Environmental Technologies Industries
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Market Plans

Taiwan Environmental Export Market Plan
Chapter 6 - Hazardous Waste Market

Toxic and hazardous waste remain a serious problem for Taiwan as extensive industrial pollution and heavy pesticide use have led to substantial soil and groundwater pollution. Although little action has been taken to control this pollution, the Taiwan Environmental Protection Administration (TEPA) is compiling a list of toxic and hazardous substances in preparation for more stringent regulatory reform.

Regulatory Infrastructure

Solid Waste Disposal Act
Hazardous waste is governed under the Solid Waste Disposal Act. TEPA has established a manifest system to track hazardous waste generation and disposal. The current manifest system relies on self-disclosure. Companies are required to obtain permission to treat, import, or export hazardous waste.

However, there are currently no standards for soil or groundwater quality. Likewise, there are no regulations governing cleanup or remediation of soil or groundwater pollution.

Regulatory Changes
Amendments were passed in October 1997 changing the system for characterizing toxic chemicals and requiring toxic waste handlers to obtain insurance. More significantly, the law includes a community right-to-know clause that requires public disclosure of the use of certain chemicals. The details of the disclosure mechanism are currently being developed, but improved tracking of chemicals may allow TEPA to better characterize hazardous waste trails. Under the newest regulations, all medical waste must be incinerated even after sterilization has been performed.

The revised draft of the Soil Pollution Control Act is due to be submitted to the Legislative Yuan for review sometime in 1999. The highly controversial draft of the act needs resolution on numerous issues, particularly with respect to liability. For example, polluters will be responsible for cleaning up any soil or groundwater contamination caused by their actions. Where the identity of the polluter is undetermined, TEPA is studying the feasibility of establishing a Superfund-type program to pay for site cleanups. In addition, soil pollution standards and regulations are to be promulgated following the passage of the act. Passage of the revised legislation is inevitable in the long run; however, the history of the legislation shows that it is unlikely to be passed quickly.

Hazardous Waste Treatment and Disposal Facilities
There are no current figures on the size of the hazardous waste market. Existing information is sparse and unreliable because TEPA relies on interviews and self-reporting to generate most of its data on hazardous waste generation. Most large companies keep detailed records, but many people in the waste management industry are skeptical that the amounts reported actually reflect the true amounts generated. The problem is further complicated by the vast number of small- to medium-sized companies that do not keep records and often change their manufacturing process (and therefore their waste) every two to three years. According to waste industry sources, a large amount of hazardous waste simply goes unreported.

As a consequence, TEPA has encountered significant difficulties in trying to track hazardous wastes. The most up-to-date figures from a 1991 study place hazardous waste generation at roughly 650,000 tons per year (see table 18). Waste industry experts expect that the actual number is significantly higher.

At the moment, there are 21 licensed hazardous waste treatment companies, most of whom provide various forms of intermediate treatment. Most hazardous waste in Taiwan is treated by solidification, distillation, or stabilization and then buried in sanitary landfills. Some sectors such as solvent distillation only have two to three licensed treatment companies. Taiwan has no secure landfills, and there are only a handful of private incinerators capable of handling hazardous waste. Rethmann and Cleanaway are the only international companies in the industrial hazardous waste markets, although many local waste management companies rely on imported technology.
Table 18 - Estimated Hazardous Waste Volume vs. Licensed Treatment Capacity
Estimated Annual Volume of Hazardous Waste
650,000 tons
Licensed Treatment Capacity
560,000 tons
Source: Taiwan Environmental Protection Agency

Currently, the only public industrial waste incinerator designed specifically to dispose of hazardous wastes is located in the Dafa Industrial Park in southern Taiwan. The site began operation in June 1998 and has a capacity of roughly 100 tons per day. The facility primarily handles scrap metal generated by factories in the industrial park, but fees have not yet been determined. There are currently no plans for additional large-scale centralized public facilities.

