Exactly which recycled plastic pellets can be imported directly?

Recently about the import of recycled plastic pellets, Guangdong, Qingdao, Dalian and other port stories frequently. In the end, how to determine the different states of recycled plastic pellets is solid waste or general merchandise, many friends of the relevant rules are not very clear, the need to clear the source, the author gathered the views of various experts, the relevant information is summarized as follows: 
1, what is the "three unified"? 
General Administration of Customs and Excise Department of Supervision on May 30, 2014 sent a special urgent document to the Guangdong Branch and the Customs directly under the issue of black recycled pellets imported clearly as follows: 
Processed from waste plastics in the primary form of recycled plastic pellets, if the same batch of imported goods of the same color, particle size and shape, consistent packaging, and meet the relevant norms and standards for plastic materials or products, can not be regulated in accordance with solid waste. 
The regulatory process found in the recycled plastic pellets suspected of solid waste, solid waste identification agencies should be identified by the identification of the properties of goods, in accordance with the results of the implementation of supervision. 
Note: The three unified, can be carried out in accordance with a package, can not be carried out in accordance with a container. 
2, the industry response focused on the issue 
1. Color difference, mixed color (as follows): 
 
The same batch of waste plastic granulation, due to various reasons the color can not do exactly the same, more or less will appear color difference, especially the light color. 
According to the three unity, this material does not meet the "three unity" requirements, suspected of solid waste waste, the customs will require the identification agency to send identification, some identification agencies will be because of color differences, determined as solid waste, the customs will require the return of goods. 
Flower film pelletizing greater color difference (as shown in the following chart): 
 
 
The following is the composite film pelletizing (as shown below): 
 
2. Shape and size differences (as shown below): 
 
The pellets with different cutting methods of water link and underwater cutting are fed directly into the storage compartment at the time of production, and then packaged as such. 
According to the "three unified", this material does not meet the "three unified" requirements, belongs to the suspected solid waste waste, the customs will request to send identification agencies to identify, some identification agencies will be different because of the shape and size of the particles, may be judged as solid waste, customs Will be in accordance with the identification conclusions, the request for the return of goods. 
3, is the Customs determine the properties of imported goods? 
People mistakenly believe that the Customs think your goods are solid waste is solid waste, on the return, a big mistake, customs supervision is only based on the "three unified" requirements of the initial judgment, beyond the "three unified" range of goods, the Customs can only determine: suspected solid waste Waste, is not solid waste, can only be sent to identification agencies to identify. 
Is the identification agency to issue an appraisal report to determine the properties of the goods. 
Identification report style 
 
and psychiatric identification report works as well, the difference is that the identification of mental illness can be exempt from prosecution, identified as solid waste waste, to be returned. 
Once sent to the identification agency, the short time of 1 month, the long 2 months, importing enterprises suffering, so not long ago to solve this problem, the state added a lot of solid waste identification agencies. 
4, identification agencies in accordance with what to identify solid waste or common goods? 
Solid Waste Identification Standards General Rules (GB34330-2017) is now the only industry standard for solid waste identification. 
General rule 5.2 "The products produced from solid waste shall not be managed as solid waste and shall be managed in accordance with the corresponding products if they meet the following conditions", "meet the national, local or industry standards for the quality of the products produced from the substituted raw materials", "have a stable and reasonable market demand", and "have a stable and reasonable market demand", "there is a stable and reasonable market demand". 
General rule 6.1 "The following substances are not managed as solid waste:" 
"Any substance that can be used for its original purpose without repair and processing, or at the point of generation after repair and processing to meet national, locally established or industry-accepted product quality standards and used for its original purpose." 
According to this general rule, basically the two issues of appeal should be judged as ordinary goods. 
But some agencies will use three uniform as the basis for identification into solid waste, the problem of inconsistent understanding, is currently there are color differences, size differences in the import of particles, is the key to identify the problem. 
There is a April 1, 2006 came into force, just repealed the standard "solid waste identification guidelines" (for trial implementation), which provides a number of specific methods. Introduced as follows: 
Judgment based on characteristics and impacts Evaluating whether a substance, article or material (hereinafter referred to as substance) is a solid waste requires consideration of the following factors: 
(1) General considerations. These include: whether the substance is intentionally produced, whether it is manufactured to meet market demand, whether it has negative economic value, and whether it is part of a normal commercial cycle or chain of use. 
(2) Characteristics. This includes: whether the substance is produced with quality control and whether it meets nationally or internationally recognized norms/standards. 
(3) Environmental impact. Including: whether the use of the substance is environmentally sound compared to the primary product; whether the use of the substance increases the risk to human health or the environment compared to the corresponding raw material in the production process; whether it poses a greater risk to human health or the environment; whether the substance contains environmentally harmful components that are not normally found in the raw material or product being replaced These components are not found in the recycling process can not be effectively used or reused in the recycling process. 
(4) Use and fate. Including: whether the substance requires further processing before use; whether it can be directly applied in production/commercial; whether it requires only minor repair before it can be put into use; whether it is still suitable for its original purpose; whether it can be used as a substitute for other uses; whether it is actually applied in the production process; whether it has a fixed use; whether it can be used in its current form or in a form that is not processed by the operations listed in Table I Can be used; can only be used after the operational methods listed in Table I. 
To evaluate whether a substance is a solid waste, all of the above factors need to be taken into account. 
Depending on the subject of the evaluation, the factors to be considered will be different. The following flow chart can be used as a reference for solid waste and non-solid waste identification, but in the specific application, the identification should be based on the characteristics and impact of the substance. 
  
5、Disagree with the identification results given by the identification agency, is there another way? 
This is a purely technical issue. There is no information collected that can no longer be sought from other identification agencies. 
The author is seeking the final answer to the question, kneeling to be able to answer the gods to reply 
Generally are directly commissioned by the Customs identification agencies to identify, not who the shipper wants to find. 
6, different identification agencies on the same goods may come to different conclusions how to do? 
This problem is difficult to do, the state has "solid waste identification standards General" (GB34330-2017), for recycled plastic pellets lack of a targeted standard.