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European paper for recycling falls into 5 main categories: ordinary, medium and high grades, kraft grades, and special grades. Within these are over 60 sub-category grades. They are either pre-consumer paper waste that has been discarded from a paper mill, or post-consumer waste of the kind that is collected from households. 

What are waste paper grades for?

Waste paper grading provides guidance on the quality and composition of paper for recycling. Manufacturers have specifications for their paper and board products that cover fibre type, chemical ingredients and the percentage of recycled content. Their choice of graded waste paper for use as a secondary raw material in the manufacturing process is largely determined by these specifications.

No international standards for recovered paper

There is currently no global standard for waste paper grades. Several nations and trade blocs, including the United States and Australia, use their own grading categories and enforce different rules on contamination, for example. Some countries such as India classify scrap paper as hazardous waste, while others don’t classify it as waste at all (Italy). This creates uncertainty for international waste paper traders who need to ensure that the materials they ship – and the documentation that accompany the shipments – meet all the requirements of every country involved. Hence the growing popularity of commodity trading and risk management CTRM software.

How is waste paper assessed?

Paper mills and traders will typically assess the strength, quality and utility of paper for recycling before buying it. Grading is part of this assessment, but buyers also conduct site visits and visual inspections to establish the quality, level of contamination, and moisture content of what they are being sold. This includes seeing how the material is stored.

While some recovered papers can deliver high whiteness, smoothness, and runability (which indicates how easily it moves through a printing press), the length of paper fibre shortens every time it is reprocessed. This limits what it can be used for and the number of times it can be recycled (6 times is considered the maximum). Some types of paper such as tissues and laminated paper cannot be recovered, because they are bonded with materials unsuitable for recycling.

European standard grades for waste paper

The following paper grades are defined by European Standard EN 643 agreed by the Confederation of European Paper Industries (CEPI). The 2013 revisions introduced maximum tolerance levels for non-paper components (1.5% for most grades) and for unwanted materials. Grade descriptions were also amended to reflect the composition of the material rather than its origin.

According to these standards, natural fibre-based paper and board suitable for recycling is defined as: ‘paper and board in any shape or product made predominately from paper and board, which may include other constituents that cannot be removed by dry sorting, such as coatings, laminates and spiral bindings.’

Ordinary and medium grades

Ordinary grades tend to contain short fibres, including sub-categories such as mixed paper and board, grey board, mixed newspapers and magazines, corrugated paper and board, and sorted graphic paper for de-inking. Medium grades contain unsold newspapers free from inserts, printed white shavings, sorted office paper, coloured letters, white books, coloured magazines, and continuous computer print-out paper.

High and kraft grades

High grades are mainly white papers made from virgin fibres such as mixed lightly coloured printer shavings, binders, letters, white business forms, white computer print-out, printed multi-ply board, white shavings and unbleached board. Kraft grades derive mostly from brown unbleached packaging materials such as paper sacks and corrugated boxes. Their long and strong fibres are particularly suited for recycling into new packaging.

Special grades

Special grades tend to combine papers that are not considered profitable to sort. Special grades are often used in the middle layers of packaging papers and boards. Examples of special grades are mixed recovered paper and board, mixed packaging, wet-strength papers and labels.

The Single Trade Window (STW) is a UK government initiative to create a one-stop digital entry point for UK traders where they can exchange data with customs and border authorities. Its objective is to grow the UK’s share of global commerce by reducing duplication, costs and delays at the border. The STW launch is scheduled for 2025, but this date is likely to be missed.

How will the STW work?

The various border authorities and agencies are expected to share data between themselves to provide the trader with a single point of digital interaction. Longer term, the government’s 2025 UK Border Strategy aims to create a seamless digital border that enables traders to complete and submit border information directly, with lower costs for everyone involved. This will require the adoption of standard data formats for automation, more international agreements on information exchange, and digital infrastructure to handle large volumes of live supply chain data.

What is the Single Trade Window replacing?

Under the current system, traders exchange data with up to 25 authorities and agencies at the UK border, depending on the type of consignment. Navigating the various data formats and portals is time-consuming and prone to human error, which risks penalties and goods seizure further down the line. As a consequence, many traders employ customs brokers to manage the complexities of customs valuation, tariff classification, and rules of origin.