Long-Term Hazardous Waste Disposal Strategy
As with industrial waste incinerators, TEPA hopes to encourage private-sector investment in developing hazardous waste facilities. Recognizing the need to improve hazardous waste data and tracking attract investors, TEPA commis-sioned a detailed study of hazardous waste generation in 1998. The study's data will be used to improve enforcement of hazardous waste regulations through the new computerized tracking system. TEPA hopes improved enforcement and better data on hazardous waste generation will raise investor confidence. So far, TEPA has not released any estimates on the types or number of facilities needed. There has been talk of a possible build-operate-transfer (BOT) or build-operate-own (BOO) project in 1999, but details are not yet available.

Barriers to Entry
As with all solid waste disposal, obtaining land is one of the biggest obstacles to developing private facilities. High land prices and siting problems have combined to discourage many potential investors. The Industrial Development Bureau's new policy to develop waste disposal facilities on a BOO/BOT basis inside industrial parks may help resolve siting obstacles.

Hazardous Waste Characterization in Taiwan

The definition of hazardous waste in Taiwan is based on promulgated listings and the characteristics exhibited by the waste. The primary list is based on industrial category. TEPA has developed a list of wastes generated in specific production processes, with particular attention paid to industrial categories considered hazardous. To complement this list, TEPA has also developed a second list of toxic chemicals also categorized as hazardous waste.

In addition to listed materials, TEPA has also developed nine characteristics that define hazardous waste. Wastes demonstrating the following character-istics are considered hazardous:
  • Leachate within range specified by TEPA
  • Flammable wastes
  • Infectious waste
  • Scrap metals listed by TEPA
  • Nonferrous metals, including lead and cadmium
  • Corrosive wastes
  • Reactive wastes
  • Asbestos
  • Polychlorinated biphenyls above 50 ppm

Aside from siting, the other major barrier lies in securing a waste stream. Given the current weaknesses in tracking and controlling the disposal of hazardous wastes, many companies are reluctant to invest in facilities. Even with stricter tracking, obtaining waste may also be difficult unless the current practice of allowing treated hazardous waste to enter sanitary landfills is changed.

Overall, the most significant barrier to market entry is mindset. A handful of major companies in Taiwan have integrated environmental responsibility into their operations at a high level. However, the vast majority of companies still approach environmental issues in a reactive manner. The out-of-sight, out-of-mind attitude toward hazardous waste and its high cleanup costs make many businesses unwilling to treat their wastes properly. Many business executives in Taiwan developed their skills when economic growth was the highest priority and environmental quality lagged far behind. Addressing expensive remediation and hazardous waste control will require developing a more proactive mindset and an ability to see the future cost of failing to deal with the wastes.

Medical Waste
Taiwan has already developed a basic infrastructure capable of handling medical waste. According to TEPA estimates, Taiwan currently has 87 hospitals and 15,322 clinics with a total capacity of 114,923 beds. On average, Taiwan produces 85,000 tons of medical waste per year (assuming an average 60 percent occupancy rate). TEPA estimates that 15 percent of medical waste, equivalent to 13,000 tons per year, is infectious. There are 32 incinerator facilities licensed to dispose of medical waste (see table 19). TEPA currently has no plans to develop new medical waste disposal facilities. Existing incinerator capacity is enough to handle current volume, so priorities have been shifted to other areas. Plans to build three centralized medical waste incinerators have finally been scrapped after spending several years in limbo.
Table 19 - Ownership of Medical Waste Incinerators
Common Waste Scheme
Source: Interview with TEPA

Soil and Groundwater Remediation
Despite having potentially large problems with soil and groundwater pollution, Taiwan currently lacks soil pollution control legislation. Over four years ago, TEPA submitted the Soil Pollution Control Act to the Legislative Assembly. The act languished in the Assembly for three years before being recalled for revision by TEPA in December 1996.

Groundwater and soil remediation have long been viewed as environmental markets with tremendous potential, but have been slow to develop. Most industry players expect a breakthrough in both markets within the next three to four years, pending the results of regulatory reform.

