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Hazards Of Importing/Exporting Hazardous Waste
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Hazards Of Importing/Exporting Hazardous Waste

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Auckland based Technical Compliance Consultant Ltd (NZ) advises clients on how to import or export hazardous waste from or into the country. To begin with, you cannot import or export hazardous waste without a permit being issued by the EPA. However, the following guidelines may help you to proceed further in the matter.

 

Importing Hazardous Waste into New Zealand

If you intend to import hazardous waste into New Zealand as an importer, you need to submit an application before the EPA (Environmental Protection Agency) for issuing an Import Permit. Simultaneously, the exporter (country of origin) has to provide the CA (Competent Authority) in the exporting country with relevant forms and information in regard to:

  • Reason the waste needs to be exported from the country of origin
  • Copies of environmental and liability insurance
  • Contractual arrangements with the disposal/recovery facility receiving the waste.

However, the EPA may issue the Import Permit after being fully satisfied with the above information as well as checking the reasons for importing such hazardous waste in the country.

 

Meanwhile, you may submit your hazardous waste Import Application by:

  • Sending an email to importexport@epa.govt.nz with ‘Hazardous Waste Import Application’ as the subject matter
  • Posting to the Environmental Protection Authority, Private Bag 63002, Wellington 6140 New Zealand.

 

Exporting Hazardous Waste from New Zealand

If you intend to export hazardous waste from New Zealand as an exporter, you also need to submit an application before the EPA to issue an export permit. However, you need to file the following documents along with your application form for the consideration of the EPA before issuing the permit

  • Statement providing reasons for the export, vide Regulation 11 of the Order
  • Completed Notification Form
  • Copy of the Contract(s) between the exporter and the disposal/recovery facility
  • Copy of the Insurance Policy/Policies as evidence of financial coverage
  • Documentation about the disposal/recovery facility’s waste management practice

You are also required to determine the hazardous waste as defined by the Basel Convention, Annex I, II and VII and is specified under Schedule 3 of the Imports and Exports (Restrictions) Prohibition Order (#2) 2004 (the Order). Common examples of hazardous waste include:

  • Clinical and pharmaceutical wastes
  • Wastes from the manufacture of wood preserving chemicals and organic solvents
  • Waste hydrocarbons and wastes containing certain polychlorinated/polybrominated biphenyls
  • Wastes from the production of inks, dyes, paints and varnish
  • Wastes from photographic chemicals and processing materials

However, if the EPA authorities feel satisfied with your submissions, you may be provided with the required export permit without which the port authorities will not allow you to export any hazardous waste from the country.

 

Exporting e-waste from New Zealand

Incidentally, the EPA or the Environmental Protection Agency in New Zealand maintains that all e-waste be declared hazardous waste, unless proven otherwise. So, prior to exporting e-waste from the country, the exporter needs to verify if the waste is hazardous, vide the formula/criteria for hazardous waste as defined in the Basel Convention as well as the Schedule 3 of the NZ Imports and Exports (Restrictions) Prohibition Order (#2) 2004 (www.legislation.govt.nz) .

 

It is assumed that assorted e-waste will contain some wastes that are defined as hazardous under the Order. Exporters should, therefore, obtain Export Permit for all e-waste exports, unless proved as non-hazardous waste. Also, the EPA will not issue Export Permit for hazardous waste until specific consent has been received from the importing country in regard to the import. In order to make the deal more foolproof, exporters may go through the rules controlling the import  of hazardous waste for the country are exporting to.

 

The draft Basel e-waste guidelines caution exporters to include evidence to demonstrate their e-waste is not hazardous when exporting it as non-hazardous waste. Exporters should also include evidence to show the proposed treatment of the waste is environmentally safe and sound.

 

Warning: Exporters need to be aware of the condition that in case of their sending e-waste as non-hazardous but has subsequently been identified as hazardous, the whole shipment may be sent back to them, along with damages and fines. They are also liable for prosecution under the Imports and exports (Restriction) Act 1988 NZ.

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