Webinar – The Value and Role of Product Stewardship in Australia
Questions
- Product Stewardship should be broader than a waste strategy and environmental outcomes, but also safety along the supply chain.
Dominique Doyle, dominique.doyle@agsafe.org.au
Answer: Agreed, essential
- What role do you see reuse having within product stewardship schemes, and the role of charities as major reuse enterprises extending the life of (household) products?
Omer Soker, omer@charitablerecycling.org.au
Answer: Charities have an important role to play and should be involved in the design of schemes and programs from the outset.
- What is the difference between Product Stewardship Act 2011 and RAWR Act 2020?
Paula, paula@atigroup.biz
Answered live
- Charities have in-house knowledge around what does and doesn’t resell, and what can and cannot be refurbished for resale – important information to identify and redesign products.
Guy Keulemans, g.keulemans@unsw.edu.au
Answer: Hi Guy – agree, collecting all of this information from various stakeholders is very important to getting things right.
- Rose, the Vinyl Council’s Stewardship Program started with CSIRO report in 2001 on wholistic approach in design, safety in supply chain, composition of product, recyclability, GHG emissions.
Helen Millicer, hmillicer@apco.org.au
Answer: Thanks Helen
- Collecting waste streams is all well and good, however if the collected material is not then reused then ‘recycling’ is not occurring, resources are just being stored. Case in point crushed glass being horded in warehouses. We need to measure how much of the collected ‘recycleable’ material is being reused!
Phil Walls, Philip.walls@hitechmaterials.com.au
Answered Live:
Any quality Product Stewardship a scheme should be reporting on both how much is collected and how much is recovered.
A classic example is in the (NTCRS) National Television and Computer recycling scheme. One of their regulated targets is to achieve a greater than 90% recovery of materials and Phil you are spot on, it is not just about how much you collect, it is about recovering and reusing and this is a key – a decent Product Stewardship program will be able to know exactly how much is recovered and it will also know where that material is recovered and how it is used and ensure it is being done in an environmentally and socially responsible manner.
- Do you think government policy and economic paradigm shift is necessary to really accelerate product stewardship? If so, does the CoE have a mandate / ability to support efforts to redesign government policy and economic models?
Jonathan Oon, RMIT, Jonathan.Oon@rmit.edu.au
Answered Live:
A great question. It really, it is part of the Centre’s mandate is to provide advice and input to Government and to policy makers so certainly our work as a result of our various research projects, the insights we are gathering from our work with stakeholders and schemes will be fed into the department and to Government as part of their ongoing work to adjust and reform policy so that we get better product stewardship outcomes – so I think it is a really important area of work for the Centre on an ongoing basis and it is part of our partnership with the Department in many respects as to how the Centre will operate is to provide that advice and input.
- Will the Centre be supporting community repair initiatives that are volunteer-led?
Mend it Australia, de55@bigpond.net.au
Answer: Repair is an important type of Product Stewardship to keep products in the economy
- From the Centre of Excellence viewpoint are regulated Product Stewardship schemes preferred to voluntary schemes or vice versa?
Graeme Stewart, Graemestewart4@bigpond.com
Answered Live:
I think what is really important as outlined in my presentation earlier I highlighted that there is a whole list of schemes out there. Regulation vs voluntary – there is no preferred option is the answer really.
In some instances you need regulation because of the vast number of players involved and that sets a very clear and level playing field. In other situations you do not. So it really.. there is no one hard and fast rule for Product Stewardship you really have to shape it in regards of the issues you are trying to resolve and who the players are and what is the best way to work together.
In the case of Mobile Muster, all of the companies have quiet happily in a collective sense have quiet happily worked on a voluntary basis and then they have sought accreditation to reinforce that. In the case of the National Television and Computer Recycling Scheme you have over 140 companies that are importing and are putting products into the market so to try to get those organisations to come together voluntarily is quite difficult so therefore regulation is required to set the basic rules but then those companies then implement that and achieve those results themselves – so there is horses for courses.
- Comment: Consumers are also actors in the product lifecycle so too have stewardship responsibility. Dont think it should just be the producer’s responsibility. Schemes should reach this important group to influence positive behaviours (not just to educate where they can drop off their end of life products)?
