notification?Section 185 of CEPA 1999 and Sections 5 to 8 of the Regulations Notification is the process by which exporters, importers, and persons wishing to convey in transit notify the Minister of Environment Canada of their intentions to send or receive international shipments of hazardous wastes or hazardous recyclable materials. It serves as the application for a permit, without which no shipment can proceed. Under the Regulations, notification involves completing either the information requirements set out in section 8 of the EIHWHRMR or the Administrative Notice Form (Annex E) specifying the details of the intended shipment, and attaching certain supporting documents. Environment Canada reviews the notice to ensure that it is complete and meets the technical requirements of the Regulations before forwarding it to the appropriate provincial or foreign government authorities for consent. While Environment Canada is the contact point between the notifier and the competent authorities in the provincial/territorial or foreign governments, it cannot predict or control the length of time it will take these authorities to respond to a request for consent. The length of time required to obtain a permit can vary greatly, and is affected by such factors as the type of waste or material, its destination, the disposal or recycling operation to be used, and the number of transit countries involved. In general, the person submitting the notification should allow at least 60 days for the administrative review process to be completed for shipments of wastes or materials to or from the United States (US), and materials to or from OECD countries. More time should be allowed for shipments to other countries, especially when confirmation of consent is required. The issuance of a permit may or may not correspond exactly to the intended shipping dates set out in the notice. Only after the notifier has received a permit is the shipment allowed to proceed. Permits are normally valid for up to one year; the export, import, or transit may take place at any time within this period. 5.2 Notification ProcedureThe Minister will provide a notice reference number to any person who requests one for the purpose of submitting a notice. This reference number is important in the tracking of the shipment and its associated documentation. For example, the notice number and line-item number must be entered on the movement document that accompanies the hazardous wastes or hazardous recyclable materials during transport. Notifying for Hazardous Wastes or Hazardous Recyclable Materials In the case of an export or import, a single notice can be submitted for either hazardous wastes or hazardous recyclable materials—but not for both. In the case of a transit, however, a single notice can include both hazardous wastes and hazardous recyclable materials. A single notice may be submitted as notification of a series of international shipments of hazardous wastes or hazardous recyclable materials if the wastes or materials
This allows for the notification of multiple hazardous wastes or hazardous recyclable materials from one site to another site within one year of the issuance of a permit. Site-Specific Notification The notification procedure is site-specific, meaning that the hazardous wastes or hazardous recyclable materials must originate from the same person and the same authorized facility, and be shipped to the same authorized facility at the same location. If a potential regulatee wishes to ship to or from multiple locations, a new notice must be submitted for each site or location. This is necessary in order to be consistent with the notification procedures of the Basel Convention and OECD Decision C(2001)107/Final. Language The notice and all attachments may be submitted to Environment Canada in either English or French. If requested by the importing country, Environment Canada will also ask the Canadian exporter to provide the information in another language specified by the foreign authority. Exporters may wish to contact Environment Canada before submitting a notice to determine whether a given country requires information in another language. Compliance with such requests will speed up the notification process and may minimize delays at border crossings or in transit. Notification for Amendments In general, once a permit has been issued, changes in the information on the notice require re-notification, since the permit is granted based on the original notice information. The person who submitted the notice may request an amendment to an existing permit by advising the Minister in writing of
After the proposed changes to the notice have been reviewed, an amendment to the permit may be issued. The new permit must be received prior to any shipment taking place under the new circumstances. Administrative updates and minor changes that do not significantly alter the notice, such as a change in phone number or civic address, may not necessarily require re-notification. The TMB should be contacted to obtain information on the need for re-notification. 5.3 What Must the Notice Contain?The exporter, importer, or person conveying in transit who submits the notice must ensure that the application meets the information requirements specified in section 8 of the EIHWHRMR. These requirements are summarized in sections 5.6 and 5.7 of this guide. 5.4 Who Must Notify?For exports of hazardous waste from Canada, the Canadian exporter is responsible for completing the notification and for making sure that all of the documents that must accompany it are provided to Environment Canada. For imports, the Canadian importer must provide Environment Canada with a notice. In the case of a transit through Canada, the notification should be completed by the person who is importing or exporting the waste in Canada. This person is normally the carrier. Paperwork may be submitted by a head office; however, the notice must indicate the actual authorized shipping and receiving sites. 5.5 Where Must the Notice Be Sent?The notification form and all accompanying documents required by the EIHWHRMR must be forwarded to the following: Director, Transboundary Movement Branch Submission of the Notice The notice may be sent by registered mail, facsimile, or courier. Environment Canada is also working toward developing a new electronic means of notice submission. 5.6 Summary of Notification Information RequirementsThe information requirements for notification are outlined in section 8 of the Regulations. They include
In addition to the above information requirements, the notifier must also submit
