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An Overview of Export of Crushed Milled Ceramic & Metal Catalyst to India

Recycling of Scrap materials for recovering precious and rare metals such as Platinum, Gold, Silver, etc., from various used products such as metal from catalytic converters and milled ceramic waste is quite complex and an extensive process due to their rarity in nature. Due to their rarity, these metals are also considered to be, by default, have an expensive value economically. Scrap that is gained from metal catalytic converter or milled ceramic waste can contain valuable metals such as Rhodium, Palladium and Platinum that are categorised under the Platinum Group of Metals or PGMs.

Due to the manufacturing value of the Platinum Group of Metals,also known as PGMs,being very limited due to their rarity resulting in being quite expensive economically, there will always be a high demand for scraps such as from metal catalytic converters or milled ceramic waste recycling procedure. Apart from the environmentally friendly point of view, the recycling procedure needs to be regulated precisely and carefully to avoid health and ecological endangerment as such scrap materials are considered to be hazardous waste.

The Government of India issued a restriction on the exportation of hazardous waste materials containing rare and expensive metals in India via a notification from the Ministry of Commerce. Prior to this notification, the exportation of such materials was free. These precious metal wastesnow fall under the Restricted Category resulting in the exporterapplying for a license and required permissions from the DGFT, which stands for the Directorate General of Foreign Trade, for the exportation of such materials into the country.

The hazardous waste materials are valuable and are primarilyin the form of ash, which carries various metals such as Platinum, Clad with Platinum, Gold and Silver, etc.

In the current scenario, the exportation of scraps of hazardous waste, such as Crushed Milled Ceramic & Metal Catalyst, from India to other countries is “Free”, butThe Directorate General of Foreign Trade (DGFT) recently made an amendment to the export policy for materials of ash that contain precious metal compounds such as Platinum, gold, etc., from being “Free” to “Restricted” with immediate effect for of scraps of hazardous waste, such as Crushed Milled Ceramic & Metal Catalyst to be exported to India as mentioned in the notification dated 29th April 2022.

List of Restricted Items Notified Free

The following items were revised to be declared “Restricted” from being “Free” for exportation to Indiawith immediate effect–

  • Ash such as scraps from Crushed Milled Ceramic & Metal Catalyst that contain rare metals or rare metal compounds
  • Gold that contains Clad Metal and Gold but excludes other swept materials
  • Platinum that contains Clad Metal and Platinum but excludes other swept materials
  • Silver that contains Clad Metal and Silver but excludes other swept materials
  • Swept wastes that contain Gold
  • Swept wastes that contain Silver
  • Other swept wastes that contain rare metals

The necessity of the Permission for Export Authorisation

MoEF stands for Ministry of Environmental and Forest, which is the licensing authority from which the companies in the business of export require an official permission certification forexporting scraps ofhazardous waste such as Crushed Milled Ceramic & Metal Catalyst.

The companies in the business of exportation have to apply for the required certification in a specific format for exporting scraps of hazardous waste such as Crushed Milled Ceramic & Metal Catalystthat can be only used as raw materials.

    The export company has to maintain the following responsibilities –

  • Packaging of scraps of hazardous waste such as Crushed Milled Ceramic & Metal Catalyst.
  • Labelling of scraps of hazardous waste such as Crushed Milled Ceramic & Metal Catalyst.
  • Quality of the raw material ofscraps of hazardous waste such as Crushed Milled Ceramic & Metal Catalyst.
  • The required duties and responsibilities for the purpose of exporting scraps of hazardous waste such as Crushed Milled Ceramic & Metal Catalyst.
  • Fully Insured for the purpose of transit of scraps of hazardous waste such as Crushed Milled Ceramic & Metal Catalyst.
  • Providing decent facilities for the cleaning up in case of spillage for any scraps of hazardous waste such as Crushed Milled Ceramic & Metal Catalyst.

Documents for Export Authorisation

The following are the Documents needed in the current scenario of exportation of scraps of hazardous waste, such as Crushed Milled Ceramic & Metal Catalyst–

  • Permission Certificate from MoEF for export of any hazardous waste or scrap, for example, Crushed Milled Ceramic & Metal Catalyst.
  • Permission Certificate from SPCB for export of any hazardous waste or scrap, for example, Crushed Milled Ceramic & Metal Catalyst.
  • Permission Certification from the DGFT.
  • Consent Letter from the Country the hazardous waste or scrap, for example, Crushed Milled Ceramic & Metal Catalyst is being exported to specifying that they do not have any issues with the good being imported to their country.
  • A Legally Binding Agreement signed by both the countries who are to export or import the scrap materials.
  • I thoroughly covered insurance of all the goods being exported.