Alvin Piadasa, alvin.piadasa@tes-amm.com
Answered Live:
Yes, consumers have a responsibility but consumers do not have the ability to redesign a product, they do not have the ability to set up a collection system, they do not have an ability to design and provide repair services so that is why we say we say that the focus needs to be on producer responsibility. Consumers will participate and as long as they educated, informed and incentivized to do that they will participate and that is their role but in terms of the actual responsibility and to fund and to establish those solutions and to enable their involvement that is the producer’s responsibility.
I think that Alvin’s point is a really important one and it underscores why those running schemes really need to ramp up their consumer and community education programs – so Alvin’s point is a good one. Rose’s is absolutely around where the focus should be but the need for schemes, arrangements and programs to really get that message out nationwide to the community is really important and that way you get the balance in terms of the different roles that everyone has to play across the product lifecycle, but it is about doing much more in certain product categories to let consumers know that Product Stewardship programs exist or solutions exist at an individual company level.
- Do you think Product Stewardship is a more strategic policy response/intervention than EPR or take back?
Alec McNeil Marlborough DC, alec.mcneil@marlborough.govt.nz
Answered Live:
Look I think it is a matter of what is fit for purpose. It is matter of looking at the particular problem that is being addressed through Product Stewardship or Extended Producer Responsibility. I think getting overly focused on the definitions in lieu of trying to solve the problem is probably energy misspent. I think really it is about what is the problem we are trying to address or the opportunity that we are trying to create – whether it is a particular product category or a material stream and then really designing the solutions collectively whether it is a collective scheme, whether it is at an individual company level or whether it is dealing with environmental performance issues or health issues hazards / occupational health and safety as it relates to stewardship. I think it needs to be comprehensive no matter what the terminology.
- Resilient end market development to ensure healthy circular supply chains is critical to the success of PS schemes. Does the Centre have a focus on end market development and in particular government support of those markets through appropriate e – procurement models? Peter Tamblyn, peter@closetheloop.com.au
Answered Live:
Market development is a really important part of a successful recycling program and this is where we should see producers and manufacturers really need to have a big role to play in terms of looking at how they can use more recycled content in their products and create markets for the materials they are using in their products and obviously closing the loop and reusing those materials back in their own products is the ideal in some instances there are alternatives.
Government can also can play a significant role in driving procurement and we are starting to see a shift especially actually at local council levels where councils are now specifying and looking for recycled materials in their procurement of services and products so I think Government does have an important role to play and but also producers and manufacturers. Look at the Tyre Stewardship Australia, one of the key underpinning elements of that program was to set up funds to develop new products and new products for recycled tires so it is definitely an important part of the Product Stewardship lifecycle.
- What is your advice/thinking on existing schemes being updated to be more comprehensive and inclusive, for example moving beyond recovery only to address recyclability and reprocessing. Currently there is no requirement for such changes to existing schemes or for new schemes. How can these improvements be achieved going forward?
Helen Millicer, hmillicer@apco.org.au
Answered Live:
I think it is a really important question. It is something where we do need to look at what are the right actions and interventions in order to address the problem or to create new opportunities and the accreditation for Product Stewardship schemes that has been introduced by recent legislation is an opportunity to look at how certain programs and arrangement can be more comprehensive, can look beyond the end of life, processing materials, can look at design etc. So I think we will see shifts and changes there in terms of the types of programs and arrangements that do get accredited and the extent to which they go back up the supply chain to address these issues.
The Product Stewardship index as well will be an opportunity to identify where some of the gaps are again back up the supply chain and whether there are opportunities there to look at other ways of addressing the issues – whether it is about the materials that are specified from the outside, whether it is about the production methods or whether it is about a smarter approach to reverse logistics in this big wide land and servicing rural, remote, regional areas so I think it is essential that we look at what Product Stewardship can be – we have talked about it before, we will need to look at Product Stewardship 2.0, we need to keep recycling and we need to be better and smarter at it with cleaner streams coming out of the collected material but we need – as Peter Tamblyn has noted here in one of the questions, we need resilient markets for these collected materials and that is part of this comprehensive approach. But that is something that cannot be done in isolation at the Centre, this is the collective impact of all of the organisations – group associations, brands, manufacturers working on these issues together to deliver these sorts of outcomes and meet the very stiff targets of the National Waste Policy action plan.
