06.10.2015

Problem with the scrap metal exporting

Complainee: Ministry of Economic Development and Trade of Ukraine (MoEDT), Ministry of Ecology and Natural Resources (MoENR)
Complaint in Brief: On 25 May 2015, Association of exporters of scrap metal addressed the BOC. The Complainant stated that the existing scheme of quotas allocation for the scrap metal export was not transparent, lead to numerous violations of active law and abuse of power by state officials. Still, this approach to quotas allocation was introduced by the MoEDT several years ago and has caused numerous complaints on behalf of market players since then. Additional obstacle is requirement to receive the Certificate from the MoENR that exporting scrap metal complies with so-called “Green List” of wastes. Such Certificate must be received each time. The term of issuance of such certificate is 30 days, while the permission for export of the scrap metal issued by the MoEDT is also limited to 30 days.   
Actions taken: BOC investigated the matter thoroughly, studied the relevant legislative base, held a number of meetings with state officials, international experts and market players and found out the following:
Result achieved: On 27 August 2015, BOC submitted an official letter to the Ministry of Economic Development and Trade with recommendations on improving existing procedures and regulations. Based on these recommendations, the Ministry of Environment and Natural Resources reduced the term from 30 to 10 days. Recommendations are subject to further monitoring and follow up.   

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