Chinese companies need to reapply for waste import licenses

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China recycling inspections ports that solid waste
Chinese customs officials inspect waste materials

China’s General Administration of Customs (GAC) has announced that companies that import waste materials into the country must reapply for their licenses and revealed new rules on imports.

Coming into force from 1 August 2018, Chinese importers including paper mills and metals recycling facilities, will need to have been approved for new licenses by GAC.

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Importers, called consignees in the new regulations, must prove that:

  • They are a processing and utilisation company with the legal import business qualifications
  • Have a fixed office space and corresponding infrastructure, plus radioactive detection equipment and testing capabilities
  • Be familiar with and comply with the laws, regulations and relevant standards of China’s entry-exit inspection and quarantine, environmental protection and solid waste management
  • It has measures and capabilities for environmental quality control and processing of waste raw materials, and establishes a corresponding management system to ensure that waste raw materials comply with the mandatory requirements of national technical specifications for China’s entry-exit inspection and quarantine, environmental protection¬† and solid waste management.

The new regulations also stipulate that the waste raw materials imported by the consignee “can only be used for self-processing and utilisation, and must not be delivered to other units, organisations or individuals in any way”.

Additionally, the consignee and its affiliates cannot engage in pre-shipment inspections of waste raw materials. There isn’t any further detail on what this means, although the most likely explanation is that self-certification is confirmed as ended. It would seem unlikely that the Chinese authorities would ban exporter companies from carrying out their own inspections to ensure the material meets Chinese standards, but this self inspection will no longer be considered sufficient prior to export.

Once companies have applied for their licenses, GAC will set up a review team within ten days to go and inspect the company. This on-site inspection will include verifying the authenticity, validity and consistency of the application materials; verify the effectiveness of the consignee’s internal management and quality control measures and assess the compliance of the imported waste material.

Once these inspections procedures have been undertaken, there will be a 10-day period under which the customs direct office will assess whether to grant the license or not.

If granted, the import license will last for five years, unless ongoing on-site inspections of the company find violations of the import regulations.

These regulations also define what constitutes full inspections of material. This is: “Full inspection means that every box, car, and wagon of waste materials that are shipped in containers, cars, or trains are tested in a box or on the ground, and the bulk of the waste materials that are shipped in bulk are tested.”

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