Just one more point on that there is one formal process to look at expanding the National Television and Computer Recycling Scheme and to look at reuse. It was one of the outcomes from the Product Stewardship review so to Helen’s question, Government has identified the need to recognise reuse within the National Television and Computer Recycling Scheme and how that is going to position itself so it will be interesting to see how that one is progressed by the Government.
- Product Design Guidelines – with over 80% of waste created at design stage will there be a discussion around this or interconnected conversations with other bodies/research orgs. Also consumer behaviour working in cooperation with the Stewardship System is this a factor or we leave to market forces in New Product Development. Back cast or forecast and also local community infrastructures – Does CE need local traction?
Sasha Alexander, s.alexander@westernsydney.edu.au
Answered Live:
There will be and Sasha has raised a really important point and it is a point that really highlights the different points of intervention that Product Stewardship can play a role but it also highlights how in a practical way, the principles of circularity can start to be embedded in Product Stewardship. You know, really in some respects you can state that Product Stewardship begins with design – how do we design out waste from the outset, how do we design products to be more easily repaired, reused, modular, upgraded etc and these are really important aspects that we need to elevate and provide guidance around the role of design in better Product Stewardship outcomes and in particular looking at how we can avoid waste from the outset so Sasha to your point around Circular Economy very much a matter of embedding it in our work but doing it in a practical way we really need to look at the specific principles of circularity and what does that mean along the supply chain or along the product lifecycle so I am glad that you raised the importance of design.
It is also reflected with some of our Specialist Advisers: Good Design Australia, Monash Uni design, the Design institute of Australia exposing Product Developers, engineers, designers, the need to look at how materials are selected, used and products are designed to prolong the life of those products and keep them circulated in the economy – very important.
- if >100 new PS schemes are in prospect, is the concept that every new scheme should establish it own recovery systems and logistics, or will reality and common sense focus on shared or common receival, pre-treatment and aggregation pathways to minimize costs and optimize performance.
Mark Glover, mark@ecowaste.com.au
Answered Live:
I will jump in on that one – it is a good question, and I will let Mark know already a number of the schemes that have been funded via the grant program the proposed schemes around agricultural plastics for instances are keeping in touch and this is where the Product Stewardship network will also play an important role in making sure that the schemes are aware of each other and trying to identify synergies where they can collaborate and look at managing the logistics effectively because it is a major cost if the Product Stewardship program is focused on the take back recycling program, collecting those materials and aggregating them and getting them to the recycler in the appropriate form is a large percentage of costs for these sorts of programs so I know that Agricultural plastics projects – some looking at film plastics and single use plastics are already in touch with each other likewise the soft plastics group but also you will even see for instance you will also see Woolworths, Mobile Muster and the Batteries Stewardship council are great examples where we also see batteries and mobile phones being collected through supermarkets so – and I know that Mark has a very close to his heart proposal about setting up Product Stewardship stations – sort of an expanded Container Deposit scheme where there are collection points – whether they are shared – you have a site that multiple schemes share – you have a site with multiple drop offs as a drive through drop for instance off so I think that is a starting point which will evolve with the schemes and hopefully come up with some innovative to address a big challenge with logistics.
- Are you aware of any studies that evaluate the impact of increased warranty periods for products to the equation?
Andre Lopez, andrew.lopes@worley.com
- what deemed success criteria for a scheme be to publish the amount of product or materials reclaimed as a proportion on the volumes of materials deem to have reached their end of first life each year?
Mark Glover, mark@ecowaste.com.au
- Will research be done around consumer preferences between EOL take-back vs leasing schemes, etc to help ensure that circularity is promoted as quickly as possible? (eg constraints of leasing phones and them being kept in good condition and good working order vs the ease of owning and having no responsibility to another party),
Tiana Nairn, LMS Energy tiana.nairn@lms.com.au
- As a plastic processing and recycling company, Product Stewardship schemes should be talking to the industries to make sure product is design in a clever way so that it can be easily reuse in Australia or keeping single polymer so that it will match up with the plastic export ban or process locally for re manufacturing.
Kai Hau, kai.hau@ycarecycling.com
Answered Live:
Yes definitely, Design is so critical in all of this. One of the things – just to reiterate the role of the Centre is really about working with businesses and helping them learn and understand about product stewardship and getting them to stop and think about their products and how they can come up with preventing a lot of these issues making if they are using a plastic that is recyclable making sure it is easily can be collected and separated easily so that it can be reused but also looking at how they can reuse that plastic in their own products is one example so our role really is about sitting down with those companies or with those schemes and going through and asking them those questions, have they thought about this and also being able to link them to other schemes or other service providers that we are aware of – and that why I really encourage everyone to join the Product Stewardship network.
