Exporters of waste paper to India need to provide the customs authorities with a pre-shipment inspection certificate (PSIC) and chemical analysis report (CAR) before their shipment arrives at port.
These documents should 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. These documents are required because waste paper is classified as hazardous waste in India. One exception to this rule is end-of-life tyres (ELTs) which are also classified as hazardous waste but are not subject to the same requirements. Exceptions also exist for scrap metal travelling from certain ‘safe’ countries and entering via specific ports.
What information goes on a PSIC?
A PSIC contains details of the exporter, importer and waste originator. It captures 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 to Customs that an inspection has found the details on the certificate to be true and correct. A PSIC should not be confused with a Certificate of Quality and Quantity, which is accepted by a buyer or a bank for the purposes of payment.
A Chemical Analysis Report is almost identical to a PSIC, but instead certifies that ‘due chemical analysis’ has verified the details of the shipment.
Submission deadline for Customs approval
Indian Customs require a hard copy of the PSIC before the shipment arrives. Obtaining certification on or after arrival is not permitted. Failure to supply an original PSIC in time risks delays and penalties. Rejected shipments are sent back to the exporter country, with the exporter bearing the costs in both money and reputation.
How do I obtain a 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 that need to be fulfilled, for example. This will enable them to issue a pre-shipment inspection certificate in good time.
What does a pre-shipment inspection involve?
The objective of a pre-shipment inspection is to confirm the buyer’s specifications, and to verify the quantity and value of imports and exports in compliance with World Trade Organisation (WTO) requirements. On a practical level, the inspection is checking that the waste being shipped doesn’t contain contaminants that contravene the rules of the destination country.
For physical inspections of scrap and shredded metal shipments, authorised inspectors go to the load site and use specialist equipment to monitor for radioactive content. They also check for forbidden metal items such as arms, ammunition and mines. Once loading is complete, the inspector submits the report together with loading photos and a copy of the shipping documents to the Pre-Shipment Inspection Agency in India.
When there is no physical inspection, which might be the case with waste paper shipments, agencies require sight of photos that capture key steps during the loading process. These include photos of the closed door with the container number visible, a bale break, and a photo of the seal in place clearly showing the seal number.
What are waste paper inspections looking for?
With waste paper shipments, inspection agencies are verifying that the material fits the internationally acceptable parameters for waste paper; that there’s no putrefiable organic matter in it; that the approximate content of non-paper material is not 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 happens after inspections are complete?
Once satisfied by document and visual inspections – and potentially random sampling and chemical analysis – the agency issues a draft PSIC to the exporter which can then be sent to India for customer approval. For many UK exporters, when the original bill of lading is in hand, the original pre-shipment inspection certificates will then be obtained as pdfs. These are printed, signed and stamped with the inspection agency stamp. The documents are then physically sent to the customer in India along with the original bill of lading and a certificate of origin of waste.
Additional export paperwork
Exporters of hazardous waste to India also need to compile form 6 and form 9 transboundary movement documents to comply with the country’s hazardous waste management rules (HWMR). These are drawn from a suite of 12 hazardous waste forms that traders and recyclers can use to obtain authorisations and file reports with the relevant State Pollution Control Board.
