Problems relating to Trade and Investment on United Arab Emirates
22. Environmental pollution and waste disposal |
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Issue |
Issue details |
Requests |
Reference |
| (1) Abrupt Amendment of Energy Efficiency Regulation | - Product development cannot catch up with the amendment in Energy Efficiency Regulation, which was announced in April and enforced from September. A member firm's subsidiary is unable to import products for distribution in UAE for 6-months or more, due to development of products that satisfy the requirements under Amended Energy Efficiency Regulation and lead-time from manufacture to shipment. | - It is requested that the Government of UAE (GOU) releases the energy efficiency regulation, etc. 2 to 3-years ahead of enforcement. | |
| (2) Mandatory Use of Oxo-Biodegradable Plastic Bags and other related Packaging Materials | - Mandatory use of oxo-biodegradable plastic bags and other related packaging materials enforced from 1 January 2014 under UAE Ministerial Decree No.118-2013 expands the scope of the items subject to regulations from the previous shopping bags only to 15-items of packaging materials. (Although it is uncertain, it includes) packaging materials for electric/electronic products. In addition, the Decree requires submission of sample packaging materials using the ESMA approved additives for further approval by the Emirates Authority for Standardization and Metrology (ESMA) and attachment of mark for certification of conformity. Use of oxidatively decomposed packaging materials susceptible of oxidation, in lieu of the sturdy, ruggedly composed materials, which are prerequisite for quality assurance of products, goes beyond the reasonable extent of protecting the products in transit. - The requirement exists for use of certified oxo-biodegradable plastic packaging materials made from poly-ethylene (PE), polypro-pylene (PP) as raw materials, attaching mark for certification of conformity, but for verbal explanation, accompanying neither formal explanation of the scope of the subject products, nor precise specifications for oxo-biodegradable plastic. Further, should this requirement for packing materials apply to all products, due to the vast varieties of the packaging materials, it is extremely difficult to comply. While member firm's subsidiary (MFS) received from the local authority a verbal confirmation that the Decree does not apply to the finished products, promulgation of its formal written Decree remains pending. |
- It is requested that GOU exempts packing materials of electric/electronic products from the scope of the goods subject to the Ministerial Decree. (DE of EU and KEA of R.O.K. already despatched letters to ESMA, requesting clarification of the subject products, and postponement of its enforcement. Furthermore, Gulf Petrochemicals and Chemicals Association (GPCA) submitted its Position Paper to UAE, to the effect that this regulation is not an optimum correct policy, as it gives negative impact among others on plastic recycling efforts, etc.) - It is requested that GOU narrows the scope of the subject product categories to those that materially damage the environment, and exclude electric/electronic products and packaging materials for distribution from the scope of the subject products. - While GOU verbally stated that the finished products packed in plastics are outside the scope of the subject products, it is requested that GOU releases formal documents, including FAQ (Frequently Asked Questions) to substantiate the verbal statement. |
- United Arab Emirates / Ministry of Environment & Water Office of the Minister Decree No.118-2013 (Law) - United Arab Emirates/ Ministry of Environment & Water Office of the Minister UAE Ministerial Decree No.118-2013 |
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