These brokers and intermediaries employ a variety of e-customs software to connect with Community Systems Providers (CSP). CSPs are commercial entities that provide network services between HMRC, border agencies, and logistics operators such as freight forwarders and shipping lines. Each CSP badge (electronic login) provides access to designated ports, airports, and customs warehousing inventory systems. HMRC’s new digitally-enabled Customs Declaration Service (CDS), which replaces the old paper-based CHIEF system, can also be accessed via CSPs.

Why now?

The STW is designed to operate within the legislative framework of the UK’s Electronic Trade Documents Act which passed into law in 2023. The Act effectively puts electronic documentation on the same legal footing as traditional hard copy documents. It promises to eliminate paper form-filling, and countries such as Singapore with similar legislation are already piloting electronic bills of lading with UK traders.

New Zealand, Sweden, Switzerland and the United States have implemented single trade windows of their own to various degrees. This suggests a growing willingness to remove obstacles to electronic communication in international trade as outlined by the United Nations Centre for Trade Facilitation and Electronic Business (UN/CEFACT).

When will the Single Trade Window be complete?

Other countries have shown that implementing a basic single trade window shielded by robust data protection (GDPR) is achievable. However, the UK government’s longer term ambition to enable traders to self-declare their border data at no extra cost promises to be much harder.

It will require the industry to embrace digitalisation and AI so that live data can be exchanged between traders and governmental agencies without the need for intermediaries and consultants. Old-fashioned interactions with legacy port and commercial systems overseas will continue for many years in some territories, creating interoperability challenges. Fees for integrating with third parties such as airports, ports and overseas customs warehouses will not disappear any time soon, either. Delivering a truly seamless digital UK border is therefore likely to be an ongoing process rather than a ‘big bang’.

An export packing list is a document that sets out the quantity of goods in an international shipment and how they are packaged, among other details. Customs authorities and supply chain partners such as shipping lines consult the packing list to learn more about the cargo they are dealing with so they can expedite the shipment.

Sometimes a packing list is also referred to as a manifest, a bill of the parcel, an unpacking note, a packing slip, a delivery docket, a delivery list, a shipping list, or a customer receipt. 

Why is an export packing list needed?

An export packing list is not necessarily a legal requirement, but it serves many essential functions along the chain of custody. For shippers, the packing list is a key component of the booking process, enabling a count of the goods so they can organise the cargo’s transportation. For Customs, having sight of a compliant packing list streamlines identification and registration of the shipment, and provides them with the information on the certificate of origin.

For a freight forwarder or importer, the packing list acts as supplementary evidence that can sometimes resolve or avoid holdups. It acts as an inland bill of lading. It provides proof for a material safety data sheet if the material is classified as hazardous waste. The receiver/buyer often refers to the packing list when checking and taking possession of the consignment. In the event of reimbursement under a letter of credit, the packing list serves as a supporting document.

What information goes on an export packing list?

A packing list has the contact information of the shipper, exporter and consignee, as well as the cargo’s origin address and destination address. It records the total number of packages within the shipment, and a detailed description of each package, including the volume in cubic metres, the weight of each package (in kg), and the weight of the entire shipment (also in kg). A packing list will usually include the commercial invoice number of the shipment and any identifying numbers or marks on the outside of each package such as a unique product reference number.

The packing list will identify the method of dispatch – be it road, rail, air or sea freight – and may include the name of the vessel and the flight or voyage number. It will identify the type of shipment, for example FCL (full container load), LCL (less than full container load), or Breakbulk (goods shipped without the use of a container). It will record the port of discharge (POD) and the port of loading (POL), including the date of departure.

Many other details can be added to the packing list, such as a bill of lading number if it is known, or the buyer reference number on a purchase order. This will depend on what the customs broker or freight forwarder thinks will help in getting the goods clear of Customs and delivered to their rightful destination. Once the packing list is complete, the shipper’s authorised signature is then added along with the company stamp or seal. 

Do packing list details need to match up?

Yes. It’s important that all the details on the packing list – such as the parties in the transaction – match those on accompanying documentation. Discrepancies between the packing list, the commercial invoice and the bill of lading carry the risk of delays and fines.

The UK government will introduce a Mandatory Digital Waste Tracking (MDWT) system from April 2025 to monitor the production and movement of waste. Anyone in the UK who produces, handles, disposes of, or makes products from waste will be obliged to enter information onto the database which is being piloted this year by the Department for the Environment, Food and Rural Affairs (Defra). 

