Indonesian Embassy sets out new application process for export of recyclate from UK and Ireland

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The Indonesian Embassy in London has set out the measures that exporters of recycled materials must undertake to send it from the UK and Ireland to Indonesia.

In order to register to send material to Indonesia exporters must fill out an application form that is available to download on the Indonesian Embassy website.

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They must also complete and sign a Letter of Declaration (downloadable from the same website) from the company that is legalised by a notary as well as apostilled by the Foreign, Commonwealth and Development Office of the United Kingdom for UK companies or the Department of Foreign Affairs and Trade of Ireland for Irish businesses.

This means that the documents need to be signed by a notary as well as receiving a seal of verification from the Foreign Office in the UK or its equivalent in Ireland.

Exporters will also need to provide an original and a copy of their Certificate of Incorporation plus their most recent company profile.

Paul’s view

Paul Sanderson, REB Market Intelligence

This seems like an overly convoluted process to register to export to Indonesia, and when combined with the additional inspection processes required to ship there, may lead to some exporters querying whether they should bother.

They will also question why it only appears to be the UK and Ireland subject to this registration process.

There are also a number of questions to be answered, for example is this an annual registration process or just one-time? Is the implementation period immediate or at a time in the future?

In my view, this seems designed to make it as hard to export to Indonesia as possible. Perhaps the authorities in Indonesia have been studying the Chinese play book and have learned a lesson or two along the way.

They will also need to provide the original and a copy of the contract between the exporter and the Indonesian company, that is also legalised by a notary and apostilled either by the UK Foreign Office or Department of Foreign Affairs and Trade of Ireland depending on location.

Additionally, they will need to send the original and one copy of their Certification of Registration as a carrier, broker and dealer in waste from the relevant environment agencies in England, Scotland, Wales, Northern Ireland and Ireland and again legalised by notary and apostilled by the relevant Foreign Office.

The original and a copy of the Grant of Accreditation as an exporter of packaging waste from the UK environment agencies must also be provided.

A copy of a valid passport or ID of the person representing the exporter is also required.

All of these will also need to be legalised by the Indonesian Embassy in London.

Finally, a fee of £105 must be paid by postal order or bank draft.

The Letter of Declaration notes that “the matter of waste trading or waste export from abroad to Indonesia has drawn global attention due to non-compliance of global, and Indonesian laws and regulations”.

Companies will be required to declare that they will “comply with international norms and regulations”, meaning the Basel Convention and Indonesian laws and regulations.

They will also need to declare that the material:

  1. Does not originate from landfill activities
  2. Is not trash and is not mixed with trash at all
  3. Is not contaminated with hazardous and toxic materials and waste at all, and
  4. Is homogenous.

The waste to be shipped must originate from a registered United Kingdom waste and recycling management facility.

Exporters must also declare that it will be shipped from a UK port of departure to designated port of arrival in Indonesia.

They must also declare that they accept full legal responsibility for any and all rejected waste that is not in compliance with the list of declarations above. They will also accept responsibility for repatriating and or all of the rejected material and shall not contest any decision by the Indonesian Government and its Customs department.

The application forms, Letter of Declaration and further information are available at https://indonesianembassy.org.uk/en/legalization-procedures-for-the-transboundary-shipment-of-nonhazardous-and-non-toxic-waste-from-united-kingdom-and-ireland-to-indonesia/

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