5.7 Completing the Notice Step-by-StepThe information requirements that must be included in the notification are outlined in section 8 of the Regulations. Although the Regulations do not prescribe the completion of a specific form, the TMB has developed an administrative notice form (see Annex E) to facilitate the notification process for regulatees. Following are step by step directions on how to complete this form: 5.7.1 Options (Box 1)Select one of the following three options (a separate notice must be completed for each option selected, even if the rest of the information on the notice remains the same):
5.7.2 Canadian Exporter/Foreign Exporter (Box 2)Exports from Canada Enter the name, civic and mailing addresses (if different), electronic address, and telephone and facsimile numbers of the Canadian exporter, as well as the e-mail address and name of the contact person. The civic address is the street address of the shipping site. Where applicable, the registration number (i.e., the provincial waste/recycler generator or identification number) must also be indicated. In the case of an export, the name of the insurance company and the policy number of the Canadian exporter must also be provided. Exports into Canada Enter the name, civic and mailing addresses (if different), electronic address, and telephone and facsimile numbers of the foreign exporter, as well as the e-mail address and name of the contact person. Where applicable, the registration number (i.e., the waste/recycler generator or exporter identification number issued by the foreign authority) must also be indicated. Transits through Canada Enter the name, civic and mailing addresses (if different), electronic address, and telephone and facsimile numbers of the foreign exporter, as well as the e-mail address and name of the contact person. Where applicable, the registration number (i.e., the waste/recycler generator or exporter identification number issued by the foreign authority) must also be indicated. Transits through a Country Other Than Canada Enter the name, civic and mailing addresses (if different), electronic address, and telephone and facsimile numbers of the Canadian exporter, as well as the e-mail address and name of the contact person. Where applicable, the registration number (i.e., the provincial waste/recycler generator or identification number) must also be indicated. 5.7.3 Foreign Receiver/Canadian Importer (Box 3)Exports from Canada Provide the name, civic and mailing addresses (if different), electronic address, and telephone and facsimile numbers of the foreign receiver, as well as the e-mail address and name of the contact person. Where applicable, the registration number (i.e., the operating licence or permit number of the facility issued by the foreign authority) must also be indicated. Imports into Canada Enter the name, civic and mailing addresses (if different), electronic address, and telephone and facsimile numbers of the Canadian importer, as well as the e-mail address and name of the contact person. Where applicable, the registration number (i.e., the provincial operating licence or permit number of the facility) must also be indicated. In the case of an import, the name of the insurance company and the policy number of the Canadian importer must also be provided. Transits through Canada Provide the name, civic and mailing addresses (if different), electronic address, and telephone and facsimile numbers of the foreign receiver, in addition to the e-mail address and name of the contact person. Where applicable, the registration number (i.e., the operating licence or permit number of the facility issued by the foreign authority) must also be indicated. Transits through a Country Other Than Canada Enter the name, civic and mailing addresses (if different), electronic address, and telephone and facsimile numbers of the Canadian importer, as well as the e-mail address and name of the contact person. Where applicable, the registration number (i.e., the provincial operating licence or permit number of the facility) must also be indicated. 5.7.4 Authorized Carrier (Box 4)Indicate the name, civic and mailing addresses (if different), electronic address, and telephone and facsimile numbers of the authorized carrier, as well as the e-mail address and name of the contact person. Also indicate the mode of transport and the carrier's licence or permit number. If using more than one carrier/mode of transport, attach a list providing the same information for each carrier that will be used. The name of the insurance company and the policy number of each authorized carrier must also be provided. 5.7.5 Authorized Facilities (Box 5) (formerly the "Final Destination")The Regulations require that all authorized facilities be specified as part of the notification. In the case of an interim operation, this includes not only the receiving facility, but also the facility that will undertake the final disposal or recycling of the waste or material. It is important to note that only one interim operation is allowed per waste stream, and that the final disposal or recycling operation associated with that waste stream must also be indicated. This information must be completed if the disposal/recycling operation is D13 (blending or mixing), D14 (repackaging), D17 (interim storage), R12 (waste exchange), R13 (accumulation), or R16 (interim storage), as described in Schedules I and 2 of the Regulations. Enter the name, civic and mailing addresses (if different), electronic address, and telephone and facsimile numbers, as well as the e-mail address and name of the contact person of the receiver at the final destination. Where applicable, the registration number (i.e., the operating licence or permit number of the facility) must also be indicated. 5.7.6 Number of Imports/Exports (Box 6)Enter the number of shipments that are intended to take place over the 12-month period covered by the notice. 5.7.7 Ports of Exit or Entry or Customs Offices (Box 7)Specify the names of all the ports of exit or entry through which the hazardous wastes or hazardous recyclable materials are to be shipped, attaching a separate page and marking the appropriate box on the notice, if necessary. Customs offices must also be indicated if the shipment is to be declared inland. 5.7.8 First and Last Shipment (Box 8)Indicate the anticipated dates of the first and last shipment. Depending on the time required to obtain consent from all authorities involved, the actual period covered by the notice may not correspond to these dates. 5.7.9 Transit Countries (Box 9)Indicate all countries through which the hazardous wastes or hazardous recyclable materials will pass before reaching their final destination, and the amount of time they will spend in each. Attach an additional page, if necessary. 5.7.10 Hazardous Waste or Hazardous Recyclable Material Information (Box 10)The following information must be provided for each hazardous waste or hazardous recyclable material:
For each hazardous waste or hazardous recyclable material, a new line containing the above information must be used. For more information on determining the classification of a waste or material, please refer to the User's Guide to Hazardous Waste and Hazardous Recyclable Material Classification. 5.7.11 Exports of Hazardous Waste for Disposal (Box 11)In the case of the export of hazardous waste destined for disposal, specify the options considered for reducing or phasing out the export of the waste and the reason that the final disposal is taking place outside Canada. 5.7.12 Statement of the Person Submitting the Notice (Box 12)The person who submits the notice must include a signed and dated statement indicating that
No agent can sign any document that, according to the Regulations, requires the signature of the exporter or importer. In the case of an export or import, the applicable contracts must also be submitted as part of the notification requirements. These contracts are described in Section 7 of this document. 6. APPROPRIATE AUTHORITIESAfter TMB has received the notification and its accompanying documents, a thorough technical review of the accuracy and completion of the application is conducted. If the notification is found to be satisfactory, the information is forwarded to the receiving jurisdiction. In the case of an export, TMB submits the notification information to the competent authority in the country of import, as designated by the Basel Convention, for review and consent. For exports to the US, the notification information is sent to the US Environmental Protection Agency (US EPA). In the case of an import, TMB submits the notification information to the appropriate authority in the province or territory where the disposal or recycling operation is to take place, since the provinces/territories license the treatment facilities. Environment Canada must receive acknowledgement from the authority that has jurisdiction over the receiving facility that the hazardous waste or hazardous recyclable material is authorized for disposal or recycling. If any competent authority objects, the shipment cannot proceed. The Minister will issue a permit once the notification has been satisfactorily completed and all authorizations are in place. No one shall import, export, or transit without a permit. Tacit consent is a government-to-government mechanism under OECD Decision C(2001)107/Final and the Canada-USA Agreement. This mechanism allows Environment Canada to issue 30-day tacit consent for hazardous recyclable materials exported to or imported from a country that is party to the OECD Decision. Environment Canada may also issue 30-day tacit consent for hazardous wastes and hazardous recyclable materials under the Canada-USA Agreement. These provisions have not been included in the Regulations, as they are best addressed administratively. 7. CONTRACTS AND INSURANCE
7.1 What Contracts or Arrangements Are Required?Except in cases where Canada is only a country of transit, the Regulations require proof of the existence of a written contract or series of contracts between the Canadian exporter, the foreign receiver, and the authorized facilities (in the case of an export) or between the Canadian importer, foreign exporter, and the authorized facilities (in the case of an import). If the Canadian exporter buys or sells materials for the purposes of recycling, and exports them to a country that is party to OECD Decision C(2001)107/Final, the notifier must have a contract with the facility from which the material will be exported. If the Canadian importer buys or sells materials for the purpose of recycling, the notifier must have a contract with the facility where the material will be recycled. Contracts must be signed by all of the parties involved. If the Canadian importer and foreign exporter (or the Canadian exporter and foreign receiver) are the same legal entity, company representatives from both countries must sign the contract. Copies of all contracts must be submitted to Environment Canada at the same time as the notification information, in order to provide proof that a business arrangement exists between the parties involved. 7.2 What Must the Contract Include?The contract between the Canadian importer and foreign exporter (in the case of an import) or the Canadian exporter and the foreign receiver (in the case of an export) need not include any confidential financial details. It must, however, contain the following information:
For an import into Canada, the contract must also include
For an export from Canada, the contract must also include
7.3 Who Must Be Insured?All Canadian exporters, Canadian importers, and authorized carriers of hazardous wastes and hazardous recyclable materials must be covered by liability insurance. All authorized carriers involved in international shipments of hazardous waste in which Canada is concerned must also be insured. The type, amount, and time period for insurance coverage are described in section 37 of the EIHWHRMR. 7.4 What Insurance Coverage Is Required?The amount of liability insurance required for exports or imports of hazardous wastes is at least five-million dollars; for exports or imports of hazardous recyclable materials, the minimum is one-million dollars. The Regulations do not specify the amount of liability insurance required for authorized carriers, since these carriers are licensed by provincial or federal authorities, and must comply with the requirements of the jurisdiction in which they operate. Insurance should cover