Traders of secondary raw materials therefore need to get ready for MDWT as a matter of priority.

What is MDWT replacing?

The new UK-wide system, which Defra is coordinating with the devolved administrations, will replace the existing fragmented system of waste tracking that is still largely paper-based. The other big change is that MDWT extends monitoring to household waste movements. This will be accompanied by reforms to permits for waste carriers, brokers and dealers, although details about how MDWT will work in practice await clarification.

Why now?

Recent advances in digital technology have made MDWT a viable option for government. A fully digitalised system will enable a single comprehensive means of tracking the amounts and types of waste being produced across the UK. It should reveal where most of the waste ends up, which represents a step-change in transparency for the sector.

With this move, Defra hopes to reduce waste crime, which costs the economy £1b a year and is estimated to affect 18% of all waste. This includes fly-tipping (which is mainly household waste), deliberate misclassification of waste, illegal waste exports and the operation of illegal waste sites. The idea is that MDWT will facilitate a more level playing field for legitimate waste operators.

More broadly, Defra wants businesses and government to adopt circular economy principles in line with the UK’s Net Zero commitments. Encouraging waste exporters to embrace digitalisation underpins this strategy. The government’s new digitally-enabled Customs Declaration Service enters into force this year, which will see the old paper-based CHIEF system shut down. At that point, waste exporters will have a strong incentive to modernise their approach to compliance and reporting.

How will digital tracking work?

Details about the practical implementation of MDWT are not yet public. What we can assume, however, is that all existing legal requirements to record waste movements will still apply under DWTM. In general, waste tracking records need to be kept when waste is passed to a different organisation or person; when it is moved between sites operated by the same organisation; and when waste is passed from the control of one organisation to another organisation within the same site. So these fundamental obligations should remain the same.

The method of compliance is likely to change however. Current UK legislation requires a written description to accompany the transfer of waste. For non-hazardous waste, these ‘duty of care’ records currently involve the completion of a waste transfer note, or a consignment note for hazardous/special waste. A streamlined digital equivalent of these processes will probably be introduced by MDWT.

Does this mean less paperwork for businesses?

That depends. Businesses that resist digitalisation will need to shoulder the administrative burden of manually inputting greater quantities of reporting data. On the other hand, businesses that adopt automated digital processes using CTRM software will – in theory at least – find the burden of compliance lightened because there will be far less manual form-filling and scope for human error. From Defra’s point of view, a unified digital database should reduce admin and provide greater quantities of up-to-date information that can be analysed to help regulators and inspectors do their job.

What are the risks of digital tracking?

Businesses will almost certainly have additional reporting responsibilities under MDWT, which will come with additional risks. The principal risk relates to liability. An organisation that transfers waste to a contractor or sub-contractor still bears a responsibility for that waste. If there is a prosecution for non-compliance, for example, everyone in the chain of custody is liable. With improved tracking under MDWT, businesses will need to take extra care that waste is managed responsibly once transferred to a licensed waste carrier because the evidence will be clearer about whose hands it passed through.

The other risk relates to back office. If your team isn’t equipped for new compliance rules and digital processes, then you might face higher staffing costs, more consultancy fees, and the possibility of fines if things go wrong. Digitalising your business also comes with costs, although these tend to be outweighed by longer term productivity gains.

End-of-waste is the point at which a discarded waste product or material gets recovered or recycled to become a substitute for raw materials. It is a step that enables waste to be reclassified as a tradeable product or commodity, usually after processing or a quality assessment. 

A set of standard regulations to define end-of-waste are being worked on by the EU as part of its circular economy action plan, which is proving controversial in the recycling sector.

Why does end-of-waste matter?

End-of-waste is important to business because products or materials classified as waste are subject to special waste management rules that limit what the materials can be used for. Waste also has special storage and transport requirements which tend to cost more. From a sustainability point of view, end-of-waste is important because it determines the environmental standards of many products and materials that are bought, sold and shipped around the world.  

The regulatory burden associated with end-of-waste standards has an impact on the growth of the circular economy and the extent to which recovered or recycled materials get used in new products instead of virgin materials. Setting a high bar for end-of-waste often makes recycled materials more expensive, deterring their use, which can see more waste ending up in landfill. On the other hand, lower end-of-waste standards can undermine customer confidence in the sustainability of the products they are buying, which can lower demand for recycled materials.