- I note many companies with product stewardship approaches are international were their products are imported, but have recycling and re-use built into their design, will those products be sent back offshore for reprocessing? I’m concerned about the logistics/carbon impacts of this aspect of life cycle.
Danielle, daniellejoyner33@gmail.com
Answered Live:
It is a really interesting question and it is a valid question but also I think it needs to be put into context of the carbon savings in recovering and reusing those materials versus mining up raw materials. So yes, there will be a carbon footprint but it is very small in comparison and Mobile Muster did look at the whole impact of the carbon footprint of the collection and recycling and reuse and recovering of materials and compared that to using virgin materials and you ended up getting a 10 times benefit of reusing materials so while there was a small carbon footprint to collect and get that material back, and a carbon footprint with reprocessing that material, it was significantly less than using virgin materials – so there was a positive net positive benefit.
And I will bring in the embodied energy point here – this is about thinking about the embodied energy and so keeping those materials in the economy and the amount of embodied energy in material is significant in comparison to just moving it about.
- As there are 20+ groups currently developing new schemes when do you expect the guidance material will be available?
Barry Cosier, barry.cosier@afgc.org.au
Answered Live:
Well Barry, there are lots of and it is great to see the Government putting so much funding out there to help companies establish schemes Product Stewardship– it has never been this good. We are looking to get guidance and practice notes together as quickly as possible but it is going to take a few months, but we are also working very closely as closely with we can with those grant recipients to help guide them through that so keep a look out for them – so hopefully we will start seeing things rollout in the next month or so.
- we have >50 motor vehicle brands in Australia…but they all use the same national road network…is there model here to facilitate the most efficient outcomes
Mark Glover, mark@ecowaste.com.au
- “Is the level of recycling in less developed countries higher than developed countries? Could that be due to poverty driving ingenuity in creating markets as individuals have to feed their families or starve?
In developed countries those issues are non-existent.”
M C 07mchhabhadia@gmail.com
- Have you seen any opportunities to lift the capacity of our systems to extend the life of products through increasing supply / reducing cost of repair in your work? I’ve always found the cost of repair of so many items so insanely expensive relative to the cost of buying new!
Jonathan Oon, RMIT, Jonathan.Oon@rmit.edu.au
- Is resource recovery part of the product stewardship focus? And does it focus on reduction of carbon footprint?
Mandy Bliss, info@repodder.com
- What’s the Centre’s involvement in Right To Repair?
Mend it Australia, de55@bigpond.net.au
Answered Live:
I think it is an area where again where it relates to producers, to manufacturers to retailers doing activity in this area and where that can be collaborative with the great number of repair cafes around the country and tool libraries etc where that can be done in a constructive and collaborative way – repair is part of the agenda. We cannot look at the issue of waste avoidance and waste reduction without looking at the sensible solutions that involve reuse and repair. Reuse and repair in some respects in certain products are the ‘first responders’ to quote Guy Guleman’s language here in dealing with the issue. So I think it will be very interesting to see what comes out of the Productivity Commission’s enquiry as I said earlier, 140 plus submissions from various stakeholders – many of them supportive and some quite concerned about what it all means, but we cannot overlook what has come out of the review of the Product Stewardship Act and its attention to looking more closely at durability, repairability, recyclability and the role of design in achieving that. So, I think it is quite a great time and I am quite optimistic about how various other strategies can be used in terms of the waste hierarchy – further up the top of the waste hierarchy to deliver better product stewardship outcomes.
- Is the conservation of embedded energy being considered as a concept for the design and assessment of product stewardship systems? I’m thinking of how some ‘recycling’ schemes are burning tyres for energy or using crushing bottles for use in road building… inappropriate uses for their types
Guy Keulemans, g.keulemans@unsw.edu.au
- Does the ability to return products at end of useful life to manufacturer makes more sense and what incentives can be set up?
M C 07mchhabhadia@gmail.com
- Is there any move by governments to outlaw or at least address the subject of “planned obsolescence” that some manufacturers are rumoured to have in place in their business models?
