E-waste Export License - Overview
E-waste is the fastest-growing waste stream globally. 50 - 60 million tons of e-waste are produced every year. However, due to its complex disposal needs, e-waste is often exported from India to other countries. Although there are technological solutions for processing e-waste, these are usually costly. So, e-waste export is the cheaper option.
Not only e-waste but plastic scrap and catalyst converters - usually found in used vehicles, honeycomb and ceramic- are exported from India. All these items are exported to extract Platinum. This, in return, helps the government improve India's GDP. However, various laws and policies are implemented to regulate e-waste export from India at different governance scales, like the International Basel Convention. Also, a MoEF&CC Licence is required for the same. Up next in this article are norms like this and much more.
Ministries Regulating E-waste Export from India
- Ministry of Environment, Forests & Climate Change or MoEF&CC Regulates e-waste export from India.
- State Pollution Control Boards or SPCBs/Pollution Control Committees or PCCs - Analysing applications for exports and recommendations to MoEF&CC.
- Ministry of Commerce & Industry - Import and export of e-waste.
- Directorate General of Foreign Trade (DGFT) - Refusal of licence for hazardous and other wastes prohibited for export.
- Port authority Verify the export concerning EPR under E-waste Management Rules, 2016. Moreover, the authority is liable for acting against exporters. These exporters have violated norms. These are as per the Customs Act, 1962. They are also as per the Indian Ports Act, 1908.
Rules governing the e-waste export from India
According to the E-waste (Management and Handling) Rules, 2008, any export of e-waste from India must follow the process mentioned in the Basel Convention on the Control of Transboundary Movement of Hazardous Wastes.
Hazardous & Other Wastes (Management & Transboundary Movement) (HOWM) Rules, 2016
Definitions
An exporter is any occupier or person under the jurisdiction of the exporting nation which exports wastes, including the country which exports e-waste;
Basel Convention is the UNs Environment Programme Convention on the Control of Transboundary Movement of Hazardous Wastes & their Disposal;
Other wastes imply wastes mentioned in Part B & D of Schedule III for export and include all such waste produced indigenously within the nation;
Transboundary movement is any movement of hazardous or other wastes. It is from a site under the jurisdiction of one nation. It is to or through a place under the jurisdiction of another nation. Or it is to or through a site not under the jurisdiction of any nation. It is the case provided that at least two nations are involved in the movement;
Export (transboundary movement) of e-waste
MoEF&CC is the nodal ministry to handle the transboundary movement of the e-waste following the norms of these rules.
Strategy for scrap waste export from India
(1) The e-waste export from India included in Parts A, and B of Schedules III and VI must be with the MoEF permission. In the case of applying for e-waste export, it is considered based on the prior informed consent of the importing nation.
(2) The export of e-waste not mentioned in Schedule III but exhibiting the hazardous characteristics mentioned in Part C of Schedule III needs prior written MoEF permission before it is exported from India.
(3) Electrical and electronic assemblies (EEAs) & components manufactured in and exported from India, if found defective or non-functional, are imported back by Original Equipment Manufacturers (OEMs) within one year from the date of export.
Procedure for Export of E-waste from India
- (1) Any occupier wishing to export waste mentioned in Part A of Schedule III, Part B of Schedule III and VI, must apply in Form 5 along with insurance cover to the MoEF&CC for the intended transboundary movement of the wastes along with the prior informed consent in writing from the importing nation related to the wastes mentioned in Part A of Schedule III and VI.
- (2) On receiving the application, the Ministry grants permission for the intended export within two months from day of submission of the complete application after imposing certain conditions as it may consider necessary.
- (3) The Ministry forwards a copy of the issued permission to the SPCB of the state where the waste is produced and the PCC of the state where the export port is located. Another copy is also sent to the concerned Port and Customs authorities to ensure compliance with the conditions of the export permission.
- (4) The exporter must ensure the shipment has the movement document in Form 6.
- (5) The exporter must also ensure that no consignment is shipped before the prior informed consent is received from the importing nation, wherever applicable.
- (6) The e-waste exporter must retain the records of the waste he exports in Form 3, and that record be available for inspection.