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Procedure for Export Authorisation

The following is the procedure in the current scenario of exportation of scraps of hazardous waste, such as Crushed Milled Ceramic & Metal Catalyst –

  • The filing process in the current scenario of exportation of scraps of hazardous waste, such as Crushed Milled Ceramic & Metal Catalyst, can be done online as well as offline.
  • After the application is filed, the SPCB,also known as the State Pollution Control Board,sends proof of acknowledgement to the applicant regarding receiving the application.
  • A public hearing is conducted by the MoEF, also known as the Ministry of Environmental and Forest, regarding the verification of the scraps of hazardous waste, such as Crushed Milled Ceramic & Metal Catalyst, to be exported to India.
  • The Consent Letter is then issued by MoEF and SPCB regarding the exportation of scraps of hazardous waste, such as Crushed Milled Ceramic & Metal Catalyst to be exported to India.
  • A Copy of the Legally Binding Agreement that has been Drafted and Signed between both countries for the purpose of recycling thescraps of hazardous waste, such as Crushed Milled Ceramic & Metal Catalyst, needs to be submitted where the clauses must state that neither of the countries has any issue in the importation and exportation procedure of such scraps.
  • A Post Compliance Report is drafted by the respective authority and sent to the applicant.
  • MoEF then notifies the SPCB for an inspection to be conducted,not checking up on the procedure of the Exportation and if all the errors mentioned in the Post Compliance Report have been rectified.
  • After the fulfilment of the procedures mentioned above, either the MoEF or SPCB grants the Permission for the exportation of scraps of hazardous waste, such as Crushed Milled Ceramic & Metal Catalyst to be exported to India.

Rules to be Followedby the Exporter

Under the Rules provided in the Customs Act, 1962, the exporter has to ensure the following are not to be violated –

  • Exportation from any country for the just purpose of disposal of hazardous waste is not permitted.
  • The exported hazardous waste such as Crushed Milled Ceramic & Metal Catalyst shall be utilised for recycling and recovery purposes only.
  • No MSW or Municipal Solid Waste; PCDW or Post Consumer Domestic Waste; Bio-Chemical Waste; or any other Hazardous Waste to be exported to India with Plastic Waste. The materials shall be immediately shipped back with the importer bearing the entire transportation charges in case of violation.
  • The Unit has to maintain all required details of the exporter, from where the consignment was exported, and inventory of the exported hazardous waste such as Crushed Milled Ceramic & Metal Catalyst.
  • During the recycling process, if any residue is generated, a record of the quantity and the nature of the non-recyclable material should be maintained, which is to be disposed of via an ecologically safe order as per the notifications provided by the effective State Government’s State Pollution Control Board (SPCB).

Validity of the Permission for Exportation

The validity of a NOC or the No Objection Certificate provided by the MoEF is until the validity of the Consent Letter issued by the effective State’s State Pollution Control Board(SPCP).

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Frequently Asked Questions

DGFT, which stands for the Directorate General of Foreign Trade, is a Governmental Body that is in charge of the exportation of hazardous waste such as Crushed Milled Ceramic & Metal Catalyst materials into the country.

The DGFT recently amendment to the export policy for materials of ash that contain precious metal compounds such as Platinum, Gold, etc., from “Restricted” to “Free” with immediate effect from 29th April 2022.

Waste Materials declared free by DGFT:

  • Ash including contains of rare metals or rare metal compounds
  • Gold that contains Clad Metal and Gold but excludes other swept materials
  • Platinum that contains Clad Metal and Platinum but excludes other swept materials
  • Silver that contains Clad Metal and Silver but excludes other swept materials
  • Swept wastes that contain Gold
  • Swept wastes that contain Silver
  • Other swept wastes that contain rare metals

Required Documents for the exportation of scraps of hazardous waste such as Crushed Milled Ceramic & Metal Catalyst:

  • Permission Certificate / License from MoEF for export of any hazardous waste, for example, Crushed Milled Ceramic & Metal Catalyst.
  • Permission Certification from the DGFT
  • NOC from MoEF
  • Consent Letter from SPCB

Suppose any residue is generated during the recycling process. In that case, it is to be disposed of via an ecologically safe order as per the notifications provided by the effective State Government’s State Pollution Control Board (SPCB).

No MSW or Municipal Solid Waste; PCDW or Post Consumer Domestic Waste; Bio-Chemical Waste; or any other Hazardous Waste to be exported with Plastic Waste. The materials shall be immediately shipped back with the importer bearing the entire transportation charges in case of violation.

The validity of a NOC or the No Objection Certificate provided by the MoEF is until the validity of the Consent Letter issued by the effective State’s State Pollution Control Board (SPCP).

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