The content of the Draft Decree detailed several articles for the Law on Environmental Protection 2020. The Draft Decree aimed to replace Decree 40/2019/ND-CP (Amending & Supplementing Some Articles Of The Decree Detailing & Guiding the Implementation Of Environmental Protection Law). There were 3 main issues mentioned in this Draft Decree, including: Importation of scrap as raw materials for production; Wastewater monitoring; A list of HS codes for imported scrap in the paper industry. Let’s find out in detail each issue related to the paper industry in the article below.
1. Importation of scrap as raw materials for production
For the paper industry, the importation of scrap as raw production materials is always a hot issue between the Association and state management agencies. Therefore, the Association has commented and recommended the Draft National Technical Regulation on the import of scrap paper (QCVN 33: 2021).
The Association proposed to remove Clause 4, Article 53 of the Draft Decree, which stipulates that “From January 1, 2025, establishments using imported scrap as raw production materials may only import scrap up to a maximum equal to 80% of design capacity, the remaining one must be purchased domestically to use as raw materials for production.”. Although this does not affect the environment, it is affected by the supply and demand of raw materials for production. Therefore, it is time for us to adjust the policy to encourage collection and recycling.
2. Wastewater monitoring
In order to strengthen the monitoring and supervision of wastewater of businesses, the Association also proposed to the Government Office as well as the Ministry of Natural Resources and Environment Continue to extend the time for the installation of automatic and continuous wastewater and emission monitoring equipment until the end of December 31, 2022 (instead of December 31, 2021).
In terms of avoiding overlapping provisions of circulars, decrees and laws, the VPPA offered that the Draft Decree only stipulated environmental provisions. Other provisions that are not in the field of environment need to be referenced by other regulations or laws.
3. List of HS codes for imported scrap in the paper industry
Currently, the Prime Minister has promulgated the list of imported scrap as raw production materials. There are 3 HS codes for the paper industry that are allowed to be imported, namely 4707.10.00, 4707.20.00 and 4707.30.00. All of them are classified papers. The handling of 3 types of scrap paper with the HS code has no difference in environmental protection criteria.
In addition to complying with the Law of Value, production activities of enterprises are also regulated and governed by the supply-demand relationship according to the market mechanism. As a result, enterprises producing a variety of products must use many different types of scrap with HS codes, especially when the supply is in short supply due to scarcity and transportation problems in the current period to many years to come. Therefore, the certificate should only issue the total amount of scrap and the names of the imported HS codes, not the detailed volume for each HS code.
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Source: Vietnam Pulp & Paper Association (VPPA)
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