Who decides end-of-waste?

Regulations governing end-of-waste differ widely, both within the EU and further afield. In some EU countries end-of-waste is decided by a governmental authority. In others, the same category of waste can be reclassified as a non-waste product or raw material by the actual waste holder. So the EU intends to harmonise these rules in the hope of eliminating trade distortions and encouraging growth in the circular economy.

Is all waste regulated equally?

No. Some groups of waste are more heavily regulated than others, although this can vary between jurisdictions. Waste paper, for example, is classified as hazardous waste by India, whereas Italy doesn’t classify it as waste at all. Acceptable levels of contamination differ between countries too. An exporter therefore needs to take care that the secondary raw materials they are shipping, along with the accompanying documentation, comply with the regulations of every country involved. Mistakes can lead to penalties or the shipment being rejected by customs authorities, so exporters often hire agents and consultants to avoid this, adding to their costs.

Why are end-of-waste rules controversial in the paper industry?

Setting a new standard for end-of-waste is more than just an environmental issue. In the UK, the Confederation of Paper Industries (CPI) has resisted lobbying to shift end-of-waste for waste paper to before the pulping stage. While advocates suggest that the proposal will promote the export of scrap paper as a usable commodity, benefiting the circular economy, the CPI argues that it would lower standards and leave UK mills with inferior quality material. EU reforms to end-of-waste – if and when they pass into law – are sure to influence the debate.

A packaging waste export recovery note (PERN) is a tradeable certificate that serves as evidence of UK packaging that’s been exported to be recycled by a certified waste reprocessor. It is the export equivalent of packaging waste recovery notes (PRNs) which are used for UK waste reprocessing.  

Who issues PERNs and PRNs?

PRNs and PERNs are issued either by UK waste reprocessors – businesses that recycle packaging waste into something new – or by UK waste exporters who are sending the material for reprocessing abroad. Both UK reprocessors and packaging waste exporters need to apply to the National Packaging Waste Database (NPWD) for accreditation enabling them to generate PRNs and PERNs.

Who buys PRNs and PERNs?

Companies that produce packaging waste and handle more than 50 metric tonnes and £2m turnover are referred to as obligated producers. They are obligated to buy PRNs and PERNs to reflect the tonnage of a specific type of packaging that has been recycled to a required standard. These evidence notes are used to demonstrate the producer’s compliance with packaging waste obligations, which are annual targets set by government in line with the ‘polluter pays’ principle.

What’s the purpose of the PRN system?

By paying a price for the quantity of packaging waste produced, waste generators are in theory being incentivised to produce less of it. Waste generators don’t need to recycle their own packaging, however. Buying a PRN certificate demonstrates that an equivalent amount of packaging waste has been recovered and recycled on their behalf, thereby meeting their obligation.

More broadly, the government wants to encourage trading in recyclable materials by adding value to what the market would otherwise consider low value and not worth recycling. The longer term objective here is to grow the global circular economy in line with Net Zero. It is also hoped that profits from the PRN marketplace will finance the development of recycling infrastructure in the UK.

How does the PRN market work in practice?

In trading terms, PRNs and PERNs act as ‘sweeteners’ or financial incentives for the exporter/reprocessor. For a waste trader, the value of a tonne of PRN qualifying commodity is its intrinsic value plus the prevailing market rate of the corresponding PRN note. So the producer of waste is effectively subsidising waste reprocessing, whether that happens in the UK or overseas in certified facilities where environmental standards are deemed to be equivalent to the UK’s.

PRNs are specific to a grade of material – but they do not accurately track the market value of the commodity itself. Internationally traded commodity prices are mainly determined by global market dynamics. PRN prices are more influenced by a range of domestic factors related to perceptions of supply and demand.

Why do PERN and PRN prices fluctuate?

Prices of a specific PRN grade rise when supply is perceived to be tight. For example, the commodity might not be traded much because recycling it is costly or complicated. Alternatively, processing capacity or demand for that material might be low. This can force producers to buy at a higher price, especially if they are approaching their annual deadline for fulfilling their obligations. Other factors that influence PRN values include the government’s annual target for packaging waste recycling, the price of oil and secondary raw materials, and exchange rates.

What are PERN and PRN compliance schemes for?

