On April 25, at the 2024 SMM (19th) Aluminum Conference and the First Aluminum Industry Expo hosted by SMM, Zhong Bujiang, former second-level director of the Science and Technology Department of Guangzhou Customs, interpreted the inspection and supervision of recycled aluminum by the customs.
Background
On November 24, 2020, the Ministry of Ecology and Environment, the Ministry of Commerce, the National Development and Reform Commission and the General Administration of Customs jointly issued Announcement No. 53 of 2020 on Matters Concerning the Comprehensive Ban on the Import of Solid Waste, which came into effect on January 1, 2021. At this point, the solid waste import license has been completely cancelled, and the import of any form of solid waste will be prohibited.
China is the world's main producer of industrial products, and the implementation of the above measures will seriously affect the development of domestic industries and lose product competitiveness. How to find a balance between strictly prohibiting the import of solid waste and expanding the import of raw materials is the way that customs and industry departments need to find.
At the beginning of 2019, with the vigorous promotion of industry associations and the support of the Ministry of Ecology and Environment and the General Administration of Customs, three standards for recycled non-ferrous metals were compiled.
On October 16, 2020, the Ministry of Ecology and Environment, the General Administration of Customs, the Ministry of Commerce, and the Ministry of Industry and Information Technology jointly issued Announcement No. 43 of 2020 "Announcement on Matters Concerning the Import Administration of Recycled Brass Raw Materials, Recycled Copper Raw Materials and Recycled Cast Aluminum Alloy Raw Materials". Three standards are involved: "Recycled Brass Raw Materials" (GB/T 38470-2019), "Recycled Copper Raw Materials" (GB/T 38471-2019), "Recycled Cast Aluminum Alloy Raw Materials" (GB/T 38472-2019)
Subsequently, the Ministry of Ecology and Environment, the National Development and Reform Commission, the General Administration of Customs, the Ministry of Commerce, and the Ministry of Industry and Information Technology jointly issued Announcement No. 78 of 2020 "Announcement on Matters Concerning the Import Management of Recycled Steel Raw Materials". The import of recycled steel that meets the standard of "Recycled Steel Raw Materials" (GB/T 39733-2020) is allowed. At this point, four recycled metals (recycled steel, recycled brass, recycled copper raw materials, recycled cast aluminum alloy raw materials) can be legally imported. It is worth noting that the four major secondary metal import issues were jointly issued by multiple ministries and commissions, indicating that this is a serious and important event.
March 14, 2022. In Announcement No. 25 of 2022 of the General Administration of Customs (Announcement on Issuing 86 Industry Standards including the Inspection Regulations for Imported Recycled Copper Raw Materials and Abolishing 3 Industry Standards), the Inspection Regulations for Imported Recycled Copper Raw Materials (SN/T 5416-2022), the Inspection Regulations for Imported Recycled Brass Raw Materials (SN/T 5417-2022), and the Inspection Regulations for Imported Recycled Cast Aluminum Alloys (SN/T 5418-2022) were issued (by Shanghai, Guangzhou, Ningbo Customs formulated) and other three inspection regulations for recycled metal raw materials, which will be officially implemented from October 1, 2022. This is the current operating procedure formulated by the customs in accordance with the above three national standards.
Explanation of the relevant facts
From the perspective of import ports, the proportion of recycled aluminum imported from Guangdong ports in the early part of 2021 will be about 90%, and the next will be less than 70%, Zhejiang ports (Ningbo) will account for more than 17%, and Guangxi ports (Nanning Customs) will account for more than 3.8%.
In terms of origin, Malaysia is the first with 23%, Japan with 12%, and the United States with 9%. This does not match the actual information.
The difference between the inspection procedures and the relevant national standards
(1) The terms and definitions of unpacking inspection, unpacking inspection, and landing inspection have been added, and the overall requirements such as inspection location, safety protection, facilities and equipment, shipment requirements, instruction requirements, document requirements, and record requirements have been added.
(2) More detailed and specific requirements for sampling.
(3) Clarify the on-site inspection and laboratory testing items
(4) The content of on-site investigation of solid waste has been added
(5) Specifically and clearly address the results
Interpretation of the main content of the inspection procedure
Technical provisions of "Recycled Casting Aluminum Alloy Raw Materials" (GB/T 38472-2019).
On-site inspection content:
1. Radiological testing
2. Inspection of explosives, airtight containers and pressure vessels
3. Appearance quality inspection
4. Dimensional specification inspection
5. Inclusion content inspection
6. Inspection of aluminum and aluminum alloy content and total metal content
7. On-site chemical composition inspection
8. On-site investigation of solid waste
Appearance quality inspection requirements
Check whether the apparent characteristics (appearance quality) meet the requirements:
1. Take a sample of one sampling unit from it for visual inspection of appearance quality. It is advisable to lay the specimen flat on a clean flat surface for inspection. Castings and aluminum blocks should not be mixed with obvious inclusions. The surface of the recycled aluminum ingot should be neat and tidy, and there should be no serious flash or pores.
2. After inspection, if the appearance quality does not meet the requirements of 5.3.1, double the number of samples shall be taken from the inspection batch for repeated inspection. If all the repeated inspection results are qualified, it will be judged to be qualified for appearance quality inspection, otherwise it will be judged to be unqualified for appearance quality inspection.
Dimensional Specification Inspection Requirements (Aluminum Block)
Check whether the size specification meets the requirements:
1. Samples of one sampling unit are taken for visual inspection of size and specifications. It is advisable to lay the specimen flat on a clean flat surface for inspection. When it is suspected that the visual inspection results of the dimensional specifications do not meet the requirements, sampling shall be carried out in accordance with the provisions of 6.3. For castings and recycled aluminum ingots, the dimensions are measured with gages of corresponding accuracy.
