The law on environmental protection does not allow the extension of the certificate of eligibility for environmental protection in importing scrap as raw production materials. If the shipment of scrap arrives at port when the certification expires, it will not be inspected and cleared according to regulations.

Through the receiving and responding system to businesses’ recommendations, representatives of companies operating in the recycled plastic industry in the North and the South have proposed a number of solutions to free plastic scrap goods currently in port, avoiding the situation of stock situation continues to exist in the future.

Accordingly, the representatives of companies proposed the authorities to put the information of licensed companies on the National Portal to the Customs authorities to catch up promptly, only receive the declaration of procedures ofimports for companies that are listed on the National Portal.

Permitting companies that have a License issued by the Department of Natural Resources and Environment to be extended for the last 5 months of 2018 to receive goods in stock for the purpose of clearing inventories, creating favorable conditions for enterprises with raw materials. manufacturing.

Supporting businesses in setting up specialized industrial zones for recycling plastic scraps in order to facilitate the management and promotion of the development of Vietnam's plastic industry.

Business representatives also proposed to expand QCVN for imported plastic scrap, including all recyclable plastics without harmful impurities in the list of scrap plastic allowed to import or at least have more tubes, plates, trays, packaging films, toys, pallets, plastic safes ... in order to take advantage of raw materials and avoid future port inventory when the consignment of goods mixed with these plastics (lot of shipments are still in stock for this reason).

Concentrating on human resources, pushing the licensing of importing new scrap plastic for businesses.

Change of management method: Using the solution "easy input, tighten the output" as Taiwan, Korea, Hong Kong and Malaysia ... are doing, which means creating favorable conditions for businesses. It imports most types of recyclable plastic but strictly manages its output, which is waste water and emissions from recycling plants.

Regarding this issue, The Ministry of Natural Resources and Environment has the following opinions:

From July 2018, the Ministry of Natural Resources and Environment has issued a document directing the functional units under the Ministry, the Department of Natural Resources and Environment to coordinate with the relevant units to publicize the results of issuing the full Certification. conditions for environmental protection in scrap import / Certificate of eligibility for scrap import (Certification) on the National Single Window Portal and electronic portal of the Ministry of Natural Resources and Environment.

By the end of October 5, 2018, the Ministry of Natural Resources and Environment updated 309 Certificates of businesses importing scrap as raw production materials.

The receipt of declaration for carrying out the procedures for importing scrap must comply with the law on environmental protection, customs regulations and other relevant regulations.

No extension of scrap import confirmation

The law on environmental protection does not allow the extension of the certificate of eligibility for environmental protection in importing scrap as raw production materials.

According to Circular No. 41/2015 / TT-BTNMT dated September 9, 2015 of the Ministry of Natural Resources and Environment on environmental protection in importing scrap as raw production materials and the regulations of the customs authorities, The scrap importing enterprise must submit to the customs’ office a valid scrap import certification of the organization or individual entrusting the import of scrap (certified copy) for inspection and customs clearance.

If the Certification issued by the Department of Natural Resources and Environment or issued by the Ministry of Natural Resources and Environment expires, the shipment of scrap arriving at port of entry when the Certification expires will not be inspected customs clearance according to regulations.

In case the Certification of scrap importing enterprises expires, the scrap importing enterprises urgently submit dossiers of application for re-grant of Certification according to the provisions of Circular 41/2015 / TT-BTNMT and Circular 03/2018 / TT-BTNMT dated August 14, 2018 of the Ministry of Natural Resources and Environment on amending and abolishing a number of regulations on administrative procedures related to specialized inspection within their functional scope State management of the Ministry of Natural Resources and Environment.

Ready supporting the establishment of plastic recycling industry

Regarding the proposal of assisting enterprises in setting up industrial parks specialized in recycling scrap plastic in order to facilitate the management and promotion of the development of Vietnam's plastic industry, the Ministry of Natural Resources and Environment supports and alreadyassiststudy and propose the establishment of recycling industrial zones to improve economic efficiency and environmental management.

However, the establishment of plastic recycling industrial zones must meet the following objectives: Recycle plastic waste generated in the country; discourage import of plastic scrap from abroad into Vietnam for recycling.

At the same time, the deployment of plastic recycling industrial zones must comply with the provisions of law on investment, construction, environmental protection and the orientation of the National Strategy on integrated management of solid waste, general socio-economic development planning of the country and locality.