Compliance schemes and agents exist to manage the complexity of the PRN marketplace, providing greater predictability to busy traders, reprocessors and producers. An exporter might issue PERNs to a compliance scheme if they want the certainty of being paid a fixed monthly rate. On the other hand they might choose to sell their PERNs on the open market if they are comfortable with the risks of fluctuating daily prices.

Is change coming to the PRN marketplace?

The PRN marketplace has no close equivalent outside the UK, which might suggest that other countries are not persuaded of its overall benefits as a model to emulate. Consultations exploring ways to reform or replace the system alongside extended producer responsibility have been launched, but repeated delays suggest that change it unlikely to happen until 2025 at the earliest.

A certificate of chemical analysis report (CAR) is one of several customs clearance documents that exporters of waste paper to India are required to submit before a shipment arrives at port. This is because scrap paper and scrap metal are classified as hazardous waste in India.

The CAR certificate along with a pre-shipment inspection certificate (PSIC) need to be issued by an inspection authority such as CWM that is recognised by India’s Directorate General of Foreign Trade (DGFT) and is present in the exporter’s country. Without these documents, a waste paper shipment risks being turned around at the port and returned to the exporter’s country. 

What information goes on a CAR document?

A CAR certificate contains details of the exporter, importer and waste originator. It lists the shipment’s container numbers, the quantity of bales, the weight in metric tonnes, and the Harmonised System (HS) code of the waste paper. It certifies that these details are true and correct.

It also certifies that, after due chemical analysis, the material fits the internationally acceptable parameters for waste paper; that there’s no putrefiable organic matter; that the approximate content of non-paper material is no more than 1%; that the shipment contains no municipal solid waste, medical waste or what the exporter country would define as hazardous waste. 

The agency also certifies that the waste paper originated from a dual stream source. Dual stream means they are separated recyclables which generally have less contamination and command higher prices.

What other customs clearance documents do I need?

Your CAR document needs to be accompanied by the PSIC and a certificate of origin (COO). The COO serves to confirm a product’s country of origin, in other words its ‘nationality’.

The information captured in a PSIC is almost identical to a Chemical Analysis Report. Only the manner of verification is different: one is based on inspection procedures, the other on due chemical analysis.

Indian customs want a hard copy CAR

Remember that Indian Customs require a hard copy of the CAR and the PSIC before the shipment arrives. Obtaining certification on or after arrival is not permitted. Rejected shipments are sent back to the exporter country, with the exporter bearing the costs.

How do I obtain a Certificate of Chemical Analysis Report and PSIC?

Exporters of waste paper and scrap metal to India should contact an authorised inspection agency before the shipment begins its journey – and be ready to supply the information and evidence needed for the agency to verify that the shipment is compliant. Inspection agencies have specific requirements regarding photographic evidence before they can issue a PSIC, for example. To avoid delays in obtaining customs clearance documentation, be sure that the agency has everything it needs in the requested format.

When a truck drives over a weighbridge, its mass is measured, enabling the creation of a weighbridge ticket. This document identifies what the load weighs, what the load is, and what’s carrying it, which usually refers to the truck’s registration number. 

The weighbridge ticket accompanies the vehicle for its onward journey in the form of a written, hard copy document. For exporters of recyclables such as waste paper, waste plastic, or scrap metal, the value of any given commodity is estimated by weight, so the information captured by the weighbridge ticket is key.

Gross weight and tare weight

The exact mass of the load being picked up or deposited is calculated by subtracting the weight of the unloaded truck or  container – known as the tare weight – from the weight of the truck or container when it is loaded, which is the gross weight. Gross and tare weights should only be entered on the same ticket if ascertained on the same day. If the driver intends to return after loading for a second weighing of the same vehicle to be recorded on the same ticket, the ticket should be retained until the second weighing is complete. 

Weighbridge ticket requirements

The transportation of waste – a category which includes secondary raw materials –  is regulated in the UK, and failing to use a working weighbridge to weigh a load of waste can incur a penalty. The official document that confirms the accuracy of a weighing scale for vehicles and their loads is called a weighbridge calibration certificate (WCC). It certifies that the weighbridge meets acceptable industry standards for accuracy, and sets out the latest calibration test results to prove it. Hysteresis is one of the issues that calibration can fix.

The weighbridge operator is obliged to keep a record of each weighing for 2 years. This can be a duplicate of the weighbridge ticket, but it needs to include the date and time of the weighing; the name and address of the person making the request; details that identify the vehicle; and the type of load on the vehicle.