Illegal traffic
(1) The e-waste export from India, respectively is deemed illegal if-
- (i) the MoEF permission has been obtained via misrepresentation, falsification or fraud; or
- (ii) it is without permission of the Central Government; or
- (iii) it doesn’t conform to the shipping information given in the movement documents; or
- (iv) it results in deliberate disposal (i.e., dumping) of hazardous or other waste in contravention of the Basel Convention & general principles of domestic or international law.
Transportation of E-waste
(1) The transport of e-waste must be as per the norms of these rules & the guidelines framed by the Central Government under the Motor Vehicles Act, 1988 & the instructions framed by the CPCB from time to time.
(2) In case of e-waste transportation for final disposal to a facility located in a state except the state where the waste is produced, the sender must get a ‘No Objection Certificate’ from the SPCB of both states.
(3) The occupier must provide the transporter with the relevant details in Form 9 related to the nature of the wastes and steps to be taken in an emergency and must label the hazardous and other waste containers according to Form 8.
(4) In the case of transportation of e-waste, the responsibility of safe transport must be either of the receiver or the sender, whosoever arranges the transport and has the compulsory authorisation for transport from the related SPCB. This responsibility must be clearly indicated in the manifest.
Liability of exporter of scrap waste from India
The exporter stands liable for all damages caused to the third party or the environment because of improper handling and management of the e-waste.
General Requirements for E-waste Export from India
The exporter intending to export the e-waste from India must provide the following details -
- Importer or Exporter (name and address) in India
- Importer or exporter (name and address) outside of India
- Details of waste to be imported or exported
- (a) Quantity
- (b) Basel No.
- (c) Single/multiple movements
- (d) Chemical composition of the waste (attach details), where applicable
- (e) Physical characteristics
- (f) Special handling requirements, if applicable
- For Schedule III A hazardous waste, whether Prior Informed Consent has been obtained
- Transboundary movement document
- Exporter’s declaration for hazardous and other waste:
Instructions to follow concerning Export of E-waste under Hazardous and Other Wastes (Management, Handling and Trans-boundary Movement) Rules, 2016
(a) The application must be addressed to Joint Director, Hazardous Substances Management Division, Jal Block, 2nd Floor, Indira Paryavaran Bhawan, New Delhi-110003.
(b) From the 73rd meeting of the EC, all applications seeking export permissions under these rules must be submitted online via the Ministry's waste management portal (www.iwms.nic.in).
(c) Applicants are requested to visit the website of the Ministry often for minutes, agenda, meeting notice and other such details (http://www.moefnic.in/division/importexport)
(d) Please make sure that the contact person's e-mail address and mobile number are mentioned in the forwarding letter of the application.
(e) For other clarification/queries, the exporter of e-waste can contact the Ministry on working days.
(f) The applicant is applying for the first time in the Ministry; s/he may invariably attend the EC Meeting for a technical discussion.
(g) After the acceptance of the online application in the Ministry, the applicant must submit a hard copy of the entire set of documents attached to the application to the Ministry via post or in person before/during the scheduled meeting of the EC.
(h)The exporters called for presentation by the EC must ensure their presence within two ensuing meetings. Their application is cancelled upon failing to do so, and they'll have to reapply.
(i) The list of the documents to be submitted to the Ministry is as follows -.
- (a) Justification for export
- (b) Form 5 Other Waste Rules, 2016
- (c) Valid Consent to Operate CTO
- (d) Insurance policy covering liability to health and environment during transit
- (e) Acknowledgement for receiving the copy of the application from the concerned PCC/SPCB
- (g) Documents stating the status of employment generation mentioning the count of people who benefitted
- (h) Copy of the agreement between the buyer and importer/seller and exporter
- (i) Copy of the previous latest permission issued by the Ministry
Frequently Asked Questions
-
1. What is included in the list of hazardous wastes applicable for export with prior informed consent [Annexure VIII of the Basel Convention*]?
Basel No.
Description of Hazardous Wastes
(1)
(2)
A1
Metal and Metal bearing wastes
A1010
Metal wastes & waste consisting of alloys of any of the following but excluding such wastes listed explicitly in Part B and Part D
- Antimony
- Cadmium
- Lead
- Tellurium
A1020
Waste having constituents or contaminants, excluding metal wastes in massive form, any of the following:
- Antimony, antimony compounds
- Cadmium, cadmium compounds
- Lead, lead compounds
- Tellurium, tellurium compounds
A1040
Waste having metal carbonyls as constituents
A1050
Galvanic sludges
A1070
Leaching residues from zinc processing, dust & sludges like jarosite, hematite, etc.
