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China updates 'recycled raw materials' import guidance

ISRI supports the guidance, which reinforces that scrap is not waste.

October 19, 2020

The Institute of Scrap Recycling Industries (ISRI), Washington, has voiced its approval for China’s Ministry of Ecology and Environment updated guidelines for the implementation of brass, copper and aluminum “recycled raw materials” standards, which China previously had planned to introduce in July. The new standards will be implemented Nov. 1 and reinforce ISRI’s long-standing position that scrap is not waste, the association says.

"ISRI has been advocating to the Chinese government for nearly 20 years that scrap should be pulled out of the ‘solid waste’ import regime and recognized as a valuable raw material,” ISRI President Robin Wiener says in a news release about China’s new standards. “China is doing just that with selected grades of nonferrous scrap, and we are expecting China to establish additional standards for ferrous metals and plastic pellets in 2021.”

She adds, “ ISRI applauds the Chinese government for setting an example, and we call on other governments around the world to follow their lead in recognizing scrap is not waste but a necessary ingredient for achieving a green economy."

In addition to the implementation date, ISRI says the updated guidelines published today state:

  • the Harmonized Tariff Codes to identify imported material under these standards are                   7404.00.00.20 for brass, 7404.00.00.30 for copper and 7602.00.00.20 for aluminum;
  • the import quotas already issued in 2020 for material under the existing “solid waste” regime will be honored; and
  • material that does not comply with the standards will not be permitted for import.

The material will enter under harmonized tariff codes for scrap. However, the last two digits of each code are the key identifier between scrap entering under the “recycled raw materials” regime and the outgoing “solid waste” regime,” ISRI says.

“This is an important step taken by the Chinese government, recognizing that recyclable materials used in manufacturing are not waste and need to be allowed to move in the global marketplace,” ISRI notes in the news release.

In an email to ISRI's Trade Committee members that was shared with Recycling Today, Adina Renee Adler, vice president of advocacy at ISRI, writes that as of Oct. 19, the association had not received any guidance on what these new standards mean for General Administration of Quality Supervision, Inspection and Quarantine (AQSIQ) licenses issued under the existing “solid waste” regime.

Additionally, Adler says shipping lines are updating their policies regarding China’s new standards. However, she adds, those policies likely won’t be consistent across all shipping companies.

“We have heard from several members—and Argus has confirmed in this article—that Maersk will issue new guidance shortly that, more than likely, will say that they will ship scrap to China under this new regime,” Adler says. “We expect some of the lines to follow suit, though intel from COSCO (China Ocean Shipping Co. Ltd.) is that they are likely to be more ‘cautious’ towards a determination.”

ISRI also is unclear as to the tariffs that will be assessed on the material, but Adler says the association is working to confirm this. “I do not believe this material will be subject to trade war tariffs, but the Chinese government has removed a number of documents that I previously used to advise members on tariff policy, and obtaining China’s current tariff schedule is not straightforward.”

By the first week of November, with the “resource” definitions for nonferrous scrap finalized and distributed to customs agents and port officials, aluminum producers in China began immediately bringing in compliant loads of scrap, according to Fastmarkets AMM.