2. After inspection, if the size and specifications do not meet the requirements of Table C.1 in Appendix C of the "Inspection Regulations for Imported Recycled Cast Aluminum Alloy Raw Materials", double the number of samples shall be taken from the inspection batch for repeated inspection. If the repeated inspection results are all qualified, it will be judged to be qualified for the size specification inspection, otherwise it will be judged to be unqualified for the size specification inspection.
Inclusion content inspection requirements
Check whether the inclusion content meets the requirements:
1. Take a sample from one sampling unit and estimate the mass proportion of inclusions in the sample by visually. It is advisable to lay the sample flat on a clean plane for inspection, and the goods that are not easy to observe should be separated by mechanical means. The mass fraction of inclusions (including wood, paper, plastics, rubber, glass, stones, textiles, powders with a particle size of no more than 2 mm) in raw materials should not be more than 0.5%, and the mass fraction of powders (dust, sludge, oil stains, crystalline salts, fiber powder, etc.) with a particle size of no more than 2 mm should be less than 0.1%.
2. When it is suspected that the visual inspection results of the inclusion content do not meet the requirements, sampling shall be carried out in accordance with the provisions of 6.3, that is, all samples are mixed together, spread on a clean plane, and the raw materials on the plane are roughly divided into four parts along the central symmetry line, and a sample is drawn from them. Sorting and weighing
3. After inspection, if the inclusion content does not meet the requirements of 5.5.1, double the number of samples should be taken from the test batch (when the sample volume is insufficient, double the number of samples shall be taken from the test batch in accordance with the provisions of 6.2) for repeated inspection. If the repeated inspection results are all qualified, it is judged that the inclusion content inspection is qualified, otherwise it is judged that the inclusion content inspection is unqualified.
Aluminum and aluminum alloy content, total metal content inspection requirements
Check whether the content of aluminum, aluminum alloy and total metal meet the requirements:
1. Take a sample of 1 sampling unit and visually estimate the mass proportion of aluminum materials or metal materials that can be picked out in the sample.
2. When it is suspected that the visual inspection results of the inclusion content do not meet the requirements, sampling shall be carried out in accordance with the provisions of 6.3, and sorting and weighing shall be carried out.
3. After inspection, if the aluminum alloy content or total metal content does not meet the requirements of Table C.2 in Appendix C, double the number of samples shall be taken from the sample of the test batch (when the sample amount is insufficient, double the number of samples shall be taken from the test batch in accordance with the provisions of 6.2) for repeated inspection. If the repeated inspection results are all qualified, it is judged that the aluminum and aluminum alloy content or the total metal content are qualified, otherwise it is judged that the aluminum and aluminum alloy content or the total metal content are unqualified.
On-site chemical composition testing requirements
A portable spectrometer was used to test the chemical composition in accordance with the standard GB/T 38472-2019 Appendix E.
Operational Requirements:
Sampling is carried out in accordance with the provisions of 6.2, and at least 1 casting or 1 recycled aluminium ingot or 2 aluminium blocks are drawn from the sample of each sampling unit. If the chemical composition does not meet the requirements of Table C.3 in Appendix C after on-site chemical composition inspection, samples should be taken according to 6.5 and sent to the laboratory for testing, that is, at least 20 kg of samples taken from 6.2 should be sent to the laboratory for testing of volatile content, metal recovery and chemical composition. If the specimen is too large, it can be crushed. For recycled aluminum ingots that need to be tested for fracture tissue, at least 3 complete pieces are extracted, and each piece is used as 1 sample.
sampling
The samples taken should be representative, and each inspection batch should be 20 tons (bundles, bags) or 1 container as one sampling unit, and the part less than one sampling unit should be counted as one sampling unit.
During the on-site inspection, except for radioactive contamination, the number of sampling units taken from each inspection batch is at least 10% of the total number of sampling units, and at least one sampling unit is extracted. For casting raw materials, at least 1 ton is taken from each sampling unit as 1 sample, and at least 4 castings are taken from each inspection batch, for recycled aluminum ingot raw materials, at least 1 bundle is taken from each sampling unit as 1 sample, and at least 2 bundles of recycled aluminum ingots are drawn from each inspection batch, and for aluminum block raw materials, at least 1 ton or 1 bag is taken from each sampling unit as 1 sample, and at least 2 samples are taken per inspection batch.
Result disposition
If the inspection items implemented in accordance with the requirements of the control instruction are qualified, the raw materials of the inspection batch shall be judged to be qualified and released.
If the quality certificate is not attached, and the quality certificate provided does not meet the requirements of 4.6, technical rectification is allowed, and the rectification is qualified, and the rectification is not qualified, and the return is ordered.
If any of the inspection results of radioactive pollutants, flammable materials, closed containers, pressure vessels, appearance quality, size specifications, inclusion content, aluminum and aluminum alloy content, total metal content, volatile content, metal recovery rate, chemical composition and fracture structure are unqualified, the inspection batch of goods shall be judged to be unqualified and disposed of in the following ways:
a) If any of the test results of radioactive pollutants and flammable materials are unqualified, they shall be disposed of or returned in accordance with relevant regulations.
b) If the size and specification inspection is unqualified, it is allowed to re-sort, re-declare, and dispose of it separately;
c) Closed containers, pressure vessels, appearance quality, inclusion content, aluminum and aluminum alloy content, total metal content, volatile content, metal recovery rate, chemical composition and fracture organization inspection unqualified, in accordance with the relevant provisions of the implementation of return disposal.
Where solid waste is identified as solid waste by the identity of the identification institution, it shall be disposed of in accordance with the relevant provisions of solid waste in accordance with law.