Leanne Buchan, rad@myesolution.com.au
- Could product embedded IoT and big data, RFID, play a role. Sorry if responded to already. ie: IoTs in plastica at granular level possibly
Sasha Alexander, s.alexander@westernsydney.edu.au
- How do you see imports not resulting in free-riders, with local producers carrying all the costs? Fiona Baxer, Fiona.baxter@asaleocare.com
Answered Live:
That is a really good question and it is becoming / there are a number of ways to manage that. The biggest issue – there is a number of ways to manage it.
The NTCRS has a regulation in place that requires that. The other option is to seek accreditation of your voluntary scheme – is another way where / that can help manage free riders in that those companies that do not join the voluntary product stewardship scheme are companies that the minister can choose to call out in Parliament and question what their activities are in terms of Product Stewardship
But one of the other big challenges and it is not just Australia that has this problem is online purchases and having those companies contributing to Product Stewardship schemes and this will be a focus of one of our white papers and to try and look at how we can find some innovative solutions to that challenge.
- With the exciting potential for consolidation of collection streams at suitable new (or existing) shared locations in communities, has anyone looked at trigger points with relevant EPA legislation for waste facilties etc that might create a barrier to this great idea?
Kirsten Coote, KCoote@bunnings.com
Answered Live:
So just to clarify, I suppose working with state EPA’s and local governments is really key part of the role and I know that many of the Product Stewardship organisations such as PaintBack in particular and Tyre Stewardship work quite closely with state governments to see regulations changed to enable their schemes to collect and aggregate materials.
Likewise, Drum Muster and the National Television & Computer recycling service and a number of schemes do work collaboratively with local councils in setting up their collection points at transfer stations and so on. I am not so sure I have quite answered the question but local government / Product Stewardship working with local and state government is really important to establish collection networks and there has been experience in the past where regulations have had to be changed in the past to enable schemes to work and state governments are generally very proactive and helpful in that regard.
Answered Live:
I just wanted to add briefly to that. From the Centre’s perspective it is our intent to reach out to be proactive and to reach out to state’s and territories around our work, our program but also to solicit their input and feedback on these sorts of issues and that may include your point around trigger points for things that we should be aware of in particular product categories or material classes.
As a starting point for us, we want to reach out to a range of stakeholders of course our producers, manufacturers, retailers, brands are the focus but ultimate success requires states, territories, local government, charities, social businesses and community organisations to be involved, we just need to be very realistic about where the energy needs to be invested over time mindful that there is a lot of other activity out there – you’ve got Planet Ark, Circular Economy Hub, Circular NSW – you have got various other organisations doing great work in this space and co – operation between these organisations to make the best use of the resources is going to be important but reaching out to other stakeholders is certainly part of our strategy.
- Great session thanks! If there is an informal stewardship scheme that exists within an industry, how important do you see it is to formalise this scheme, whether that be through a voluntary, or regulated program? Also, are there specific considerations, or a ‘check-list’ for ideal participants for a scheme, including reps from consumer groups and impacted industries, or would it be product/stream specific?
Shannon Mead, shannon@nomorebutts.org.au
- Wouldn’t it nice to have national schemes rather than state based. Is product stewardship being promoted as a national approach so the various states don’t just do their own thing? Are you guys actively talking to state governments to get them on board at the start?
Phil Walls, Philip.walls@hitechmaterials.com.au
- Are wages too high in developed countries which makes it uneconomical to do the right thing? M C 07mchhabhadia@gmail.com
- Does the product stewardship recognise the APCO 2025 target for all packaging to be either recyclable, compostable or reusable?
Mandy Bliss, info@repodder.com
- Product Stewardship schemes on a national basis seem, in my view, to have been most successful. Is national the best approach for the future or is there a place for State schemes? Graeme Stewart, graemestewart4@bigpond.com
Answered Live:
That is a really good question and national is preferable for a number of reasons so you have consistency in collection point and what the Collection point looks like, education to the community, what is the reporting requirements and so on.
A good example is the Container Deposit Schemes which have been established on a state basis and there are differences between them and that does cause unnecessary administration issues and costs but there is a commitment – the environment ministers met recently and made a commitment to ensure consistency in some of the core elements of some of these schemes but the preference would be for national.
- Is carbon costed appropriately in various processes? Does this mean that we are not measuring correctly and hence losing many opportunities?