For imports, insurance must cover liability from the time the hazardous waste enters Canada to the time it is accepted for disposal or recycling at an authorized facility in Canada or, if the waste must be returned, the time it leaves Canada. For exports, insurance must cover liability arising from the time the hazardous waste leaves the Canadian exporter's shipping site to the time it is accepted for disposal or recycling at an authorized facility, including a facility in Canada if the waste must be returned. For transits, insurance must cover liability for the duration of the time that the hazardous waste or hazardous recyclable material is in transit in Canada. 8. SUMMARY OF CONDITIONS ON EXPORTS, IMPORTS AND TRANSITS8.1 ExportsWhere the Waste or Material May Be Exported An exporter may only export hazardous waste or hazardous recyclable material to countries that are party to the Basel Convention, OECD Decision C(2001)107/Final, or the Canada-USA Agreement. No exports may be shipped south of 60° South latitude or to Antarctica. What May Be Exported The Regulations set out the conditions for the export of hazardous wastes and hazardous recyclable materials. Some substances that fall within the Regulations' definition of hazardous waste or hazardous recyclable material may be prohibited from export by other Canadian laws and, therefore, cannot be exported under the Regulations. Other substances have additional conditions placed on them by the Regulations. For example, biomedical waste, as defined by the Regulations, and infectious substances, as set out in the TDGR, may be exported only for disposal. Who May Export In order to obtain an export permit, a person must meet the conditions of what constitutes an exporter, as set out in the Regulations. An exporter must be a resident of Canada or, in the case of a corporation, have a place of business in Canada. The exporter must also
Permits A permit will be issued by the Minister only after prior informed consent has been obtained from the authorities in the countries of transit and destination, in accordance with section185 of CEPA 1999. The conditions that must be met are specified in both the Regulations and the export permit. They are as follows:
This information is similar to that required for notification. A Canadian exporter may notify Environment Canada with his or her intentions to export hazardous wastes or hazardous recyclable materials, but it is only after a rigorous approval process that a permit will be issued indicating what may be exported and how the export must be carried out. In addition to meeting the requirements of the export permit, the Canadian exporter or authorized carrier must ensure that copies of both the permit and movement document accompany the waste or material and are deposited at the border. Shipments of hazardous waste may also be subject to other local, provincial, national, or international laws, regulations, and agreements. The Regulations are meant to complement these additional controls, especially those related to safety. The provisions of the Regulations do not override or replace any other current federal or international laws, regulations, or agreements concerning the transportation of dangerous goods under which any given shipment of hazardous waste may be controlled. It is important to note that most of the wastes and materials subject to the Regulations may also be subject to the TDGR. Exporters and authorized carriers must comply with the applicable Part 4 requirements of the TDGR governing such areas as proper vehicle placarding, labelling and packaging. Time Limits The disposal and recycling operations specified in the Regulations are consistent with those set out under Canada's international obligations. These obligations also specify the time within which disposal or recycling must take place. The following are interim operations that may take place prior to final disposal or recycling:
The authorized facility (commonly known as a "transfer station") has 180 days to complete these interim disposal or recycling operations, after which time the waste or material must undergo final disposal or recycling. The authorized facility has one year to complete the operations that constitute final disposal or recycling. If the jurisdictional authority requires final disposal or recycling to be completed within a shorter time frame, the authorized facility must comply with this requirement. Within 30 days after the date on which the final disposal or recycling took place, the Canadian exporter must provide the Minister with written confirmation that the operation has been completed. There is no prescribed form for this confirmation. Alternate Arrangements Section 186 of CEPA 1999 prohibits the abandonment of any waste or material for which a permit has been issued. Section 9(p) of the EIHWHRMR sets out the conditions that must be followed when
If the shipment cannot be recycled or disposed of in the manner stated in the export permit (after the transboundary shipment process has begun), the Canadian exporter must
Movement Document Before the shipment may begin, the Canadian exporter must complete and sign Part A of the movement document and provide it and a copy of the export permit to the first authorized carrier. The carrier must then complete and sign Part B of the movement document and provide a copy to the exporter. The shipment may then proceed. The Canadian exporter has three working days after the date on which the waste or material was shipped to submit a copy of the movement document, with Parts A and B completed, to the Minister and, if required, the provincial authority. A copy of the movement document and export permit must also be deposited at the Canada Customs by the Canadian exporter or authorized carrier. The Canadian exporter must ensure that the foreign receiver completes Part C of the movement document on receipt of the shipment, and provides a copy of the movement document and the export permit to the Canadian exporter. If the waste or material is not regulated as hazardous in the foreign jurisdiction, the exporter may, in accordance with the contract, sign Part C of the document on behalf of the foreign receiver. The Canadian exporter has three working days after the date on which the hazardous waste or hazardous recyclable material was delivered to the foreign receiver to provide the movement document, with Parts A, B, and C completed, to the Minister and, if required, the provincial authority. The following table summarizes the export conditions set out in Part 2 of the Regulations. Table 2 : Conditions on Exports for Disposal or Recycling
8.2 ImportsWhere the Waste or Material May be Imported An importer may only import hazardous waste or hazardous recyclable material from countries that are party to the Basel Convention, OECD Decision C(2001)107/Final, or the Canada-USA Agreement. What May Be Imported The Regulations set out the conditions for the import of hazardous waste and hazardous recyclable material. Some substances that fall within the Regulations' definition of hazardous waste or hazardous recyclable material may be prohibited from import by other Canadian laws and, therefore, cannot be imported under the Regulations. Other substances have additional conditions placed on them by the Regulations. For example, biomedical waste, as defined by the Regulations, and infectious substances, as set out in the TDGR, may be imported only for disposal. Who May Import In order to obtain an import permit, a person must meet the conditions of what constitutes an importer, as set out in the Regulations. An importer must be a resident of Canada or, in the case of a corporation, have a place of business in Canada. The importer must also
