Update on Notice to Members No.11 2020 2021 - PRC Law
Further to the Notice to Members No. 11 2020/2021, a number of amendments to what was previously understood to be a complete prohibition on the importation of solid waste into China have been passed. Certain recyclable materials as set out below can be imported as exemptions to the prohibition since they will not be classified as solid waste for the purposes of that prohibition.
On the 31 December 2020 a Notice of Regulatory Management in the Import of Recycling Iron-steel Materials was issued stating:
Any recycling iron-steel materials that are in accordance with the standard of the National Standard of Recycling Iron-steel Materials (GB/T 39733-2020) shall not be construed as solid waste and are therefore free from importing restrictions into China.
The HS Code of the recycling iron-steel materials are: 7204100010, 7204210010, 7204290010, 7204410010 and 7204490030.
Any Recycling iron-steel materials that do not meet the requirements of the National Standard of Recycling Iron-steel Materials (GB/T 39733-2020) shall not be imported.
This Notice came into effect on 1 January 2021.
Prior to this in October 2020, a Notice of Regulatory Management regarding the Import of Recycling Iron-steel was issued, allowing the import of recycling materials for brass, copper and cast aluminum alloy from the 1st November 2020.
Therefore, scrap metals that meet the relevant GB/T (i.e. Chinese standards for metals) and are re-classified as recyclable materials can be imported into PRC.
The following table provides a useful overview:
Recycling materials that do not belong to solid wastes
Importable Recycling materials | HS Code | Effective date | Legal basis | |
Recycling Iron-steel Materials that are in accordance with the National Standard of Recycling Iron-steel Materials (GB/T 39733-2020) | 7204100010 7204210010 7204290010 7204410010 7204490030 | 1st January 2021 | Ministry of Ecological Environment, the NDRC, the General Administration of Customs, the Ministry of Commerce and the Ministry of Industry and Information Technology Notice No.78 of 2020 | |
Recycling Materials for Brass that are in accordance with the National Standard of Recycling Materials for Brass (GB/T 38470-2019) | 740000020 | 1st November 2020 | Ministry of Ecological Environment, the General Administration of Customs, the Ministry of Commerce and the Ministry of Industry and Information Technology Notice No.43 of 2020 | |
Recycling Materials for Copper that are in accordance with the National Standard of Recycling Materials for Copper (GB/T 38471-2019) |
| 1st November 2020 | Ministry of Ecological Environment, the General Administration of Customs, the Ministry of Commerce and the Ministry of Industry and Information Technology Notice No.43 of 2020 | |
Recycling Materials for Cast Aluminum Alloys (GB/T 38472-2019) |
| 1st November 2020 | Ministry of Ecological Environment, the General Administration of Customs, the Ministry of Commerce and the Ministry of Industry and Information Technology Notice No.43 of 2020 | |
Members with any questions about the import of these materials into China should contact the Loss Prevention Department.