A host of questions were answered during session, although more uncertainty still surrounds Chinese policy.
While exporters of various recyclables to China are grappling with the often confusing signals sent out by the Chinese government, as well as through the licensing and permitting agencies, two speakers at the recently concluded ISRI National Convention attempted to explain the purpose behind the policies.
Baolong Qian, with CCIC North America, the inspection agency for all types of recyclables being shipped from North America to China, through an interpreter, provided a general explanation of the relevant requirements for scrap materials being exported to China.
Mr. Qian noted that there are only three aspects of the requirement: Qualification requirement, control standards requirement and procedure requirement.
Under qualification, companies must receive AQSIQ registration. For control standards, the mandatory standards imposed by the Chinese government hope to standardize the standards for suppliers, arrival and pre-shipment inspection, as well as CIQ inspection at the destination port.
Finally, for the procedure requirement, Qian said that all shipments must have a pre-inspection by CCIC, while the Commodity Inspection and Quarantine Bureau will perform a check of the shipment at the destination port.
During his presentation, Qian spent a majority of the time laying out the problems with some poor quality materials that have been shipped to China over the recent past. While spending an ample amount of time attempting to clarify the standards for what is acceptable scrap metal and what isn’t, he also noted that the Chinese agency will be fine tuning some of the standards. Also, as to companies who may not have successfully applied for a permit to ship material to China Qian said that the AQSIQ will be accepting new registration applications in the future, although there is not set date as to when new applicants will be accepted.
The second half of Qian’s presentation touched on a number of the problems to look out for when shipping recyclable material to China. He broke out the problems into two categories: environmentally related issues, and commercial fraud issues.
More typical was the focus on environmental concerns. Often these consist of material that did not meet the standards required by the Chinese buyers. This includes paper, plastics and metal, and run the gamut from greater than acceptable outthrow levels to including impurities with the recyclable material.
As for commercial fraud, Qian noted that “Some people loaded better grade materials near the door of the container to hide the garbage inside the container. This kind of case usually happens during the trade of waste paper.
Other companies may declare a certain material met the conditions required, but after shipment turned out to be of sharply lower quality.
Finally, Qian noted that some people used faulty or suspect documentation to obtain money from letters of credit.
While Mr. Qian’s presentation took up a majority of the session’s time allotment, Scott Horne, general counsel/V.P. of Gov. Relations for the Institute of Scrap Recycling Industries, put together information on historical information on the AQSIQ operation, beginning with late 2003 when the original announcement was made, through the final reviewed deadline for the required license, the beginning of this year.
In his presentation, Horne noted some of the challenges to applying, including translating the AQSIQ notices into English, the amount of information required to complete the license application, translating the application to Chinese, and confusion and uncertainty.
He also noted that of the roughly 4,000 applications received by the AQSIQ, 3,056 licenses were approved, including 686 in the United States and 114 in Canada.
Due to time constraints, Horne was unable to address many of the questions that attendees might have had, although in his prepared presentation he noted the following:
· Companies whose license applications were rejected may reapply for a license six months from the date on the notice of disapproval
· AQSIQ has authorized ISRI and the Bureau of International Recycling to act on behalf of its members as an intermediary
· AQSIQ will no longer communicate through fax. Couriers are the preferred method of communicating
· AQSIQ has agreed to forward relevant announcements directly to ISRI for translation.
Horne also noted that AQSIQ is likely to have a number of random inspections throughout this year. Also, to better explain its operation, AQSIQ will be holding a seminar for licensees and others wishing to become licenses.
The seminary is currently planned to be conducted in Los Angeles, although there has not yet been any definitive information on where or when the program will be.
While both speakers attempted to address many of the questions attendees had, due to the newness of the policy and procedures, there have been a continual adjustments in the policy.
In his closing remarks, Horne said that ISRI would continue to monitor the situation and work with AQSIQ to make the program as clear as possible.