DND Exemption The Regulations exempt the Department of National Defence (DND) from the conditions for importing hazardous wastes and hazardous recyclable materials (specified in sections 16 to 21 of the Regulations). The stipulations governing this exemption are that
Permits An import permit will be issued by the Minister only after prior informed consent has been obtained from the authorities of the countries of transit and the provincial authority of destination, in accordance with section 185 of CEPA 1999. The conditions that must be met are specified in both the Regulations and the import permit. They are as follows:
This information is similar to that required for notification. A Canadian importer may notify Environment Canada with his or her intentions to import hazardous waste or hazardous recyclable material, but it is only after a rigorous approval process that a permit will be issued indicating what may be imported and how the import must be carried out. In addition to meeting the requirements of the import permit, the Canadian importer or authorized carrier must ensure that copies of both the permit and movement document accompany the waste or material and are deposited at the border. Shipments of hazardous wastes or hazardous recyclable material may be subject to other local, provincial, national, or international laws, regulations, and agreements. The Regulations are meant to complement these additional controls, especially those related to safety. The provisions of the Regulations do not override or replace any other current federal or international laws, regulations, or agreements concerning the transportation of dangerous goods under which any given shipment of hazardous waste or hazardous recyclable material may be controlled. It is important to note that most of the wastes and materials subject to the Regulations may also be subject to the TDGR. Canadian importers and authorized carriers must comply with the applicable Part 4 requirements of the TDGR governing such areas as proper vehicle placarding, labelling, and packaging. Time Limits The disposal and recycling operations specified in the Regulations are consistent with those set out under Canada's international obligations. These obligations also specify the time within which disposal or recycling must take place. The following are interim operations that may take place prior to final disposal or recycling:
The authorized facility (commonly known as a "transfer station") has 180 days to complete these interim disposal or recycling operations, after which time the waste or material must undergo final disposal or recycling. The authorized facility has one year to complete the operations that constitute final disposal or recycling. If the jurisdictional authority requires final disposal or recycling to be completed within a shorter time frame, the authorized facility must comply with this requirement. Within 30 days after the date on which the final disposal or recycling took place, the Canadian importer must provide the Minister with written confirmation that the operation has been completed. There is no prescribed form for this confirmation. Alternate Arrangements Section 186 of CEPA 1999 prohibits the abandonment of any waste or material for which a permit has been issued. Section 16(o) of the EIHWHRMR sets out the conditions that must be followed when
If the shipment cannot be recycled or disposed of in the manner stated in the import permit (after the transboundary shipment process has begun), the Canadian importer must
Movement Document Before the import may begin, the Canadian importer must provide the foreign exporter with a copy of the movement document and import permit. In accordance with the contract, the foreign exporter must complete and sign Part A of the movement document and provide it and a copy of the import permit to the first authorized carrier. If the waste or material is not regulated as hazardous in the foreign jurisdiction, the importer may, in accordance with the contract, sign Part A on behalf of the foreign exporter. The first authorized carrier must complete and sign Part B of the movement document and provide a copy to the foreign exporter. The shipment may then proceed. The foreign exporter must provide the Canadian importer with a copy of the movement document, with Parts A and B completed, at the commencement of the shipment. The Canadian importer has three working days after the date on which the waste or material was shipped to submit a copy of the movement document, with Parts A and B completed, to the Minister and, if required, the provincial authority. A copy of the movement document and permit must also be deposited at Canada Customs by the Canadian importer or authorized carrier. The Canadian importer must complete Part C of the movement document upon receipt of the shipment. The importer has three working days after the date on which the delivery was received to provide the movement document, with Parts A, B, and C completed, to the Minister and, if required, the provincial authority. The following table summarizes the import conditions set out in Part 3 of the Regulations. Table 3: Conditions on Imports for Disposal or Recycling
8.3 TransitsWhat Constitutes a Transit There are two types of transits that may occur under CEPA 1999 and the Regulations:
Put simply, a transit is basically the import of hazardous waste or hazardous recyclable material into Canada and the subsequent export of the waste of material from Canada, or vice versa. What May Be Conveyed in Transit The Regulations set out the conditions for the transit of hazardous wastes and hazardous recyclable materials. Some substances that fall within the Regulations' definition of hazardous waste or hazardous recyclable material may be prohibited from import, export, or transit by other Canadian laws and, therefore, cannot be conveyed in transit under the Regulations. Permits A transit permit will be issued by the Minister only after prior informed consent has been obtained from the authorities of the countries of transit, in accordance with section 185 of CEPA 1999. The conditions that must be met are specified in both the Regulations and the transit permit. They are as follows:
