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This section of this paper examines the key elements necessary in establishing a successful rechargeable Ni-Cd battery recycling program. As background, it is important that the reader understand certain basic terminology and relationships.

Consumer use of the term "battery" in fact often extends to several different items. The basic building block of a "battery" is a "cell" - the combination of materials that produces electrical current in a predictable fashion. Some "batteries" consist of a single cell. More commonly, however, a series of cells are connected in a single package. In the trade, this is commonly referred to as a "battery pack," but consumers often call it simply a "battery."

Cells and battery packs can be included in products sold to consumers - such as portable telephones or power drills - or sold independently. In the trade, the former category is generally referred to as "original equipment manufacture" or "OEM," while the latter is referred to as "replacement."

A number of channels of manufacture and distribution apply within each category. Their principal shared characteristics are that they are multileveled, international and dynamic. For example, an OEM battery pack included in a power tool may include cells manufactured in one or more countries (by a company or companies domiciled elsewhere), which were assembled into battery packs in yet another country or countries, by yet another company, and which then finally were assembled into the tool elsewhere (and by another company or companies). This last company may then place its own brand on the product, or supply it to yet another company which markets the product under its own brand.

The uninitiated generally characterize only the company whose brand appears on the product as the product manufacturer, but this obviously is not necessarily the case. Furthermore, even after the product is "manufactured," it may be sold directly to retailers, may be sold through one or more independent distributors, or maybe sold through both channels.

Moreover, the same companies that supply component parts to the OEM product supplier may also supply it with replacement battery packs; may market those replacement products on their own; and/or may supply replacements to yet others to sell under their proprietary brand names. In addition, there are some companies that manufacture or assemble battery packs and batteries only for the replacement market. These replacement products may be marketed under the assembler's name or under that of some other entity.

Varying cost and pricing considerations affect companies that participate at each level of this complex manufacture and distribution scheme. Moreover, these relationships are constantly changing.

Additional dynamism arises from technological progress, which results in particular products being put to different uses over time. For example, five years ago rechargeable Ni-Cd batteries were the solution of choice to power all sorts of portable products, including computers, telephones and power tools. Today, batteries that rely upon chemistries other than nickel - cadmium have come to play an increasingly important role in many sectors, such as laptop computers and camcorders. Thus, distribution channels that were devoted to Ni-Cd batteries some years ago may now carry a relatively smaller quantity of such products or, in some situations, may no longer handle any Ni-Cd battery-containing OEM products at all. At the same time, the remaining OEM and replacement Ni-Cd battery marketplace has attracted additional suppliers.

No governmentally-defined collection program can be expected to efficiently or effectively respond to these changing conditions or allocate responsibilities and costs among the numerous participants in product manufacture and distribution. But quick responses and cost allocations of this sort are a fundamental aspect of all marketplaces. Hence, collection and recycling programs can be expected to be most successful where governmental entities create an environment in which voluntary, private sector systems can succeed and then encourage widespread participation in those programs.


Well-established Ni-Cd battery recycling plants are operational in France, Germany and Sweden. These plants, one of which has been in operation since 1977, recover the cadmium, nickel and iron from batteries collected throughout Europe and elsewhere across the world.

The European Battery Directive, EEC 91/157, establishes a labeling requirement and requires separate collection for used Ni-Cd batteries marketed in Europe. Such batteries are also regulated as special waste when spent, imposing more costly handing requirements than apply to most recyclable products, but less than apply to hazardous waste. The European Battery Directive has spurred the collection of Ni-Cd batteries through a number of different systems. First, there are general public collection schemes run by governments in a number of European countries. Second, Ihere are also numerous collection programs focused solely on Ni-Cd batteries that are bang funded by the battery industry, in cooperation with government. Finally, Ni-Cd batteries are also collected in programs operated by OEM manufacturers that capture the appliance at the end of its life and tie battery that has been powering it as well. When these batteries are shipped across national borders for recycling in France, Germany or Sweden, all of the applicable OECD transboundary controls apply.

Since the early 1990s, private sector sponsored batteiy collection schemes have been operating in many counties in Western Europe, including Austria (UFB), Belgium (BEBAT), Germany (GRS), the Netherlands (STIBAT), Switzerland (BESO), the U.K. (REBAT), and Fiance (ECOVOLT). Similar recycling organizations are being set up in Italy, Norway, Spain and Sweden. The number of units being collected increases each year.

