WEBVTT

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>> Good afternoon. I am Chrissi Guth
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with CBP's Office of Trade relations.
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Today's webinar is all about Heading
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8549 electronic waste and scrap.
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This webinar is a part of the NCSD's
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2023 webinar series. Please be mindful
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that you will be on mute during the
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presentation. Therefore we ask that you
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submit any questions you have in the
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CHAT feature.
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Now, I would like to pass it over to
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national import specialist Luke LePage.
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>> Thanks, Chrissi. As she said, good
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afternoon or good morning, depending
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where you're calling in from. My name
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is Luke LePage, the national import
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specialist with CBP, presenting the
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webinar today on Heading 8549.
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I want to thank you all for tuning in
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and encourage you to questions you may
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have. However, since this is a recorded
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webinar, I feel like it will be better
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to go through the entire presentation
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and answer your questions in the end.
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Feel free to type them in the CHAT as
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I'm going. Just know I'll only get to
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them in the order that they come in at
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the end of the presentation.
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I may not be able to get to all of them
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or know the specific answer off the top
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of my head. In those instances, you can
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just reach out after the fact, and we
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can try to help you out, I'll have the
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contact info for my office including me
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and my associate at the end of the
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presentation.
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Here's our mission statement for both
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CBP and the Office of Trade which our
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group is assigned to.
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This is just our general disclaimer that
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we use for our webinars. This covers
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that the webinar is essentially for
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informational purposes only and not
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binding in in anyway. For those
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external participants, the key point to
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this is that reliance only on this
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presentation may not be considered
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reasonable care if that issue were to
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ever arise.
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Here's our audio, visual disclaimer,
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covering the media use in this
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presentation. I may not have some of
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the really cool animations or graphics
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that you might see from some of my
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compatriots. But there are some
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imagines that I hope you find
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interesting and helpful.
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We do our best to make sure the pictures
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are all public domain. If they're not,
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they're attributed correctly.
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So the best way to get an answer from
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our office or really any NIS office is
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to submit a ruling request for any
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specific classification or origin issue
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that you may have. Those are the two
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primary issues that our offices handle.
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As I mentioned before, this webinar is
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only for informational purposes. So
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applying for a ruling request for your
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specific issues could be very
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advantageous. This is really the way to
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go to get the most concrete and complete
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answer.
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The link to our eRulings portal is on
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this slide. Please make sure that in
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the event you submit a ruling, you
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include all the available information
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that we'll need to make a decision.
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This should include a complete and
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detailed description of the device and
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its function as well as marketing
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material, users' manuals and anything
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else that could be pertinent.
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For origin related requests, please make
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sure there's a complete description of
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the manufacturing process, showing where
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all the steps are completed as well as
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the complete building materials. That
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building materials should include--
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where applicable. And where every
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single piece is manufactured along in
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the process.
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There's a template to follow within the
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link. So please make sure you read all
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the information necessary. For those
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listening, they're internal CBP
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personnel. There are also ways to get
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official internal request to us if
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you're running into any issues. Again,
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make sure there's sufficient information
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input for us to and so we can come to a
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legitimate and coherent response.
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Here's the list of all the headings that
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my office handles. Again my office is
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office 212, our offices are broken up by
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number. As you can see, I handle the
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end of chapter 85 with a few headings at
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the beginning of chapter 90. The bulk
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of my work comes through in heading 8543
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which is the electronics basket
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provision which is also the electronics
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hot potato which tends to get passed
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back and forth whenever the newest
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national import specialist shows up into
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the electronics group which just so
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happens to be me now. So I have it.
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The second is 8544 which is for cables
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and other conductors. But I'm starting
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to see more in the other headings as
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well. Today we're going to focus on the
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highlighted section, heading 8549.
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Okay. So we can get started. Let's get
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right into it.
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Heading 8549 covers what we refer to as
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electrical or electronic waste and
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scrap. You hear this commonly referred
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to as e-waste. We'll get way more into
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what all of that means as we go forward.
