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Reclamation and Utilization Packaging Measures in China

Published September 16, 2008

Packaging and Labeling

EIATRACK members doing business in China should be aware that since 2005, the National Development and Reform Commission (NDRC) has been leading a multiagency effort to promulgate packaging rules.  Other priorities, however, have forced NDRC to put packaging rulemaking on a "back burner" until recently.

The current draft regulation is entitled "Measures for Administration of Packaging Reclamation and Utilization" (hereinafter referred to as "Measure").  Essentially, the Measure would prohibit the over-packaging of products, restrict the use of certain materials in packaging, and encourage the use of reclaimed packaging materials.   The Measure would also require that packaging be produced using clean production and implements standards for recycling, including prohibiting certain disposal methods for packaging.

NDRC has also proposed the Catalog of Packaging for Reclamation and Utilization Administration ("Catalog") outlining the packaging materials subject to the Measure.

The overall goal of the Measure is to reduce the impact of packaging on the environment throughout the entire life cycle.  Based on the current draft of the Measure, certain EIATRACK members may be required to participate in collectives, or individually establish, packaging take back opportunities.

The draft Measure is not expected to be completed until sometime in 2009, although NDRC officials have commented that finalization of packaging laws will be a rulemaking priority going forward.

As is still common in China, the draft Measure and associated Catalogue were released to a limited number of stakeholders.  Hence, please keep the draft included with this Alert within your organization and be sensitive to the limited distribution in your discussions with the authorities on this issue, if any.


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