Waste Recovery and Import/Export Procedures

user Mahmoud Elsayed calender 26 Jun 2024 views 192 Views

Egypt’s efforts to improve its waste management practices received a major boost with the passing of Law 202 of Year 2020.  Articles 3 and 4 of the aforementioned law establishes an authority called “Waste Management Regulatory Authority” (WMRA), this agency aims to “organize, follow up, monitor, evaluate and develop everything related to integrated waste management activities, attract and encourage investments in the field of integrated waste management activities to ensure the achievement of sustainable development, and follow up on the implementation of the necessary plans to regulate waste management”.

The Basel Convention on the Control of Trans boundary Movements of Hazardous Wastes is an international agreement that aims to reduce the movements of hazardous waste between nations, and prevent the transfer of hazardous waste from developed to less developed countries. Entered into force in 1992, the Basel Convention is the most comprehensive global environmental agreement on hazardous and other wastes. It has near universal membership, with 188 countries as Parties as of 2024.  Article 4 conveys the obligations of the parties including their duty to ensure the management of hazardous and non-hazardous wastes and preventing the export of such wastes to nations that have banned their import.  Without the proper written notification and consent of the importing and transit, states there can be no movement of wastes as per Article 6.

The Basel Convention has been instrumental in raising global awareness about the dangers of hazardous waste movements and promoting environmentally sound waste management practices worldwide. Its continued implementation and evolution remains crucial in addressing the growing challenge of waste, especially in an increasingly globalized economy.

A key focus of Law 202 of 2020 is regulating the import and recovery of waste materials. As per the law, companies wishing to import waste into Egypt must first obtain a permit from the WMRA. This permitting process requires submitting an electronic application form along with detailed information on the waste composition, planned recovery or disposal methods, and proof that the receiving facility is properly registered and authorized. The required documents for an import permit are as following as per the internal regulations of the WMRA:

  • A copy of the registration card in the register of exporters/importers
  • A certificate of examination and analysis of the shipment of waste issued by an internationally accredited laboratory (recognized by the General Organization for Export and Import Control) from Annex I of the Basel Convention at a level that gives it one of the hazardous characteristics contained in Annex III of the same agreement in terms of (toxicity, flammability, reactivity/ activity, corrosion) at levels exceeding permissible or in a concentration sufficient to exhibit one of these characteristics
  • A letter from the Industrial Development Authority – or any other authority issuing an operating license – that the item to be imported is considered a production requirement for the company, and the annual quantity is determined
  • A copy of the contract or attribution order between the importing company and the beneficiary facility
  • Environmental approval of the beneficiary facility
  • Beneficiary facility license
  • Import invoice
  • Data validation
  • Notification document
  • Movement document

As per the law, companies wishing to export waste out of Egypt must first obtain a permit from the WMRA. The necessary documents to extract an export permit from the WMRA is as follows as per the internal regulations are:

  • A copy of the registration card in the register of exporters/importers
  • Notification document
  • Movement document
  • A copy of the contract between the exporting and importing company
  • Result of waste analysis from an accredited laboratory
  • financial security
  • Importing company license
  • Description of the technology used
  • Purchase invoices/contracts
  • Data validation
  • A copy of the licenses of the carriers inside Egypt
  • A copy of the environmental approvals of the carriers inside Egypt

The WMRA charges a fee of 1% of the total value of the yearly import quantity as part of the permitting process. These funds are used to support the agency’s waste management oversight and enforcement activities. Once a permit is granted, importers must ensure the waste is transported and handled according to strict Egyptian regulations. This includes proper labeling, packaging, and manifesting to track the waste from its point of origin to the final recovery or disposal site within Egypt.

Challenges remain, however, as Egypt works to strengthen its waste management capabilities and crack down on illegal dumping and trans boundary waste trafficking. Continued investment, enforcement, and collaboration with international partners will be crucial as the country strives to build a more sustainable and circular waste management system under the framework established by Law 202 of Year 2020.