A1080
Waste zinc residues not included in Part B, having lead and cadmium in concentrations sufficient to exhibit hazard characteristics indicated in Part C
A1090
Ashes from the insulated copper wire incineration
A1100
Dust & residues from gas cleaning systems of copper smelters
A1120
Waste sludges, except anode slimes, from electrolyte purification frameworks in copper electrorefining & electrowinning processes
A1140
Waste cupric chloride and copper cyanide catalysts not in liquid form note the related entry in Schedule VI
A1150
Precious metal ash from the incineration of printed circuit boards not included in Part B.
A1160
Waste lead acid batteries, whole or crushed
A1170
Unsorted waste batteries excluding mixtures of only Part B batteries. Waste batteries not specified in Part B contain constituents mentioned in Schedule II to an extent to render them hazardous.
A2
Wastes having principally inorganic constituents, which may contain metals and organic materials
A2010
Glass waste from cathode-ray tubes & other activated glasses
A2030
Waste catalysts but excluding such wastes specified in Part B
A3
Wastes with principally organic constituents, which may include metals & inorganic materials
A3010
Waste from the processing and production of petroleum coke & bitumen
A3020
Waste mineral oils not for their originally intended use
A3050
Wastes from production, formulation & use of resins, latex, plasticisers, glues or adhesives, excluding such wastes specified in Part B (B4020)
A3120
A fluff-light fraction from shredding
A3130
Waste organic phosphorus compounds
A4
Wastes that may contain either organic or inorganic constituents
A4010
Wastes from the preparation, production and use of pharmaceutical products but excluding such waste specified in Part B
A4040
Wastes from the manufacture, formulation & use of wood-preserving chemicals (does not include wood treated with wood-preserving chemicals)
A4070
Waste from the formulation, production & use of inks, dyes, pigments, paints, lacquers, and varnish, excluding those specified in Part B (B4010)
A4100
Wastes from industrial pollution control equipment for cleaning industrial off-gases but excluding such wastes specified in Part B
A4120
Wastes that contain or are contaminated with peroxides.
A4130
Wastes packages and containers containing Schedule II constituents in a concentration sufficient to exhibit Part C of Schedule III hazard characteristics.
A4140
Waste consisting of or containing off-specification or outdated chemicals (unused within the period recommended by the manufacturer) corresponding to constituents mentioned in Schedule II and exhibiting Part C of Schedule III hazard characteristics.
A4160
Spent activated carbon not included in Part B, B2060.
-
2. What is included in the list of other wastes applicable for import and export and not requiring Prior Informed Consent [Annex IX of the Basel Convention*]?
Basel No.
Description of Hazardous Wastes
(1)
(2)
B1
Metal and metal-bearing wastes
B1010
Metal and metal-alloy wastes in the metallic, non-dispersible form:
- Thorium scrap
- Rare earth scrap
UB1020
Uncontaminated, clean metal scrap, including alloys, in bulk finished form (sheet, beams, plates, rods, etc.), of:
- Antimony scrap
- Beryllium scrap
- Cadmium scrap
- Lead scrap (excluding lead acid batteries)
- Tellurium scrap
- Selenium scrap
B1030
Refractory metals containing residues
B1031
Molybdenum, titanium, tungsten, niobium, tantalum, rhenium metal & metal alloy wastes in form of metallic dispersible (metal powder), except such wastes as mentioned in Part A under entry A1050, Galvanic sludges
B1040
Scrap assemblies from electrical power generation not polluted with lubricating oil, PCT or PCBto an extent to render them hazardous
B1050
Heavy fraction scrap, mixed non-ferrous metal, containing cadmium, antimony, lead & tellurium mentioned in Schedule II in concentrations sufficient to exhibit Part C faetures
B1060
Waste selenium & tellurium in metallic elemental form, including powder
B1070
Waste of copper and its alloys in dispersible form, unless they have any of the constituents listed in Schedule II to the extent that they exhibit Part C features
B1080
Zinc ash & residues, including zinc alloys residues in dispersible form unless they have any of the constituents listed in Schedule II in a concentration such as to exhibit Part C characteristics
B1090
Waste batteries conform to a standard battery specification, excluding those made with cadmium, lead or mercury.
