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Electronic Filing Required for Some EPA-Regulated Exports

Tuesday, December 26, 2017
Sandler, Travis & Rosenberg Trade Report

According to U.S. Customs and Border Protection, starting Dec. 31, 2017, exporters of RCRA (Resource Conservation and Recovery Act) manifested hazardous waste for recycling or disposal, spent lead-acid batteries being shipped for recovery of lead, and universal waste being shipped for recycling or disposal must comply with filing Environmental Protection Agency-specific information as part of their electronic export information filing in the Automated Export System. Exporters of whole or broken cathode ray tubes being shipped for recycling must similarly comply with filing EPA-specific information in AES starting on that date. Previously exporters had the option of using this new electronic process or the old paper process.

EPA-specific information that must be filed in AES includes the EPA license required indicator, EPA consent number, RCRA hazardous waste manifest tracking number, EPA net quantity of measure, and EPA net quantity.

CBP notes that the EPA’s acknowledgement of consent meets the definition of an export license under Census Bureau regulations and that as a result RCRA exporters are already required to file the EEI in AES for each export shipment regardless of shipment value or destination country.

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