However, these programs' operations are not all identical, in part because of the varied legal requirements that exist in the different countries. The divergent program approaches that developed across Europe have led to inconsistencies and inefficiencies that the European Portable Battery Association (EPBA) is seeking to address. For example, some countries require the collection of all used portable batteries {i.e., Austria, France, Germany, Netherlands, Sweden, and Switzerland), while other national collection mandates are focussed on used Ni-Cd batteries (i.e., Denmark and Norway). In the U.K., Ni-Cd batteries are collected on a voluntary basis. Efforts to extend the U.K. program to cover all portable rechargeable batteries under an industry established return company failed, in part because of disagreements over how to share the costs of collection among industry participants. Some of the disputes concerned paying for the collection of "free-rider" batteries (i.e., batteries produced or imported by companies that do not financially participate in the program).

Funding mechanisms to pay for Ni-Cd battery collection programs have varied from one EU country to the next, sometimes to the point of incompatibility. For example in Denmark manufacturers and importers of Ni-Cd Batteries are required to pay fees based on the number to be sold. These monies are paid out to (15 Euro/kg) collection companies who return spent Ni-Cd batteries to the government. Collection efforts have thus focused on the more urban, high population density areas because the collection results are the most profitable there, leaving more rural locations without collection. As a result, used Ni-Cd batteries that were originally purchased elsewhere in the EU — including countries where collection organizations pay for collection -reportedly have been tunneled to Denmark for the refund revenue.

Consumers pay the fee indirectly by an increase in the cost of batteries. Sales of Ni-Cd batteries and battery powered tools reportedly have decreased in Denmark as a result of this deposit.

In Norway, a new organization (REBATT AS) has undertaken the management of deposits collected from replacement Ni-Cd battery importers. Monies are also collected from sellers of OEM batteries, but these are put into the fund dedicated to electronic waste recycling. As REBATT AS collects OEM batteries, it invoices the electronic waste fund for the monies necessary for their recycling. The fact that over 90% of the Ni-Cd batteries now marketed in Norway are OEM batteries makes this system very complex.

The most common OEM collection programs are operated by the cordless tool industry. Spent Ni-Cd batteries, often along with the tool, are collected through reverse distribution schemes (e.g. the truck that brings new products returns with used tools and batteries). Consumers may thus leave their spent batteries and/or used tools at specialized trade or company outlets or service centers. Bosch runs such a program in Germany. Black & Decker operates a similar one in the U.K. An association of manufacturers operate programs in France (Ecovolt) and Italy (Ecoelit) .Computer batteries are collected by Siemens-Nixdorf in Germany. Nokia and Ericsson are cooperating with the cordless tool manufacturers to begin a new program in Finland this month. As examples of how such programs operate, the following discussion focuses on two OEM operated programs in the U.K. and Sweden.

1. U.K. Pilot Collection Experience

In 1996, a group of cellular phone manufacturers organized two year pilot programs to collect end-of-life cellular phones and the batteries that power them in the U.K. and Sweden. The group operated under the auspices of the European Trade Organization for the Telecommunications and Professional Electronics Industry (ECTEL). Many of the collected batteries were Ni-Cds which, in the case of the batteries collected in the U.K., were sent to France for recycling at SNAM.

The U.K. pilot was operated in conjunction with British Telecom outlets. Retail or distribution outlets were favored as collection points because of their widespread geographical coverage and accessibility to cell phone users. The pilot program was designed to make battery collection as trouble free as possible for consumers. A reverse distribution company, Loddon Holdings, was retained to handle the used battery collection and shipment operations in the UK. Loddon had considerable experience managing reverse distribution programs and familiarity with relevant regulatory compliance obligations, such as hazardous waste transportation and facility licensing.

Regrettably, in September of 1996, new special waste regulations took effect with respect to used Ni-Cd batteries. As a result, all of the participating retail outlets, as well as consolidation points, had to be licensed hazardous waste storage facilities and pay all associated fees. Considerable expenditures of time, money and effort, were incurred by program managers to ensure that all of the applicable special waste regulations were followed.