B1100
Metal-bearing wastes arising from the melting, smelting and refining of metals:
- Slags from copper processing for further refining or processing having arsenic, lead or cadmium
-
Wastes of refractory linings, including crucibles, arising from smelting of copper
- Tantalum-bearing tin slags with not more than 0.5% tin
- Slags from processing of precious metals for further refining
B1110
Used Electrical and electronic assemblies other than those listed in Part D of Schedule III
Electronic assemblies having only of metals or alloys
Waste electrical and electronic assemblies or scrap (including printed circuit boards) not having components such as accumulators and other batteries included in Part A of Schedule III, mercury switches, glass from cathode-ray tubes & other activated glass & PCB-capacitors, or not contaminated with Schedule II constituents like mercury, cadmium, lead, polychlorinated biphenyl) or from which these have been eliminated to the extent that they do not possess any of the characteristics contained in Part C of Schedule III (note the related entry in Schedule VI, A1180)
B1120
Spent catalysts, except liquids used as catalysts, containing any of the following:
Transition metals, excluding waste catalysts (spent catalysts, the liquid-used catalysts or other catalysts) in Part A and Schedule VI:
- Scandium - Titanium
- Vanadium - Chromium
- Manganese - Iron
- Cobalt - Nickel
- Copper - Zinc
- Yttrium - Zirconium
- Niobium - Molybdenum
- Hafnium - Tantalum
- Tungsten - Rhenium
Lanthanides (rare earth metals):
- Lanthanum - Cerium
- Praseodymium - Neodymium
- Samarium - Europium
- Gadolinium - Terbium
- Dysprosium - Holmium
- Erbium - Thulium
- Ytterbium - Lutetium
B1130
Cleaned spent precious metal-bearing catalysts
B1140
Precious metal-bearing residues in solid form, which have traces of inorganic cyanides
B1150
Precious metals & alloy wastes (silver, gold, the platinum group but not mercury) in a dispersible form, non-liquid form with appropriate packaging and labelling
B1160
Precious metal ash from the incineration of printed circuit boards (note the related entry in Part A A1150)
B1170
Precious metal ash from the photographic film incineration
B1180
The waste photographic film contains silver halides & metallic silver
B1190
Waste photographic paper having silver halides & metallic silver
B1200
Granulated slag produced from the manufacture of iron & steel
B1210
Slag arising from the manufacture of iron & steel, including slags as a source of Titanium dioxide and Vanadium
B1220
Slag from zinc production, chemically stabilised, having a high iron content (above 20%) and processed as per industrial specifications mainly for construction.
B1230
Mill scale produced from the manufacture of iron & steel
B1240
Copper Oxide mill-scale
B2
Wastes having principally inorganic constituents, which may have metals and organic materials
B2010
Wastes from mining operations in the non-dispersible form:
- Natural graphite waste
- Slate wastes
- Mica wastes
- Nepheline, leucite & nepheline syenite waste
- Fluorspar waste
- Feldspar waste
- Silica wastes in solid form, excluding those utilised in foundry operations
B2020
Glass wastes in the non-dispersible form:
- Cullet & other waste & scrap of glass except for glass from cathode-ray tubes & other activated glasses
B2030
Ceramic wastes in the non-dispersible form:
- Cermet wastes and scrap (metal-ceramic composites)
- Ceramic-based fibres
B2040
Other wastes having principally inorganic constituents:
- Waste gypsum wallboard or plasterboard generated from the demolition of buildings
- Partially refined calcium sulphate generated from flue gas desulphurisation (FGD)
-
Slag from copper production, chemically stabilised, containing a high iron content (more than 20%) and processed according to industrial specifications mainly for construction and abrasive applications
- Sulphur in solid form
- Limestone from the production of calcium cyanamide (pH<9)
- Sodium, potassium, calcium chlorides
- Carborundum (silicon carbide)
- Broken concrete
- Lithium-tantalum and lithium-niobium containing glass scrap
B2060
Spent activated carbon not containing any of Schedule II constituents to the extent they exhibit Part C characteristics, for example, carbon as an outcome from potable water treatment & processes of the food industry & vitamin production (note the related entry in Part A A4160)
B2070
Calcium fluoride sludge
B2080
Waste gypsum arising from chemical industry activities not included in Schedule VI (note the related entry in A2040)
B2090
Waste anode butts from aluminium or steel production made of bitumen or petroleum coke & cleaned to normal industry requirements (excluding anode butts from chlor alkali electrolyses and from the metallurgical industry)
B2100
Waste hydrates of aluminium & waste alumina & residues from alumina generation, excluding such materials used for gas cleaning, flocculation or filtration processes