To preempt future regulations, some companies have begun to quietly remediate contaminated sites. The most prominent project is a remediation effort undertaken by CH2M Hill to remediate soil and groundwater pollution at the old site of an electronics factory in northern Taiwan. However, an additional project funded by the Taoyuan County government to remediate cadmium pollution at the site for a new shopping mall has been stalled for several months.

In addition to the pending legislation, environmental impact assessments (EIAs) as part of land rezoning applications, are likely to drive remediation markets. In the past, EIAs only required testing soil for heavy metal contamination. However, following the discovery of organic contaminants, including polychlorinated biphenyls (PCBs) at a former electronics site, TEPA has become more aggressive in requiring former industrial sites to test soil for chemical (especially organic) contamination. Likewise, EIA review panels are increasingly requesting more comprehensive tests even when TEPA does not.

Remediation Opportunities

As is to be expected, Taiwan has focused on taking care of visible or salient wastes such as air pollution, wastewater, and solid waste. The less obvious immediate consequences of subsurface pollution have allowed authorities to give soil and groundwater cleanup low priority. Yet, this pollution is surfacing in the form of contaminated public water supplies and farmland, leaking underground oil pipelines, and the discovery of buried drums containing unknown materials.

The most public of these cases has involved a multinational electronics company, which apparently contaminated land with organics, including polychlorinated biphenyls (PCBs). The case has broken new ground in Taiwan both legally and environmentally. The current owner of the land -- a private developer with plans to build an apartment complex -- has brought suit against the electronics company for related damages. Although it was a prior owner of the land, the company has taken responsibility for the cleanup. In light of the fact that Taiwan currently has no regulations related to soil and groundwater cleanup, the responsible parties have also agreed with TEPA to follow characterization and cleanup procedures of the U.S. Environmental Protection Agency.

All parties are feeling the effects from this and other recent cases. Pressure has increased on TEPA to promulgate a soil pollution law; land developers are required to execute site assessments prior to building; and industry has increased soil and groundwater monitoring efforts.

For companies interested in operating hazardous waste treatment facilities, the greatest competition will come from the numerous local treatment companies. Rethmann and Cleanaway are the only major foreign players that have seriously entered the hazardous waste treatment market. U.S. firms interested in entering the market will have to compete with the low treatment fees offered by local companies.

For hazardous waste treatment technology providers, the main competition comes from other foreign manufacturers. Most local companies use foreign technologies. As noted, the majority of treatment technologies are intermediate treatments, such as stabilization or distillation.

Best Opportunities for U.S. Firms
Overseas technologies for the treatment and disposal of hazardous wastes are in great demand. For example, only one or two disposal companies are licensed to dispose of solvents. In the long term, the market will hold more assurance for sustained market opportunities as hazardous waste landfills are secured and regulations are established to drive the private sector to build treatment and disposal facilities. When that time comes, the demand for U.S. technologies will be even greater.

In the medical waste arena, niche opportunities may exist for technologies that can significantly reduce costs, but the existing medical waste disposal infrastructure, dominated by local companies, is already capable of meeting basic market needs. Newcomers to the market will have to compete based on cost advantages over existing technologies.

Over the long term, hazardous waste and soil remediation markets represent the best opportunities for U.S. firms. There will be substantial opportunities for U.S. technologies (particularly for companies with Superfund experience) in remediating soil and groundwater for local governments. There is already a niche in the short to medium term in the industrial remediation market, especially for companies with technologies that allow for discreet remediation efforts (i.e., efforts that will not attract much community attention). Eventually, Taiwan will have to implement wide-scale remediation programs on former industrial sites, but it is still difficult to say when the market will truly develop.

The agricultural market may offer the least demand for U.S. technologies. TEPA prefers simple tilling techniques such as are used in Japan to remediate agricultural land because although engineering remediation projects may clean the soil, they often make it impossible to continue farming. According to TEPA studies, farmland in Taiwan is mostly clean of organic chemical pollution. Copper and zinc are the primary contaminants in agricultural land, but only appear in relatively low concentrations. As a result, future remediation projects will most likely center on industrial sites.

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