These regulations require notification of the Environment Agency at least 3 days prior to each used battery shipment. This seeming simple requirement rendered collection very difficult. Batteries ready for pick up at some collection sites had to await the expiration of the three day notice. As those shipments became timely, a neighboring location might give the consolidator notice of another batch of used batteries that, added to the first, would make a full load. These shipments could not be made together, however, because of the timing of the notification requirements. Large inefficiencies resulted, especially in more remote parts of the U.K. where transportation costs were already large.

The rules also set different requirements for large and small shipments. A vehicle visiting collection facilities is allowed a week to finish its rounds if its load is 400 kg. or less. If that load exceeds 400 kg. the batteries must reach their destination within 24 hours. This proved to be very disruptive of the normal method of making the rounds of collection facilities. Drivers had no ability to know whether or when a large shipment from one collection facility would completely disrupt the scheduled (and notified) collection run.

In short, the UK program pointed up the considerable limitations and costs imposed by the UK's classification of used Ni-Cd batteries as special waste.

2. Swedish Pilot Collection Experience

The ECTEL participants also established a two-year pilot program in Sweden. Used Ni-Cd batteries were collected in Sweden through the stores of five major retail chains. They were recycled domestically at the SAFT Sweden facility in Oskarshamn.

The Swedish pilot program was significantly easier to manage than the U.K program, largely because - notwithstanding the cadmium content of Ni-Cd batteries — end-of-life electronic products are not considered hazardous or special waste in Sweden. Thus, collected phones and batteries could be transported from retail outlets to consolidation points via common carriers. Retailers and consolidation points were also not required to have hazardous waste licenses. Shipping the batteries for recycling was even further simplified because the batteries were recycled domestically, so no OECD transboundary shipping requirements applied. The pilot program also highlighted the benefits of competitive pricing that arose from having a broader choice of contractors (consolidation facilities, haulers, etc.).

B. The Australian Experience

In Australia, there are Federal and state laws prohibiting the disposal of Ni-Cd batteries in landfills, however, no mandatory collection requirements.

The Australian Mobile Telecommunications Association (AMTA) has recently completed a six month trial that involved 140 retail stores in New South Wales collecting used mobile phone batteries. During the trial, AMTA collected over 100,000 batteries, which included Ni-Cd batteries, as well as other chemistries. The collected batteries were sent to a recycling facility operated by the Melbourne-based company, Ausmelt Limited.

As a result of the success of the trial program, the AMTA membership (which includes handset manufacturers and suppliers, carriers, retailers and service providers) has decided to launch a national program that initially will involve over 600 stores. The national program will collect and recycle batteries, handsets, and all mobile phone accessories.

According to AMTA's executive director, the program also will be seeking to make the recycling service available to other rechargeable battery suppliers/manufacturers in hopes that they may join the program and offer their customers the same service.

The trial program was funded by a $0,156 (US$ 0.1017) levy on each battery sold, which in turn funded all batteries collected. The new national program will involve a higher levy. The new levy will be $1.00 (US$ 0.6518) per handset sold, or $0.45 (US$ 0.2933) per battery for those companies supplying replacement batteries and accessories to the market.

C. The Mexican Experience

A pilot program to collect used Ni-Cd batteries is currently underway in Mexico. It was initiated in 1998, when a major electronic product manufacturer initiated a pilot program for the collection and recycling of used Ni-Cd batteries from 2-way radios. Under this pilot program, customers that returned used batteries to the company for recycling were given a discount on the purchase price of new replacement batteries. In six months over 10,000 Ni-Cd batteries were collected.

Because no facility capable of processing these batteries and recycling their constituent metals exists in Mexico, the collected units must be sent to the U.S. or elsewhere for recycling. To do so, however, requires compliance both with the OECD transboundary shipping requirements (notification and tracking forms) and national requirements. To date, Mexican environmental authorities (the Instituto Nationale de Ecología, or "INE") have required that the company register as a hazardous waste generator before export will be allowed. The company prefers not to do so, because of the implications of this characterization of their activities. It thus is pursuing INE permission to send the shipment without being identified as the generator.

The company has also been involved in discussions with the INE about adopting a regulatory scheme more tailored to management of used batteries. Dialogue currently is underway about initiating a rulemaking to reduce the domestic hazardous waste management requirements to facilitate Ni-Cd battery collection and recycling. It is expected that a workgroup will be convened in the near future to discuss the development of relaxed INE regulations. The manufacturer has offered to expand the pilot radio battery collection program to full-scale status if more manageable standards for used battery handling are adopted.