B2130
Bituminous material (asphalt waste) from road construction & maintenance, not containing tar (note the related entry in Schedule VI, A3200)
B3
Wastes having principally organic constituents, which may have metals and inorganic materials
B3027
Self-adhesive label laminate waste containing raw materials used in label material production
B3030
Textile wastes
The following materials, given that they're not mixed with other wastes & are produced to a specification:
- Silk waste (including cocoons unsuitable for reeling, garnetted stock & yarn waste)
• not combed or carded
• other
- Waste of wool or of coarse or fine animal hair, excluding garnetted stock but including
yarn waste
• other waste of fine animal hair
or of wool
• noils of fine animal hair or of wool
• waste of coarse animal hair
- Cotton waste (including garnetted stock and yarn waste)
• yarn waste (including thread waste)
• garnetted stock
• other
- Flax tow & waste
- Tow & waste (including yarn waste & garnetted stock) of true hemp (Cannabis sativa L.)
- Tow & waste (including garnetted stock and yarn waste) of jute & other textile bast fibres (excluding flax, true hemp and ramie)
- Tow, noils & waste (including yarn waste and garnetted stock) of
coconut
- Tow & waste (including yarn waste & garnetted stock) of sisal & other textile fibres of the genus Agave
- Tow, noils and waste (including garnetted stock & yarn waste) of abaca (Manila hemp or Musa textilis Nee)
- Tow, noils & waste (including garnetted stock & yarn waste) of ramie & other vegetable textile fibres not elsewhere specified or included
- Waste (including yarn waste, noils & garnetted stock) of manmade fibres
• of artificial fibres
• of synthetic fibres
- Worn clothing & other worn textile articles
- Used rags, rope, scrap twine, cordage and cables and worn-out articles of twine, rope, cordage or cables of textile materials
• sorted
• other
B3035
Waste textile floor coverings, carpets
B3040
Rubber Wastes
The following materials, provided they're not mixed with other wastes:
-
Other rubber wastes (excluding such wastes mentioned elsewhere)
- Waste & scrap of hard rubber (e.g., ebonite)
B3050 Untreated cork & wood waste:
- Wood waste & scrap, whether or not agglomerated in briquettes, logs, pellets or same forms
- Cork waste: granulated, crushed, or ground cork
B3060 Wastes genereated from agro-food industries provided it is not infectious:
- Wine lees
- Dried and sterilised vegetable waste, residues & byproducts, whether or not in the pellets form, of a kind used in animal feeding, not elsewhere included or mentioned
- Degras: residues arising from the treatment of fatty substances or animal or vegetable waxes
- Waste of bones and horn cores, unworked, defatted, simply prepared (but not cut to shape), degelatinised or treated with acid
- Fish waste
- Cocoa shells, skins, husks and other cocoa waste
- Other wastes from the agro-food industry, excluding byproducts that meet national and international requirements and standards for human or animal consumption
B3070
The following wastes:
- Waste straw
- Waste of human hair
- Deactivated fungus mycelium from penicillin generation to be used as animal feed
B3080
Waste parings and a rubber scrap
B3090
Paring & other wastes of leather or of composition leather not ideal for the manufacture of leather items, excluding leather sludges, not containing hexavalent chromium compounds and biocides (note the related entry in Schedule VI, A3100)
B3100
Leather dust/ash/sludges or flours not having hexavalent chromium compounds/biocides (note the related entry in Schedule VI, A3090)
B3110
Fellmonger wastes not having hexavalent chromium compounds/biocides, or infectious substances (note the related entry in Schedule VI, A3110)
B3120
Wastes having food dyes
B3130
Waste polymer ethers & waste non-hazardous monomer ethers incapable of forming peroxides
B3140
Waste pneumatic & other tyres, excluding those which don't lead to resource recovery, recycling, or reclamation but not for direct reuse
B4
Wastes that may contain either inorganic or organic constituents
B4010
Wastes consisting mainly of water-based or latex paints, inks, & hardened varnishes not having heavy metals, organic solvents, or biocides to an extent to render them hazardous (note the related entry in Part A, A4070)
B4020
Wastes from formulation, production and use of resins, latex, plasticisers, glues or adhesives not listed in Part A, free of solvents and other contaminants to the extent that they don't exhibit Part C characteristics (note the related entry in Part A, A3050)
B4030
Used single-use cameras with batteries not included in Part A
-
3. What is included in the list of other wastes applicable for import and export without permission from the MoEF&CC [Annex IX of the Basel Convention*]?