In addition to meeting the requirements of the transit permit, the Canadian exporter or foreign exporter must ensure that copies of both the permit and movement document accompany the waste or material, and are deposited at Canada Customs. Shipments of hazardous waste or hazardous recyclable material may be subject to other local, provincial, national, or international laws, regulations, and agreements. The Regulations are meant to complement these additional controls, especially those related to safety. The provisions of the Regulations do not override or replace any other current federal or international laws, regulations, or agreements concerning the transportation of dangerous goods under which any given shipment of hazardous waste or hazardous recyclable material may be controlled. It is important to note that most of the wastes and materials subject to the Regulations may also be subject to the TDGR. Exporters and authorized carriers must comply with the applicable Part 4 requirements of the TDGR governing such areas as proper vehicle placarding, labelling, and packaging. Movement Document For transit through Canada: Before the transit may begin, the first authorized carrier must ensure that the foreign exporter has completed and signed Part A of the movement document. The first authorized carrier must complete and sign Part B of the movement document and provide a copy to the foreign exporter. The shipment may then proceed. The authorized carrier has three working days after the date on which the waste or material exited Canada to provide a copy of the movement document, with Parts A and B completed, to the Minister and, if required, the provincial authority. The carrier must also deposit a copy of the movement document and transit permit at Canada Customs. For transit through a country other than Canada: Before the shipment may begin, the Canadian exporter must complete and sign Part A of the movement document and provide it and a copy of the transit permit to the first authorized carrier. The first authorized carrier must complete and sign Part B of the movement document and provide a copy to the Canadian exporter. The Canadian exporter has three working days after the date on which the waste or material was shipped to provide a copy of the movement document, with Parts A and B completed, to the Minister and, if required, the provincial authority. The Canadian exporter or the authorized carrier must also deposit a copy of the movement document and permit at Canada Customs. The Canadian importer must complete Part C of the movement document, and has three working days after the date on which the delivery was received to provide the movement document, with Parts A, B, and C completed, to the Minister and, if required, the provincial authority. The following table summarizes the transit conditions set out in Part 4 of the Regulations. Table 4: Transits for Disposal or Recycling
9. MOVEMENT DOCUMENT
9.1 What Is the Movement Document?The movement document is a form that provides detailed information on the types and amounts of hazardous wastes or hazardous recyclable materials being shipped, a record of the various firms or individuals involved in the shipment, and information on the treatment, storage, and disposal of the wastes or materials when they reach their final destination. The document is made up of three separate parts, and has six copies. These copies are intended to make it easier for all parties involved to meet the necessary completion and distribution requirements. The movement document is found in Schedule 9 of the EIHWHRMR. 9.2 When Must the Movement Document Be Used?Canada's international agreements require that the waste or material be accompanied by a movement document from the time it is shipped to the time it is received. The movement document serves the needs of both the federal and provincial/territorial governments with respect to the tracking of hazardous wastes and hazardous recyclable materials. Requirements for the distribution of copies of the movement document may differ among various provincial and territorial jurisdictions. For example, some require an original, signed movement document, while for others a copy is sufficient. Movement documents may also be required by some jurisdictions for waste other than hazardous waste and hazardous recyclable material. Exporters, importers, and carriers are encouraged to contact the appropriate jurisdictions to determine provincial/territorial requirements. 9.3 Who Must Complete the Movement Document?The movement document is made up of three separate parts:
For tracking purposes, in an international shipment of hazardous waste or hazardous recyclable material, the person who exports acts as the consignor and the person who imports acts as the consignee. Individuals completing the movement document must print clearly and press firmly. 9.4 What Are the Requirements When Importing, Exporting, or Transiting Hazardous Waste or Hazardous Recyclable Material?The Basel Convention, which Canada ratified in August 1992, prohibits the shipment of hazardous wastes and hazardous recyclable materials across international borders without prior notification and approval. International shipments of wastes or materials that pass into, through, or out of Canada are subject to the requirements of the EIHWHRMR. The Regulations, made pursuant to CEPA 1999, contain a number of documentation requirements, including the use of a movement document. Individuals or corporations wishing to transport hazardous wastes or hazardous recyclable materials for import to, export from, or transit through Canada (or from Canada, transiting through the US, and back into Canada) should contact the appropriate authority for international shipments (see Annex D). Knowledge of the requirements that must be met reduces the risk of shipments of hazardous waste or hazardous recyclable material being held up in transit or rejected at a border crossing. 9.5 Responsibilities Associated with the Movement Document9.5.1 International ShipmentsResponsibilities of the Canadian Exporter and the Foreign Exporter The Canadian exporter is responsible for ensuring that copies of the movement document are properly completed and distributed to the foreign receiver, to the appropriate authorities (Environment Canada and the province or territory of origin)and to the authorized carrier.
Responsibilities of the Carrier
Responsibilities of the Canadian Importer and the Foreign Receiver The Canadian importer is responsible for ensuring that copies of the movement document are properly completed and distributed to the foreign exporter, to the appropriate authorities (Environment Canada and the province or territory of destination) and to the authorized carrier.