In the meantime, the collected used batteries are being stored in a suitable consolidation facility.

D. The U.S. Experience 1. Background

In the late 1980s, generalized commercial interest in promoting "green" attributes of their products spurred the rechargeable power industry to begin implementing nationwide collection-for-recycling programs. In addition, thirteen of the fifty U.S. states enacted laws to facilitate the collection and recycling of used rechargeable batteries. The specifics of these laws varied, but the majority mandated used Ni-Cd battery collection and recycling.

However, the difference between state mandates made impossible the adoption of identical programs in all of them. For example, some states specified what entities must act as collection points, while other states left the decision up to the rechargeable power industry. It also was uncertain in some states whether or not memory backup batteries were to be covered by the programs.

The situation became even more complicated because of a change in the U.S. hazardous waste management law. In 1990, the U.S. EPA changed its test protocol for determining what wastes should be classified as hazardous. The new toxicity test, called the "TCLP test," required that materials be crushed or cut up to a small particle size and exposed to an acetic acid solution. The constituents of the leachate were then measured against standards for (among other elements) cadmium and lead. The idea was to simulate the release of the battery's contents into a landfill environment over a protracted period of time. If excessive quantities of the hazardous constituents of concern were measured, the waste material was to be regulated as hazardous.

However, no consideration whatsoever had been given to the implications of this change on Ni-Cd battery recycling. Because the new test required that materials be ground up - thus breaching the integrity of battery casings — used Ni-Cd batteries failed the TCLP test for cadmium. As a consequence, for the first time the transportation, storage, handling and recycling of used Ni-Cd batteries became subject to the hazardous waste provisions of the Federal Resource Conservation and Recovery Act (RCRA) and its attendant regulations. These regulations require waste generators to obtain identification numbers from federal or state regulators; waste transporters to meet stringent safety, insurance and licensing requirements based on worst case assumptions about waste spillage; and collection and recycling facilities to acquire comprehensive and expensive permits.

But not all "waste" batteries were subjected to these requirements. By virtue of a historic policy-based exception, many RCRA requirements applicable to batteries from commercial generators did not apply to used batteries generated from households. Yet if a mixture of identical Ni-Cd batteries from household and commercial sources were collected, then all had to be regulated as hazardous waste.

To further add to the confusion, in the U.S. environmental regulations are enforced by the states, but only after the U.S. EPA approves each state's enforcement plan for consistency with the Federal program. States also can be more stringent than the Federal requirements. Thus, when the U.S. EPA decides to relax a requirement, states must act affirmatively to implement relaxed requirements. Nothing in the U.S. federal system requires them to act, so state programs are frequently inconsistent with the Federal model.

This complex array of regulatory requirements immediately resulted in the suspension of most voluntary collection and recycling programs previously set up or contemplated for Ni-Cd batteries. The administrative and liability burdens were too significant to be acceptable to the volunteer collectors. Because of the new classification of used Ni-Cd batteries as hazardous waste, large and small retailers refused to take part in their collection. Collection systems had become economically prohibitive to manage when the batteries had to be shipped under a hazardous waste manifest by costly hazardous waste carriers. Storing used batteries for a long enough period of time to allow for economic shipment was impossible because entities that store hazardous waste in excess of 90 days were required to have hazardous waste storage permits. Even in states where collection was mandated, compliance efforts were frustrated.

Moreover, even where used Ni-Cd batteries were collected, transportation costs skyrocketed. For instance, in 1991 shipping costs for truckload quantities increased by as much as 250 percent if a hazardous waste hauler ($3.00 to $3.50 per mile) had to be used in place of a common carrier ($1.40 per mile). Even greater increases applied to shipments of smaller quantities. For example, the cost of shipping three 55-gallon drums of used Ni-Cds from a generator in Minneapolis to International Metals Reclamation Company (INMETCO) in Ellwood City, Pennsylvania increased from $150.00-$200.00 for a common carrier to $1,273.00-$1,580.00 for a "backhaul" hazardous waste carrier (one that takes a load it would ordinarily not haul in order to avoid returning to its origin empty). The cost for a dedicated hazardous waste carrier was even higher, at $2115.00-$3,300 per load.

