November 11, 2015

Proposed Changes to Import/Export Regulations

On October 19, 2015, EPA proposed significant changes to the regulations covering the import and export of hazardous waste. [80 FR 63284] This proposal would impact any person (including a transporter) who imports or exports hazardous waste for recycling or disposal, including universal waste, spent lead-acid batteries, industrial ethanol, secondary material shipped for precious metal recovery, and cathode ray tubes. The agency’s goal for these proposed changes is to improve the oversight and efficiency of transboundary shipments of hazardous wastes in the following ways:

Consolidating all hazardous waste import/export regulations that are currently in Subparts E, F, and H of Part 262 into Subpart H. A primary purpose of this reorganization is to make existing U.S. import- and export-related requirements consistent with the current requirements for shipments between members of the Organization for Economic Cooperation and Development (OECD).
Mandating electronic submission of notices, reports, receipts, and consent notifications required for transboundary shipments of hazardous waste. This will allow for 1) improved and timelier communications between U.S. Customs and other countries involved in the exchange, and 2) better monitoring and control by EPA of imported/exported hazardous waste.

You can find more details on this proposed rule at EPA’s import/export webpage. Comments on this proposed rule will be accepted until December 18, 2015 under Docket No. EPA-HQ-RCRA-2015-0147.

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This document addresses issues of a general nature related to the federal RCRA regulations. Persons evaluating specific circumstances dealing with the RCRA regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.