中国- 固形廃棄物の輸入 全面禁止についてのアップデート

回覧 10/20 でお伝えした通り、中国政府は、固形廃棄物環境汚染防止法が改正されたため、2021年1月1日より固形廃棄物の輸入を全面的に禁止しています。しかし2020年12月に鉄鋼材料等のリサイクル可能な特定の材料は輸入禁止項目から除外されております。現地コレスポンデンスHuataiは、これらリサイクル鉄鋼材料の輸入管理について最新情報を提供しましたので、お届けいたします。

Members are referred to the UK Club’s Circular 10/20 and the Oasis’ Circular No.2014 published earlier this year. In order to implement the amendment to The Prevention and Control of Solid Waste Law, the Chinese government announced the complete ban of imports of solid waste from January 1, 2021.

On December 14, 2020, with the approval of the recommended national standard of recycling iron-steel materials (GB/T39733 2020), certain recyclable materials such as recycling iron-steel materials are allowed to be imported as exemptions to the prohibition. As such, any scrap metals that meet the requirements of GB/T39733 2020 are re-classified as recyclable materials and are therefore free from importing restrictions into China. 

The Club’s correspondents, Huatai Insurance Agency and Consultant Service Ltd, have provided the following update on the management of the importation of the recycling iron-steel material into China. For detailed descriptions of the classification, processing methods, technical requirements, inspection methods, and acceptance rules of recycled iron and steel raw materials, please refer to Oasis’ Circular PNI[2021]07.

Background

On April 29, 2020, Law of the People’s Republic of China on Prevention and Control of Environmental Pollution by Solid Waste (hereinafter referred to as “the Law”) was revised by the Standing Committee of the National People’s Congress for the second time, which took into effect on September 1, 2020. The new amendment raises the penalties for imported solid waste and transboundary movements of hazardous waste, and also raises the penalty for smuggling of waste by five times, setting a new ceiling of $700,000.00, and specifies that the Carriers are jointly and severally liable for the return and disposal of solid waste.

On November 25, 2020, in accordance with the Law, the Ministry of Ecology and Environment issued the Announcement on Matters Relating to the Total Ban on Imported Solid Waste, prohibiting the import of solid waste by any means. Once the announcement was released, it caused heated discussion in related industries. We have also received several inquiries from the Club and Members regarding the disposal of solid waste.

The Standard of Recycling Iron-Steel Materials (GB/T39733-2020）

On December 14, 2020, the recommended national standard of recycling Iron-steel materials (GB/T39733-2020) was approved to release by the State Administration for Market Regulation (China National Standardization Management Committee), which was formally implemented on January 1, 2021. According to the new standards, “steel scrap” that meets the criteria can be identified as “Recycling Iron-Steel Materials”.

To improve the import management of Recycling Iron-Steel Materials, the Ministry of Ecology and Environment and other relative departments jointly issued the Announcement on Matters Related to the Standardization of the Import Management of Recycling Iron-steel Materials(Announcement 2020 No. 78) on December 30, 2020. It is stipulated that from January 1, 2021, recycled steel raw materials that meet the national standard (GB/T39733-2020) are not solid waste and can be imported freely.

In accordance with the provisions of the Notice on Matters Relating to the Regulation of the Import of Recycled Iron and Steel Raw Materials, recycled iron and steel raw materials, including scrap, that meet the national standards for recycled iron and steel (GB/T39733-2020) are free for import. 

In accordance with the relevant standard, which is called “Recycling Iron-steel Materials Standard” (GB/T39733-2020), the “recycling Iron-steel materials” are divided into 7 Items and 18 Codes according to their physical and chemical properties. Each Code corresponds to its physical specifications, sources, and processing methods. Detailed descriptions of the classification, processing methods, technical requirements, inspection methods, and acceptance rules of recycled iron and steel raw materials can be found on the National Standard Information Public Service Platform (website: http://std.samr.gov.cn/). The following are the Items, Marks, and Codes of recycling Iron-steel materials. 

The Code does not directly correspond to the commodity code classified by component content. Therefore, the importer is required to fully understand the physical and chemical properties of the goods before import, and fill in the corresponding information truthfully. Many references are provided in the typical examples of raw material sources, where the corresponding Codes can be found directly.

Suggestions

In accordance with the provisions of the Notice on Matters Relating to the Regulation of the Import of Recycled Iron and Steel Raw Materials, recycled iron and steel raw materials, including scrap, that meet the national standards for recycled iron and steel (GB/T39733-2020) are free for import. 

If Members are in doubt about the description of the cargo to be shipped, we recommend asking the shipper to submit a certificate of cargo quality or other similar documents issued by a professional body. In addition, Members can consult the local agent for the classification standard of the relevant cargo and the official name of the cargo to determine in advance whether the cargo is solid waste or recycled steel materials. Likewise, Members are suggested to contact us in advance if there are any questions about the classification standard of steel scrap or recycling Iron-steel materials so as to properly dispose of the goods in a timely manner.