Recently, there have been frequent stories about the import of recycled plastic pellets in Guangdong, Qingdao and Dalian. In the end, how to determine whether the recycled plastic pellets in different states are solid waste or general merchandise. Many friends are not very clear about the relevant rules. They need to clear the source. The author gathers the opinions of the masters and summarizes the relevant information as follows:

1. What is the "three unifications"?

The Supervisory Department of the Customs and Excise Department sent an urgent document to the Guangdong Branch and the respective customs offices on May 30, 2014. The import of black recycled pellets was clearly as follows:

The recycled plastic pellets of the primary form processed from waste plastics may not conform to the solid if the imported batches of the same batch are of the same color, uniform particle size and shape, consistent packaging, and meet the relevant specifications and standards of plastic materials or products. Waste supervision.

If it is found that the recycled plastic particles are suspected of solid waste during the supervision process, it shall be identified by the cargo attribute of the solid waste identification institution and shall be supervised according to the identification results.

Description: Three uniforms can be carried out in one package, not in one container.

2. Problems with industry response

1. Color difference, color mixing (as shown below):

The same batch of waste plastic granulation, due to various reasons, the color can not be exactly the same, how many will have chromatic aberration, especially light color.

According to the three unifications, this material does not meet the requirements of the “three unifications”. It is suspected that solid wastes will be sent to the appraisal agencies for identification. Some identification agencies will judge solid waste because of the color difference. The customs will require the goods to be retired. Shipped.

The granules are granulated with larger chromatic aberrations (as shown below):

The following is composite membrane granulation (As shown below):

2. Difference in shape and size ( as shown below):

The granules of different granulation methods are cut in the water and under water, and are directly sent to the storage tank during production. This is the case after packaging.

According to the "three unifications", this material does not meet the requirements of the "three unifications" and belongs to suspected solid waste. Customs will request identification agencies to identify them. Some identification agencies may be judged because of different particle shapes and sizes. For solid waste, the Customs will require the goods to be returned in accordance with the appraisal conclusion.

3. Is the customs determining the attributes of imported goods?

Everyone mistakenly believes that the Customs believes that your goods are solid waste or solid waste, and they are returned. It is a big mistake. Customs supervision only makes preliminary judgments according to the requirements of "three unifications", which is beyond the scope of "three uniforms". The goods, the customs can only determine: suspected solid waste, whether it is solid waste, can only be sent to the identification agency for identification.

It is the appraisal agency that issues an appraisal report to determine the attributes of the goods.

Identification report style

It is used in the same way as the psychiatric appraisal report. The difference is that it can be exempted from prosecution for identification as a mental illness. It is identified as solid waste and must be returned.

Once sent to the appraisal agency, the time is short for one month and for two months, the importing companies are suffering, so in order to solve this problem, the country has added a lot of solid waste appraisal institutions.

4. According to what is the identification agency to identify solid waste or ordinary commodities?

The General Principles for the Identification of Solid Wastes (GB34330-2017) is the only standard in the industry for solid waste identification.

In General Regulation 5.2 , “Products made from solid waste meet the following conditions, not as solid waste management, in accordance with the corresponding product management”, “in accordance with national, local or industry-standard product quality standards for the production of substitute raw materials”, "There is a stable and reasonable market demand."

General 6.1 “The following substances are not treated as solid waste:”

“Any substance that can be used for its original purpose without repair and processing, or a substance that meets national, local, or industry-accepted product quality standards and is used for its original purpose after it has been repaired and processed.”

According to this general rule, basically two questions should be judged as ordinary goods.

However, some organizations will use three unifications as the basis for identification and identify them as solid waste. This issue is different. It is the current import of particles with different color and size, which is the key to the identification problem.

There is a standard “Guidelines for the Identification of Solid Wastes” (Trial), which has been implemented since April 1, 2006, and has specified many specific methods. Introduced as follows:

Judging whether a substance, article or material (hereinafter referred to as a substance) is a solid waste based on characteristics and influence requires consideration of the following factors:

(1) General considerations. This includes whether the substance is intentionally produced, whether it is manufactured to meet market demand, whether the economic value is negative, and whether it is part of a normal business cycle or use chain.

(2) Features. This includes: whether the production of the substance is quality controlled and meets national or internationally recognized norms/standards.

(3) Environmental impact. Including: whether the use of the substance is environmentally friendly compared to the primary product; whether the use of the substance increases the risk to human health or the environment during the production process compared to the corresponding raw material; whether it is human health or the environment There is a greater risk; whether the substance contains environmentally harmful ingredients, and these ingredients are usually not found in the substitute raw materials or products and cannot be effectively utilized or reused in the recycling process.

(4) Use and destination. This includes: whether the substance needs further processing before use; whether it can be applied directly in production/commercial use; whether it can be put into use with only minor repairs; whether it is still suitable for its original purpose; whether it can be used as a substitute for other uses; Whether it is actually applied in the production process; whether it has a fixed use; whether it can be used in its existing form or in a form not handled by the operation methods listed in Table 1; whether it can be used only after being processed by the operation methods listed in Table 1. .

To assess whether a substance is solid waste, all of the above factors need to be considered.

Depending on the assessment target, the factors that need to be considered are different. The following flow chart can be used for the identification of solid waste and non-solid waste, but in the specific application, it should be identified according to the characteristics and impact of the substance.

5. Do not agree with the identification results given by the identification agency. Is there any other way?

This is a purely technical issue. No information was collected that could not be found in other identification agencies.

The author is looking for the final answer to the question, pleading for the great God who can answer

Generally, the customs directly entrust the relevant identification agencies to identify them, not who the cargo owners want to find.

6. What should be done if different identification agencies may draw different conclusions about the same goods?

This problem is very difficult to do. The State has the "General Principles for the Identification of Solid Wastes" (GB34330-2017), which lacks a targeted standard for recycled plastic particles.

There are no standards for various identification agencies to make various differences can not be avoided, different identification agencies may draw different conclusions for the same goods can only be through the preparation of "plastic waste reprocessing products solid waste identification standards."

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