The future of weighbridge tickets

Physical weighbridge tickets may become obsolete in the coming years. New technologies already exist that enable weighbridge data to be shared electronically with shipping lines in real time, speeding up export procedures. The UK government also introduced legislation, the Electronic Trade Documents Act 2023, which effectively puts electronic documents on the same legal footing as their paper equivalents, removing a barrier to weighbridge tickets being digitalised.

The National Packaging Waste Database (NPWD) is an online database that tracks how much packaging has entered the UK market and how much packaging waste has been recovered or recycled. 

The NPWD is supported by the Environment Agency, the Scottish Environment Protection Agency (SEPA), Natural Resources Wales (NRW), the Northern Ireland Environment Agency (DIEA), and industry. It enables businesses obligated by packaging and battery regulations to prove that they’re meeting their legal requirements. The NPWD is also where waste packaging reprocessors and exporters submit their data for compliance schemes.

The Department for Environment, Food & Rural Affairs (Defra) uses data from the NPWD to help measure the UK’s progress in meeting its recycling and recovery targets in line with Net Zero.

What services does the NPWD provide?

The NPWD went online in 2006, replacing a paper-based system that was considered inefficient and susceptible to fraud. Its first iteration enabled waste reprocessors and exporters to submit their quarterly returns online. Since then the NPWD has expanded to provide a range of functions, including those of a public register and reporter. 

It enables online registration for compliance schemes; accreditation of packaging reprocessors and exporters; approval of batteries treatment operators and exporters; and the issuing of Electronic Packaging Waste Recovery Notes (PRNs) and Electronic Packaging Waste Export Recovery Notes’ (PERNs). It issues batteries evidence notes, generates electronic statements and certificates of compliance. 

It also monitors the compliance of producers, schemes, reprocessors and exporters.

What does packaging mean here?

Packaging in this context is any material used to hold, protect, handle, deliver and present goods. This includes packaging for secondary raw materials and those for finished goods. Pallets, bags, boxes, tape for wrapping, rolls, tubes and clothes hangers sold as part of the clothing item are all defined as packaging for the purposes of the NPWD.

A certificate of origin document serves to confirm a product’s country of origin, which is often required for a soft commodity and certain secondary raw materials. Customs authorities in the destination country often require the COO as part of the import clearance process.

What details go on a certificate of origin form?

The COO document includes the name and contact information of the product’s exporter, receiver and also the producer if this is different from the exporter. It states the country of origin – the product’s ‘nationality’ – and provides a clear description of the product itself, including the HS code, quantity and weight. In some cases the COO includes a waybill number, details of the route and mode of transport, and the commercial invoice numbers and dates.

Are all certificates of origin the same?

No. The most common kind of certificate of origin is non-preferential. It states the origin of a type of product that doesn’t qualify for special treatment. A preferential COO on the other hand is for shipments between countries with a trade agreement. This kind of COO serves as proof that the goods qualify for reduced or no import duties. This enables Customs authorities to calculate the relevant charges. 

All certificates of origin are one-time documents that accompany a specific shipment. Sending a second shipment of the same product requires a new certificate of origin. Remember that the ‘nationality’ of the product is not always the country it was shipped from.

What determines the country of origin?

The country of origin is determined by what parts or ingredients are in a product and where they came from. The production process and where that took place is also important. 

The International Chamber of Commerce (ICC) describes non-preferential rules of origin as goods that are ‘wholly obtained’ in one country. When there are two or more countries involved in the manufacture of a product, origin is obtained where goods underwent their last, substantial, economically-justified processing or working, in an undertaking equipped for that purpose, resulting in the manufacture of a new product or representing an important stage of manufacture.

Where can I get a certificate of origin form?

In the UK, a local Chamber of Commerce can issue or certify a certificate of origin if that is required by the destination country or customer. However not all UK exporters of waste paper to India, for example, use the standard COO document as provided by the ICC. Some produce their own.

Why do some Customs authorities require a COO and not others?

Import duties are not the only reason Customs want to inspect a certificate of origin. When safety is a potential issue, for example – such as with the transport of hazardous waste – Customs need to know what rules to apply during the clearance process. There may also be anti-dumping measures or trade embargoes in place for goods from certain countries, which are features of trade wars.