Basel No.
Description of Hazardous Wastes
(1)
(2)
B1
Metal and metal-bearing wastes
B1010
Metal and metal-alloy wastes in the non-dispersible, metallic form :
- Precious metals (gold, Platinum, silver but not mercury) * *
- Iron and steel scrap * *
- Nickel scrap * *
- Aluminium scrap* *
- Zinc scrap * *
- Tin scrap * *
- Tungsten scrap * *
- Molybdenum scrap * *
- Tantalum scrap * *
- Cobalt scrap * *
- Bismuth scrap * *
- Titanium scrap * *
- Zirconium scrap * *
- Manganese scrap * *
- Germanium scrap * *
- Vanadium scrap * *
- Hafnium scrap * *
- Indium scrap * *
- Niobium scrap * *
- Rhenium scrap * *
- Gallium scrap * *
- Magnesium scrap * *
- Copper scrap * *
- Chromium scrap * *
B1050
Mixed non-ferrous metal, heavy fraction scrap, containing metals other than specified in Part B1050 and not containing constituents mentioned in Schedule II in concentrations sufficient to exhibit Part C characteristics* *
B1100
Metal-bearing wastes arising from the melting, smelting and refining of metals:
- Hard Zinc spelter * *
- Zinc-containing drosses * *:
~ Galvanising slab zinc top dross (>90% Zn)
~ Galvanising slab zinc bottom dross (>92% Zn)
~ Zinc die casting dross (>85% Zn)
~ Hot dip galvanisers slab zinc dross (batch) (>92% Zn)
~ Zinc skimmings
- Aluminium skimmings (or skims), excluding salt slag
B1110
Electrical & electronic assemblies (EEAs) (including printed circuit boards, electronic components & wires) intended for direct reuse, not for recycling or final disposal.
- Used electrical and electronic assemblies imported for repair and to be reexported back after repair within one year of import * * *
- Used electrical and electronic assemblies imported for rental purposes and reexported back within one year of import * * *
- Used electrical and electronic assemblies exported for repair and to be reimport after repair
- Used electrical and electronic assemblies imported for testing, research and development, and project work purposes and to be reexported back within three years from the date of import * * *
- Spares imported for warranty replacements provided an equal number of defective or non-functional parts are exported back within one year of the import * * *
- Used electrical and electronic assemblies imported by the Ministry of Defence, Department of Space and Department of Atomic Energy * * *
- Used electrical and electronic assemblies (not in bulk; quantity less than or equal to three) imported by the individuals for their personal uses
- Used Laptop, Personal Computers, Mobile, and Tablet up to 01 number each imported by organisations in a year
- Used electrical and electronic assemblies owned by individuals and imported on the transfer of residence
- Used multifunction print and copying machines (MFDs)* * * *
- Used electrical and electronic assemblies imported by airlines for aircraft maintenance and remaining either on board or under the custodianship of the respective airline's warehouses located on the airside of the custom-bonded areas.
B3
Wastes having principally organic constituents, which may have metals and inorganic materials
B3020
Paperboard, Paper & paper product wastes * *
The materials given below, given that they're not mixed with hazardous wastes:
Waste & scrap of paperboard or paper of:
- unbleached paper/paperboard/of corrugated paper/paperboard
- other paperboard or paper, made especially of bleached chemical pulp, not coloured in the mass
- paperboard or paper made mainly of mechanical pulp (such as, newspapers, journals and similar printed matter)
- other, including but not limited to
(1) laminated paperboard
(2) unsorted scrap
B3140
Aircraft tyres are exported to Original Equipment Manufacturers for re-treading and reimported after re-treading by airlines for aircraft maintenance and remaining either on board or under the custodianship of the respective airline's warehouses located on the air side of the custom bonded areas.