M C 07mchhabhadia@gmail.com
- Where might a designer of plastic products find resources on how to design/source materials that are recyclable? We have a few industrial designers in-house
Anonymous attendee
- Contestable deadlines are a good point of discussion as without stretch targets, nothing much gets actioned.
M C 07mchhabhadia@gmail.com
- Do you believe that increasing the minimum warranty period of products (say, to 3-5 years) would have a positive impact to the issue?
Andre Lopes, andre.lopes@worley.com
- I believe there are a lot of application to PS scheme, what is the most important thing that the scheme is looking for to approve the submission? saving landfill? volume? micro plastic?
Kai Hau, kai.hau@ycarecycling.com
- Guidance material for the Right To Repair in Australia would be helpful.
Mend it Australia, de55@bigpond.net.au
- Do Intellectual Property sharing challenges impact value creation and possible re-use solutions – and are there useful ways of managing this?
Jennifer Conley, Jennifer.conley@advancedfibrecluster.org.au
Answered Live:
That is a really good question and sharing of Intellectual Property and working collaboratively is challenging so this is where being very clear about what the issues are that you are trying to address and to stay focused on those – you can overcome those barriers of sharing Intellectual Barriers.
Sharing of Intellectual Property and working collaboratively is challenging so this is where being very clear about what the issues are that you are trying to address and to stay focused on those you can overcome those barriers of sharing Intellectual Property and not sort of cut across commercial boundaries or ACC rulings and so on.
A good example of this would be Nestle’s work in producing a prototype for their Kit Kat wrapper.
What was great and this would not have been able to happen if Nestle had not have stepped up to do is that they actually got people together right across the supply chain and they were all focused on the single focus of being able to recycle soft plastics back into food-based packaging and so in terms of dealing with a lot of those issues if you stay focused on that issue, you can manage some of those other areas.
- you could manage free riders by making PS as universal as industrial trade waste, and or emissions to atmosphere etc
Mark Glover, mark@ecowaste.com.
- We’re often dealing with multinational companies, generally the Australian market represents around 2% of their global revenues, influencing design initiatives from such a small market may not resonate with these organisations. Any thoughts on this?
Peter Tamblyn, peter@closetheloop.com.au
Answered Live:
I have an opinion on this and I will share it with you. I think where it is designed and made has relevance, but it has become a bit of a mythology if you look at energy star ratings and the water efficiency labelling schemes, these are Australian programs that help consumers choose products in relation to energy and water appliances for tapware etc. Many of these products in the energy space the majority if not all of them are designed and made overseas.
So, I don’t think it is the size of our market always, I think it is the nature of the program – the policy, the labeling scheme that drives design changes and therefore better environmental outcomes. So I think again, without fear of generalizing too much we need to look at what is the problem being addressed, how can we address it, how can we influence design more effectively.
If we look at the European Union response on electrical equipment waste and how it touches on end of life electronics or the restrictions of hazardous substances in electronics, many of the products that enter the European Market are designed and made elsewhere in the world so it is about the response to addressing the problem in the jurisdiction that is trying to deal with it. So I think that Peter, your point is a really good one and I think it stills holds in product categories, but I don’t always think it is the size of the market in Australia, it is about the response to dealing with that problem either from a policy perspective, a labeling perspective that can drive good design, better design, circular design in fact.
- Given that State’s have a leading role in regulations/oversight through their respective EPA’s etc should these organisations play a greater role in overseeing national stewardship schemes?
Jan van de Graaff, jan.vandergraaff@vinyl.org.au
- Consumers are stakeholders. Consider representation from consumer groups/associations. Mend it Australia, de55@bigpond.net.au
Answer: Thanks – we will circulate our needs analysis and hope to hear more from you and other stakeholders.
- For many of us getting data is very difficult, especially for imports where import codes are broad and include both inputs to a product and finished product. Can the CoE help us lobby government to get more granular detail (acknowledging some codes are globally used)?
Janelle Wallace, jwallace@beddingstewardship.org.au
- Is there any product priority/focus to kick off e.g. top 5 targets that are not schemed?
Daryl, daryl.moyle@ecocycle.com.au
- Do we have too many types, shapes and sizes of containers which is more expensive and not conducive to shared reuse by manufacturers?
M C 07mchhabhadia@gmail.com