n° 171 – March 2021

The most significant occurrence since our previous Mirror report was the issuance in February of “Guidelines for importation and inspection of metal scrap” by the Malaysian-based agency SIRIM QAS International Sdn. Bhd., which may indicate increased restrictions on both ferrous and non-ferrous imports into the country. According to the guidelines, the Malaysian Ministry of International Trade and Industry (MITI) could require all metal scrap import cargoes to be subjected to a pre-shipment and post-shipment inspection process, and for all imported material to meet a minimum threshold for non-metallic and non-conforming content.

The presentation by SIRIM further outlines which entities are allowed to apply for import licences as well as the pre-conditions and qualifications for the issuance of a Certificate of Approval (CoA) of imports. SIRIM also states that it will be the agency running the inspection process. A list outlining the costs of inspections, inspector travel expenses and post-inspection certificates has also been provided.

According to the agency, all ferrous and non-ferrous shipments would have to arrive by sea rather than travelling across any of the nation’s land borders with Thailand, Indonesia, Brunei or Singapore. With plastics having been seen as an unwanted contaminant in ferrous and non-ferrous scrap shipments, MITI has set a 0.25% threshold on plastic found in scrap metal cargoes. The tolerance for “electrical and electronic” scrap has been set at zero per cent.

The guidelines also state that the CoA would require a bank guarantee to be purchased by importing companies in Malaysia that have “an approved manufacturing licence from MITI”. Shipments found to be out of compliance, according to SIRIM, would be returned to the country of origin. The agency also states that funds from the “bank guarantee (tied to the CoA) will be used by SIRIM as transportation and incidental costs particularly for shipments that will have to be returned to the country of origin”.

At the time of writing, it remains unclear how restrictive these new import policies may be to our industry and when they could take effect. It needs to be restated that, at present, the guidelines are to be considered as purely indicative to BIR members.

The 23-page guideline document issued by SIRIM has been posted on the BIR website and provides further details on how the order is now intended to be enforced.