2. Government & Industry Cooperation on Regulations

In 1985, shortly after lead acid batteries first became regulated as hazardous waste, the U.S. EPA had implemented rules that exempted collectors and transporters of used lead acid batteries for bona fide recycling from the regulatory burdens of the hazardous waste program. This allowed participation in established reverse distribution collection programs by retailers, distributors and transporters to remain strong. (The rate of lead battery lead recycling is now better than 95%.)

Five years later, however, when the TCLP test was finalized, its potential adverse impact on Ni-Cd battery recycling was not recognized. Consequently, no parallel exemption was adopted.

In April 1991, Ni-Cd battery manufacturers filed a petition with the U.S. EPA that proposed for Ni-Cd batteries the adoption of an exemption similar to the one applicable to lead acid batteries.

EPA staff promptly indicated that they agreed in principle with the industry proposal. However, rather than extend their existing lead battery recycling exemption to

Ni-Cds, EPA decided to address the Ni-Cd battery recycling issue within the framework of a broader effort to foster the recycling of several other widely used products that the Agency believed should not be disposed of in municipal trash. Along with Ni-Cd batteries, these included unused pesticides, mercury-containing thermostats, and mercury-containing lamps. Due to the controversy that surrounded some of the other wastes that were being considered for coverage - not Ni-Cd batteries - it then took the Agency nearly four years to develop and promulgate the rule.

Finally, on May 11, 1995, EPA promulgated the "Universal Waste Rule." That rule's stated purpose was to reduce the amount of problem wastes entering the municipal solid waste stream and encourage their recycling or proper disposal. The rule significantly streamlined applicable regulations, including those related to generator notification, accumulation time limits, employee training, and shipping documentation. By allowing retailers, service centers, and institutional generators to collect and store used Ni-Cd batteries on site for up to one year, it opened the door for these entities to participate in collection programs. They also now could avoid the burdens and stigma of handling hazardous waste, hazardous waste generator notification, hazardous waste storage facility permits, shipping on a hazardous waste manifest, and using a hazardous waste hauler. Transportation became more feasible as well: common carriers may store spent Ni-Cd batteries for up to ten days at a transfer facility (loading docks, parking areas, etc.) without limitation. Movement of Ni-Cd batteries became subject to the same Department of Transportation (DOT) requirements that apply to the batteries when they are shipped as new products.

Notably, the Universal Waste Rule did not reduce regulatory burdens on Ni-Cd recycling facilities. They continue to be required to have hazardous waste facility permits, facility closure plans and demonstrations of financial responsibility, employee training, storage requirements, and recordkeeping and reporting obligations. This is appropriate, as these facilities open the batteries and crush the constituents. Such activity, if done improperly, could represent a threat to human health and the environment.

3. Inconsistency of State Regulations Requires Change in Federal Law

By simplifying collection and making transportation more affordable, the Universal Waste Rule served to encourage the establishment of a national collection and recycling program for Ni-Cd batteries. Under the U.S. federal system, however, this rule could not take effect nationwide until it was individually adopted by all fifty states. The industry and U.S. EPA were justly concerned that this could take many years. Furthermore, without changes in Federal law, states were free to accept the provisions of the new regulation or to continue to apply inconsistent requirements. To bring about a consistent and efficient used battery collection system, harmonization was necessary. (This situation parallels the current state of inconsistent regulatory requirements among the 29 OECD countries, where conflicting requirements have stifled efficient collection.)

To this end, the industry approached the Congress and urged the passage of legislation to fix this problem by creating a standardized national system. After considerable effort, such legislation was enacted on May 13, 1996. Formally named the Mercuiy-Containing and Rechargeable Battery Management Act, but generally referred to as the "Battery Act", this law facilitates Ni-Cd recycling by, among other things, making the Universal Waste Rule effective immediately in all fifty states for all batteries covered by the Battery Act, including Ni-Cd batteries

Acknowledging the steady increase in the use of rechargeable batteries, as well as potential environmental impacts resulting from their improper disposal, EPA issued a statement that it considered the law to be "a major step forward in the effort to facilitate the recycling of nickel-cadmium (Ni-Cd) batteries " Most importantly, the rule made possible the national collection program for used Ni-Cd batteries that today is being implemented through the industry-supported Rechargeable Battery Recycling Corporation.

£. The Canadian Experience

Canada's federal transportation and environmental agencies, as well as regional governments, classify Ni-Cd batteries as hazardous waste. As has been the case in the U.S. and many other countries across the world, this classification made it very difficult for program operators to find entities willing to undertake the role of Ni-Cd battery collector.