New QCVN has been issued for imported plastic scrap

Decision 73/2014 / QD-TTg dated December 19, 2014 of the Government’s  Prime Minister stipulating the list of scraps permitted to be imported from foreign countries as production materials specifying 07 plastic scrap codes that are allowed to be imported. .

On the basis of implementing Decision 73/2014 / QD-TTg; Directive 27 / CT-TTg and opinions of Ministries, Associations and related units, the Ministry of Natural Resources and Environment, in coordination with the Ministry of Science and Technology, consider and promulgate Circular 08/2018 / TT-BTNMT dated September 14, 2018, including QCVN 32: 2018 / BTNMT - National technical regulation on environment for imported plastic scrap as raw production materials (replacing QCVN 32: 2010 / BTNMT).

QCVN 32: 2018 / BTNMT has specified the types of resins allowed to be imported under the list in Decision 73/2014 / QD-TTg, including:

Plastics are removed from manufacturing processes that have not been used; plastic (PET) packaging for used mineral water, purified water; plastic (PET) packaging for used carbonated carbonated drinks and complete removal of internal liquids; used plastic in one of the following forms: blocks, lumps, bars, wires, strips, ribbons, films, splints, trays, plates, sheets, pallets and plastic safes; Jumbo bags have been cut into strips, sheets or ribbons.

Other resins that are not subjectto mentioned resins above must be chopped, cut into pieces and cleaned to remove impurities (the dimension of each piece of debris shall not exceed 10 cm. The percentage of fragments that is larger than 10 cm does not exceed 5% of the volume of imported plastic scrap cargo.

Therefore, it is recommended that enterprises importing scrap should carefully study the provisions of QCVN 32: 2018 / BTNMT to ensure that imported scrap must meet the national technical regulation on environment for plastic scrapimported as production materials.

Tightly control the inlet and outlet of scrap plastic

Regarding the proposal of focusing on manpower and speeding up the licensing of importing new scrap plastic to enterprises, the Ministry of Natural Resources and Environment is currently carrying out activities to grant certificates of eligibility for environmental protection. in importing scrap as raw production materials in accordance with the provisions of Decree 38/2015 / ND-CP, Circular 41/2015 / TT-BTNMT, Circular 03/2018 / TT-BTNMT and Directive 27 / CT-TTg dated September 17, 2018 of the Government’s Prime Minister on a number of urgent measures to strengthen the management of the import and use of imported scrap as raw materials for production.

Following the direction of the Government’s Prime Minister to strengthen the management of import and use of imported scrap as raw production materials, the Ministry of Natural Resources and Environment shall only consider granting and re-granting certificates of satisfaction of conditions. conditions for environmental protection in importing scrap as raw production materials, for units importing scrap fully satisfying the regulations on environmental protection; direct use of scrap as raw production materials.

Regarding the proposal to change the management method: Using the solution "easy to input, tighten the output" as Taiwan, Korea, Hong Kong, Malaysia ... is doing, which means creating conditions for businesses importing most types of recyclable plastic but strict management of waste water and emissions from recycling plants.

In recent years, in addition to recycling waste and utilizing domestic scrap as raw materials for production, to meet the raw material needs of some manufacturing industries, the State has allowed the import of scrap. with strict and specific conditions prescribed in the Law on Environmental Protection; Decree 38/2015 / ND-CP dated 24/4/2015 of the Government on waste and scrap management; Decision 73/2014 / QD-TTg dated 19/12/2014 of the Government’s Prime Minister stipulating the list of scrap permitted to be imported from abroad as raw production materials; Circular 41/2015 / TT-BTNMT; Circular 03/2018 / TT-BTNMT.

In the face of the current reality, the import and use of imported scrap if not managed and strictly controlled it will be taken advantage to bring waste into our country, causing environmental pollution. A number of countries (the world's largest scrap import markets such as China, Malaysia, and South Korea) have restricted or even banned the import of some types of scrap, resulting in the movement of large quantities of imported scrap into countries in Southeast Asia, including Vietnam, has led to large backlog of scrap imports at Vietnamese seaports.

Therefore, to strictly manage imported scrap must strictly comply with the provisions of the law on environmental protection and other relevant regulations (strict management of both input and output).

During the operation of the manufacturer using imported scrap, the Ministry of Natural Resources and Environment has and will continue to coordinate with relevant units to organize inspection and examination activities to protect environmental protection in accordance with the current law on inspection and examination; In case of detecting a production establishment violating the environmental protection regulations, the sanction shall comply with the provisions of Decree 155/2016 / ND-CP of the Government stipulating the sanctioning of administrative violations in the field of environmental protection.