For certain categories of metal and metal-alloy wastes, the rules provide a specific procedure and documentation for import through customs.
NOZIX provides professional assistance for scrap import documentation and environmental compliance, helping importers organize the required documents and understand the applicable regulatory requirements.
What is Scrap Import Compliance?
Scrap import compliance involves ensuring that the proposed scrap material falls within the permitted category and that the importer has the applicable approvals, consents, certificates, movement documents, and other supporting documents required for clearance.
Under the Rules, import of hazardous and other wastes is permitted only for purposes such as recycling, recovery, reuse, and utilization, including co-processing. Import for disposal is not permitted.
Metal Scrap Covered Under the Rules
Schedule VIII of the Rules identifies Basel No. B1010 – Metal and metal-alloy wastes in metallic, non-dispersible form.
The listed materials include:
- Iron and steel scrap
- Aluminum scrap
- Copper scrap
- Nickel scrap
- Zinc scrap
- Tin scrap
- Magnesium scrap
- Chromium scrap
- Titanium scrap
- Cobalt scrap
- Manganese scrap
- Tungsten scrap
- Molybdenum scrap
- Other specified metal and metal-alloy wastes
The applicable classification should be checked carefully before importing the material.
Documents Required for Metal Scrap Import
For metal scrap falling under the specified category, the Rules provide for verification of documents by Customs. These include:
1. Form 6 – Movement Document
A duly completed Form 6 – Movement Document is required for the applicable import consignment.
2. DGFT Import License
An import license from the Directorate General of Foreign Trade (DGFT) is required wherever applicable.
3. Pre-Shipment Inspection Certificate
A Pre-Shipment Inspection Certificate (PSIC) issued by the inspection agency of the exporting country or an inspection and certification agency approved by DGFT is required as applicable.
4. Valid Consent and Hazardous Waste Authorization
For actual users, the applicable Consent to Operate under the Air and Water Acts and authorization under the Hazardous and Other Wastes Rules are required.
For traders, the rules provide for the applicable valid one-time authorization from the concerned State Pollution Control Board.
5. Chemical Analysis Report
A chemical analysis report of the waste being imported is required for the applicable scrap category.
6. Annual Return Record
An acknowledged copy of the annual return filed with the concerned State Pollution Control Board for import in the previous financial year is also specified among the documents for verification.
Actual User vs Trader
The applicable compliance requirements can differ depending on whether the importer is an actual user or a trader.
An actual user may be required to have the applicable environmental consent and authorization for handling or utilizing the waste. The rules separately provide requirements for traders importing waste on behalf of actual users.
Therefore, identifying the correct importer category before preparing the documentation is an important part of the scrap import compliance process.
Environmental Authorisation for Scrap Handling
Facilities engaged in activities such as handling, storage, processing, recycling, recovery, utilization, or other specified management of hazardous and other wastes are subject to authorization requirements from the concerned State Pollution Control Board under the Rules.
The State Pollution Control Board may examine the facility, its technical capabilities, equipment, and compliance with applicable procedures before granting authorization.
Import Procedure for Regulated Waste
For hazardous wastes and certain other wastes falling under the relevant categories of Schedule III, the Rules prescribe different import procedures.
For Part A and Part B of Schedule III, actual users are required to apply in Form 5 to the Ministry of Environment, Forest and Climate Change. For Part A wastes, prior informed consent from the exporting country is also required.
For Part D of Schedule III, the rules provide a different procedure: the importer does not require permission from the ministry under Rule 13 but must furnish the required information in Form 6 to Customs along with the applicable documents.
Customs Verification
Before clearance of applicable consignments, Customs authorities verify the prescribed documents. Port and Customs authorities may also verify the movement documentation and, where applicable, the waste analysis report.
This makes accurate documentation and correct classification of the imported scrap especially important.
Annual Compliance After Import
Importers are required to maintain records of hazardous and other wastes imported by them in Form 3 and make those records available for inspection.
The rules also require the importer to submit an annual return in Form 4 to the concerned State Pollution Control Board on or before 30 June following the financial year to which the return relates.
Our Scrap Import Compliance Services
At NOZIX, we assist businesses with the documentation and environmental compliance requirements associated with scrap imports.
Our Assistance Includes:
- Scrap category and requirement assessment
- Environmental compliance guidance
- Documentation checklist preparation
- Form 6 documentation assistance
- PSIC documentation guidance
- Chemical analysis report documentation
- SPCB consent and authorization assistance
- Trader/actual-user requirement guidance
- Import compliance documentation support
- Customs documentation coordination support
- Annual return compliance assistance
Why Choose NOZIX?
- Requirement-based compliance assistance
- Documentation-focused support
- Environmental regulatory guidance
- Actual user and trader compliance assistance
- Professional application support
- End-to-end coordination
Import Scrap with Proper Compliance
Scrap import should be planned only after checking the exact nature, classification, and regulatory status of the material. The applicable requirements can differ depending on the type of scrap and whether it falls under hazardous waste or other waste categories.
NOZIX helps importers understand the applicable requirements and prepare the necessary compliance documentation for their scrap import activity.
Get Professional Scrap Import Assistance
Planning to import metal scrap, aluminum scrap, copper scrap, iron & steel scrap, or other regulated scrap into India?
Contact NOZIX for professional scrap import documentation and environmental compliance assistance.
Frequently asked questions
How long does Hazardous Waste Import Authorization take?
We confirm the timeline after reviewing your documents. It depends on the department and how quickly documents are shared.
Can I apply for Hazardous Waste Import Authorization online?
Yes. The entire process is online. A physical visit is only needed if the authority requires an inspection, and we prepare you for it.
What if my application is rejected?
We fix the issues raised by the department and refile at no extra professional fee.
Is the government fee included in your price?
Our price is the professional fee. Government fees are charged at actual cost and shown separately before you pay.