Multiple Carrier Form If more than one authorized carrier is utilized by the same Canadian exporter or foreign exporter for hazardous wastes or hazardous recyclable materials being sent in the same shipment to the same Canadian importer or foreign receiver, an additional document detailing the required authorized carrier information may be attached to the movement document. The person completing the additional document must ensure that it also contains the movement document reference number. The above option is not available in jurisdictions where provincial/territorial legislation requires the use of additional movement documents when more than one authorized carrier is used for shipment into, out of, or through the jurisdiction. If more than four hazardous wastes from the same Canadian exporter or foreign exporter are to be sent in the same shipment, additional movement documents must be completed. The person completing the additional movement document must ensure that it contains the first movement document reference number. 9.6 Instructions for Completing Each Item on the Movement Document9.6.1 Part A. Generator/Consignor or Canadian Exporter/ForeignExporter
9.6.2 Part B. Carrier
9.6.3 Part C. Receiver/Consignee or Canadian Importer/Foreign Receiver
10. SUMMARY OF CONDITIONS ON RETURNS
Under Part 7, Division 8 of CEPA 1999, a new permit to export or import for the purposes of a return must be obtained in order to return hazardous waste or hazardous recyclable material that cannot be disposed of or recycled in accordance with the original import or export permit. The provisions for returns set out Part 5 of the Regulations are intended to facilitate returns of waste or recyclable material to either the exporting country and the original foreign exporter, or to Canada and the original Canadian exporter, as required under Canada's international agreements. A simplified notification procedure for obtaining a new permit to export or import for the purposes of a return has been incorporated into the Regulations, given that contracts and consent already exist between the original parties. Once the notification to return a waste or recyclable material has been approved by the Minister, a permit will be issued for the re-export or re-import of the return to the authorized facility named in the permit. 10.1 Returns to Canada (Imports for the Purposes of a Return)If the hazardous waste or hazardous recyclable material cannot be disposed of or recycled in accordance with the export permit, the original Canadian exporter must make arrangements to
Notification Procedure In submitting a notification for a new import permit for the purposes of a return, the original Canadian exporter must advise the Minister of the following:
New Import Permit Once a new import permit has been received for the purposes of returning hazardous waste or hazardous recyclable material to Canada, the original Canadian exporter must
10.2 Returns to the Country of Export (Exports for the Purposes of a Return)If the hazardous waste or hazardous recyclable material cannot be disposed of or recycled in accordance with the import permit, the original Canadian importer must make arrangements to
Notification Procedure In submitting a notification for a new export permit for the purposes of a return, the original Canadian importer must advise the Minister of the following:
New Export Permit Once a new export permit has been issued for the purposes of returning hazardous waste or hazardous recyclable material to the foreign country from which it was exported, the original Canadian importer must
Table 5: Conditions for Returns
11. CONFIRMATION OF DISPOSAL OR RECYCLINGThe Canadian importer or foreign receiver who accepts a shipment of hazardous waste or hazardous recyclable material is responsible for its disposal or recycling. Canada's international obligations specify the time frame within which this operation must take place. Interim Disposal/Recycling Interim disposal or recycling operations that may take place prior to final disposal or recycling include
The authorized facility (commonly known as the "transfer station") has 180 days to complete these interim operations. Final Disposal/Recycling All other disposal or recycling operations (including those made following interim disposal or recycling) must be completed by the authorized facility within one year. If the authority of the jurisdiction requires that the hazardous waste or material be disposed of or recycled within a shorter period of time, the authorized facility must comply with this requirement. Within 30 days after the completion of the disposal or recycling operation, a letter confirming that the operation has taken place in accordance with the export or import permit must be forwarded to Environment Canada by the Canadian exporter or importer. The letter must include the movement document reference number and the line-item number of the applicable hazardous waste or hazardous recyclable material. 12. PRE-APPROVED FACILITIESA pre-approved facility is one that has been approved in advance by the competent government authority to receive shipments of certain types of waste destined for recycling. A Canadian facility may apply for pre-approval by submitting the following information (outlined in OECD Decision C(2001)107/Final) to Environment Canada's TMB:
This and any additional information required will be forwarded to the province in which the facility is located. The province may then grant approval for the facility to receive a certain quantity of a specific recyclable material over a given period of time. The same mechanism exists under the Regulations. No export or import to a pre-approved facility may begin until a permit has been issued by the Minister. Permits issued to pre-approved facilities may be valid for up to three years, in accordance with the OECD Decision. Owners/operators of foreign facilities must apply for pre-approval in their own country. For a Canadian export to be shipped under the seven-day tacit consent scheme8, the foreign facility must be on the list of pre-approved facilities prepared by the OECD. 13. WASTE-EXPORT REDUCTION PLANSSection 188(1) of CEPA 1999 provides the Minister with the authority to request an exporter or class of exporters of hazardous waste for final disposal to submit and implement a plan for the purpose of reducing or phasing out the export of the waste. Section 191(g) of CEPA 1999 takes into account the proximity or benefit of using the nearest appropriate disposal facility, and the increased production of goods responsible for generating the hazardous wastes for disposal. The Regulations define the information to be included in such plans as follows:
Environment Canada will notify exporters directly if they are required to prepare an export-reduction plan for the waste destined for final disposal. One of the triggers for requiring a plan will likely be based on review statistics, the notification information of 8(j)(ix) of the EIHWHRMR, the reduction or phase-out options considered, and the reason the disposal is taking place outside Canada. The export-reduction plan must be submitted before a permit to export will be granted. A copy of the plan must be kept at the exporter's principal place of business in Canada for a period of five years after the date on which the plan was submitted. 14. ENVIRONMENTALLY SOUND MANAGEMENT CRITERIAIn accordance with Part 7, Division 8 of CEPA 1999, the Minister may refuse to issue a permit to import, export, or transit hazardous waste or hazardous recyclable material if the Minister is of the opinion that the waste or material will not be managed in a manner that protects the environment and human health. The Regulations set out the criteria under which the Minister makes this determination. 15. PELESSection 190 of CEPA 1999 authorizes the issuance of permits of equivalent level of environmental safety (PELES), which may be used to obtain a variance from the Regulations under specific conditions. Variances must be consistent under Canada's international obligations, and are issued on a case-by-case basis. When requesting a PELES for this purpose, the following information should be provided:
ANNEXES
A. Definitions"Act" means the Canadian Environmental Protection Act, 1999. "authorities of the country" means the competent authorities designated in the Compilation of Country Fact Sheets (CFS), Basel Convention Series No. 01/04, as amended from time to time, and the United States Environmental Protection Agency. "authorized carrier" means a carrier that is authorized by the authorities of the jurisdiction in which the waste or material is transported, to transport the hazardous waste or hazardous recyclable material that is to be exported, imported or conveyed in transit. "authorized facility" means a facility that is authorized by the authorities of the jurisdiction in which the facility is located to
"Canada-USA Agreement" means the Agreement between the Government of Canada and the Government of the United States of America Concerning the Transboundary Movement of Hazardous Waste, which entered into force on November 8, 1986, as amended from time to time. "Convention" means the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal, which entered into force on May 5, 1992. "foreign exporter" means the person who exports hazardous waste or hazardous recyclable material from a country other than Canada. "foreign receiver" means the person who imports hazardous waste or hazardous recyclable material into a country other than Canada. "movement document" means the form set out in Schedule 9 of the Export and Import of Hazardous Waste and Hazardous Recyclable Material Regulations. "notice" means the notice of export, import, or transit referred to in paragraph 185(1)(a) of the Act. "OECD Decision C(94)152/Final" means Decision C(88)90/Final of the Organization for Economic Co-operation and Development, Decision of the Council on Transfrontier Movements of Hazardous Wastes, dated May 27, 1988, as amended by Decision C(94)152/Final, Decision of the Council Amending the Decision on Transfrontier Movements of Hazardous Wastes, dated July 28, 1994. "OECD Decision C(2001)107/Final" means Decision C(2001)107/Final of the Organization for Economic Co-operation and Development, Decision of the Council Concerning the Revision of Decision C(92)39/FINAL on the Control of Transboundary Movements of Wastes Destined for Recovery Operations, dated May 21, 2002. "permit" means the export, import, or transit permit referred to in paragraph 185(1)(b) of the Act. "registration number" means the number assigned by a province or country indicating the authority to undertake an activity with respect to a hazardous waste or hazardous recyclable material. "TDGR" means Transportation of Dangerous Goods Regulations. "PIN" means Product Identification Number, as defined in the TDGR. B. Countries that Ratified the Basel ConventionFor information on the countries that ratified the Basel Convention, visit http://www.basel.int/ratif/frsetmain.php. C. OECD CountriesFor information on the OECD Countries, visit http://www.oecd.org/countrieslist/0,3025,en_33873108_33844430_1_1_1_1_1,00.html. D. Appropriate Authorities/Emergency NumbersFor more information on the EIHWHRMR, contact Environment Canada headquarters or one of the provincial authorities listed below. Emergency numbers are indicated with an asterisk. International Shipments Environment Canada Provincial Authorities Alberta *1 800 222-6514 British Columbia *1 800 663-3456 Manitoba *(204) 944-4888 Newfoundland and Labrador *1 800 563-9089 New Brunswick *1 800 565-1633 Northwest Territories *(867) 920-8130 Nova Scotia *1 800 565-1633 Ontario *1 800 268-6060 Prince Edward Island *1 800 565-1633 Québec *(514) 873-3454 Saskatchewan * 1 800 667-7525 Yukon *(867) 667-7244 Nunavut *(867) 920-8130 E. Administrative Notice Formhttp://www.ec.gc.ca/tmb/eng/EIHWHRM_Information_e.html 1 This information is required for Canada to meet its obligations under the Stockholm Convention. The management of waste POPs is a joint effort involving the secretariats of both the Stockholm and Basel Conventions. 2 Schedule 5 does not set out an ID number, so the substance name identified in column 1 of that schedule is to be entered instead. 3 This information is required in order for Canada to meet its obligations under the Stockholm Convention. The management of waste POPs is a joint effort involving the secretariats of both the Stockholm and Basel conventions. The levels set out under the Regulations are consistent with the low POP content being used under the Basel Convention's "General technical guidelines for the environmentally sound management of wastes consisting of, containing, or contaminated with persistent organic pollutants (POPs)". 4 In such a case, where a broker is acting as the exporter and may not have physical possession of the material, the broker must identify the shipping site in the notice and include a contract with the site as part of the notification. 5 Note that this is not limited to imports from OECD countries. In the case of recyclable material, a broker may, therefore, act as the importer. The broker must identify the receiving site in the notice and include a contract with the site as part of the notification. 6 Part A of the new import permit is to be completed by the foreign receiver. 7 Part A of the new movement document must be completed by the Canadian importer. 8 With the pre-approval mechanism, 30-day tacit consent under OECD Decision (2001)107/Final is reduced from 30 days to seven days. |
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