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Revised Proposed Battery Take-Back Would Expand Obligations in Brazil

Published August 25, 2008

Batteries

CONAMA’s latest revisions to its 1999 battery content and take-back rule include a new focus on products containing batteries. On its face, the latest version (the “Draft”), as currently drafted would impose new obligations on manufacturers and importers of all products containing any primary or secondary batteries, including registration, testing and management plan requirements. The Draft would also impose more stringent heavy metal content limits on batteries, and would keep all batteries, regardless of content, out of household waste bins.


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