On December 18, the General Administration of Quality Supervision, Inspection, and Quarantine of China (AQSIQ) issued new guidelines for exporters and suppliers seeking to apply for export permits to ship scrap to China.
Although not too different from current rules, there are some points you need to know:
- Much of the qualifications remain the same, including ISO 9001 or RIOS, but applicants must also be able to achieve the environmental control standards (i.e., contaminants thresholds) and have radiation detection equipment at your facilities;
- China will maintain the double-inspection system before and after the material is shipped;
- CCIC will no longer be the only approved pre-shipment inspection company. AQISQ lays out a process for third party inspection companies to apply for a license from AQSIQ to conduct pre-shipment inspections but is clear that no processors may conduct inspections. These companies will also share the liability in the event material that was approved before shipment is rejected on arrival at a Chinese port. We anticipate, however, that those applications will take time to process.
Also, there is no specified time that a license will be issued, so we assume that the same guidelines should be adhered to apply not more than 180 days but not less than 90 days before a current license will expire.
These new guidelines will become effective on February 1, 2018. They can be read in English and Chinese.
Finally, just a reminder that only companies "in the business of processing and utilization" in China will be eligible for a scrap import permit, so be sure you know your customer. The Ministry of Environmental Protection (MEP) issued guidelines for domestic companies, which can be read in English and Chinese.
Please let us know if you have any questions, which can be directed to Adina Renee Adler.