Nonetheless, industry proponents of collection for recycling, acting through the Rechargeable Battery Recycling Corporation of Canada (RBRC), a subsidiary of the U.S. Rechargeable Battery Recycling Corporation, in January of 1997 initiated a collection program. Due to regulatory constraints, the program was limited to retail take-back. With the help of Environment Canada, Natural Resources Canada, and Transport Canada, RBRC was able to convince the province and territory governments that retailers who collect spent Ni-Cd batteries should not have to register as hazardous waste generators. This removed a substantial disincentive to retail participation in RBRC's Canadian program, but RBRC wanted to expand the program to collect used batteries from businesses, institutions (e.g., hospitals, police and fire stations), government agencies, and municipalities and counties.

On April 20, 1999, after two years of efforts to negotiate reduced management standards for non-retail program participants, Transport Canada issued to RBRC an Equivalent Level of Safety Permit (ELSP). The ELSP allows RBRC and its designated collectors and transporters to handle used Ni-Cd batteries as common goods (e.g., repeals package marking and recordkeeping and reporting obligations). To get the permit, RBRC demonstrated that its Ni-Cd program provides a level of safety that is equivalent to the Transportation of Dangerous Goods Regulations.

On June 11, 1999, the Ontario Ministry of the Environment (MOE) gave RBRC a provisional Certificate of Approval (COA) that exempts RBRC from having to use a permitted hazardous waste facility to accumulate Ni-Cds prior to shipment to recycling facilities. This COA was primarily intended to give RBRC a broader and more affordable choice of consolidators.

Unfortunately, the COA is only good in Ontario. Canada's remaining provinces and territories have yet to adopt a similar exemption.

The OECD transboundary requirements for shipping used Ni-Cd batteries from Canada to the U.S. continue to make the RBRC collection program more cumbersome and less cost efficient than it would be if streamlined controls could be applied to shipments to pre-approved facilities like INMETCO. The OECD requirements, as they are today, preclude retailers, service centers, municipalities, and other front line collectors from being able to even consider sending used battery collection boxes directly to approved recycling facilities within the OECD.

F. Transboundary Movement Within the OECD

Ni-Cd battery processing and recycling involves a number of processes, including physical component separation and applying chemical and/or thermal stresses to the resulting materials. Some of these materials are toxic, and these operations involve a number of workplace dangers. Thus, these facilities are technically sophisticated and costly to operate. Most nations require that operators obtain and comply with hazardous waste treatment, storage and disposal facility permits.

Because of these characteristics, and as noted above, only a handful of Ni-Cd recycling facilities exist in the world. They are located in France, Germany, Japan, Australia, the U.S., Korea and Sweden. Ni-Cd batteries collected in any other country must be shipped across national borders if they are to be recycled.

Spent Ni-Cd batteries now move between OECD nations under "amber list" controls, plus any national controls imposed by the member nations involved. Amber transboundary controls are intended, among other things, to provide sufficient notice to the nation of import to insure that the shipments entering its territory are destined for a facility capable of managing them in an environmentally sound manner. Such controls also alert any transit nation to the fact that a cargo of recyclable material that presents a potential environmental threat is passing through its jurisdiction.

Under the amber controls, shipments of used Ni-Cd batteries require 45 days' advance notification to receiving and transit counties. However, a general notification can be filed to cover multiple shipments from, through, and to designated countries for a one-year period. Within thirty days of receipt of a notification, concerned countries must consent to the shipment before it can commence. Shipments sent to pre-approved recovery operations require only ten days' advance notice to concerned countries.

The OECD notification form for amber wastes requires:

• generator, shipper and consignee identification information;

• a designation of the countries of import, transit and export;

• waste composition and quantity information;

• a certification that the information provided on the foregoing is complete and correct;

• a certification that legally enforceable contractual obligations have been entered into to provide for alternate management of the shipment if its disposition cannot be carried out as specified; and

• a certification that applicable insurance or financial guarantees are in force.

The OECD movement/tracking form requires the same information related to generator, shipper and consignee identification; the countries of import, transit and export; and waste composition and quantity. It also includes a certification statement verifying the accuracy of the information on the form and confirming that all necessary consents have been received or tacitly obtained, and in the case of pre-authorized facilities, that no objections from the concerned countries have been raised.

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