As we have previously reported, as a result of the Chinese government’s restructuring, AQSIQ’s oversight of scrap import/export activities were taken over by China’s General Administration of Customs, and AQSIQ was dissolved.
In order to align China’s regulations with this new structure, Customs has been reissuing regulations under its own banner. The regulation governing scrap import and export licenses is the latest to be changed, and the translation of that regulation is now available. Of particular note, and as confirmed by my meeting with CCICNA, RIOSTM continues to be an eligible requirement, and there does not appear to be any changes to application requirements or procedures.
Furthermore, ISRI confirmed that current export licenses issued by AQSIQ will still be valid past this regulation’s August 1 start date. According to our contacts, Customs has not issued any guidance regarding existing licenses, and the regulation says nothing about abolishing existing licenses. Furthermore, the separate Administrative Licensing Law of the People’s Republic of China states “the licenses granted under the then-effective administrative regulations shall be protected by law, and the government agency shall not change the effectiveness of the licenses, unless revoked/abolished by the law AND the holders of such licenses are duly compensated.”
Should anything change with this situation, ISRI will let you know. But if you have any questions, please contact Adina Renee Adler.
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