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You'll see here that I circled the year
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2022. That's because this is a
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completely new heading as of last year's
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tariff publication. Prior to that, we
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had a whole host of ways to classify
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electronic waste that would have gone
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into this new heading. Always prior to
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this heading was handled pretty much the
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same way and placed in various headings
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throughout the tariff, typically based
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primarily on what it will be mind for,
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what term it's made out of, where it's
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coming from a whole host of different
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ways.
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This heading is intended to give us the
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a specific spot for an ever-growing
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segment of waste as we introduce more
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electronics and the need for electronics
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grows. We are seeing more and more waste
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of those, of the materials that are
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being imported or used for various
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purposes.
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The harmonized system committee or HSC
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began discussing this addition a few
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years back. And it was finally
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published in the 2022 tariff. We are
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involved, my office as well as a few
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other offices who handled it prior to me
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coming on, we're involved in I have
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going our opinions and bringing up
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issues that we saw going forward
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throughout the negotiation process.
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Those who don't know, in order to have
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a new heading added, it's a long and
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drawn out process. That needs to be
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negotiated at the Harmonized System
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Committee with input from the member
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countries. It takes quite a few years or
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can take a few years, and very
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significant amount of back and forth.
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To date, my office hasn't received any
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ruling request specific to this heading.
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So nothing has really been published
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for us to follow. I also haven't seen
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anything when I searched that has gone
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through the headquarters office either.
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So that precedence isn't available as
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of yet. You'll notice that I will be
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giving a lot of theory of what we think
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should be going on here and our stance
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right now as to how to interpret the
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heading and notes.
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This is essentially from our
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conversations with CBP attorneys and the
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HSC over the years as well as our
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initial review and interpretation of the
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headings and notes. This could all
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change as more rulings come out. So,
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please, stay tuned.
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If you have anything in your businesses
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or internally for the CBP listeners,
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please think about filing a ruling so we
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can and it and get some precedence
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started so we'll have a little bit more
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to follow as we go forward.
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The first item that we need to address
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even before we get into the specific
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terms of this heading is the new note 6
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to section 16 which is where chapter 85
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is located.
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This gives us our first look into what
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exactly we will be looking at within
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heading 8549. As you can see, there are
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multiple rules and definitions here, and
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we'll get into more of this as we go
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forward.
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I'm going-- I'll skip going too deep
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into the capital A section since we're
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going to get into those items much more
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in the coming slides.
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This deals with the definition of
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e-waste and how it should be presented.
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I did want to bring your attention to
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capital B and C lines. Line B states
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that mixed consignments of electrical or
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electronic waste in scrap and other
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waste in scrap are to be classified in
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heading 8549. This is pretty
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self-explanatory. So if we have goods
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that are not going to be considered
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e-waste with goods that are heading 8549
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is going to take precedence.
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And then line C states this section does
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not cover municipal waste as defined in
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note 4 to chapter 38. For the reference
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to chapter 38, municipal waste is the
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waste that's collected from your
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household, your hotels, restaurants,
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offices and the like. In general it's
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the type of waste that you see your
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local garbage men pick up as he drives
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by your house. That's not something
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that we would see in heading 8549 per
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these notes.
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We can now turn to our second of the
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legal notes that we'll discuss. That's
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subheading note 6 to chapter 85. This
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says for the purposes of subheading
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8549.11 to 85.49.19, spent primary
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cells, spent primary batteries and spent
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electric accumulators are those which
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are neither usable as such because of
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breakage, cutting up, wear, or other
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reasons nor capable of being recharged.
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If you read the note from the last
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screen, you'll noticed that there was
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reference to things no longer usable.
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That's going to be something you'll
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hear me talk quite a bit in this
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presentation. And this is just the
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beginning. But it does lay the
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groundwork for the heading. The
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batteries of the heading must not be
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able to be recharged and must be
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destroyed in some way.
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The explanatory notes are the official
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definitions and interpretations of the
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tariff. They're not dispositive or
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legally binding but do give us a look
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into the thinking of the committee and
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members as they were creating the
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tariff.
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Note 6 that we discussed before
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references goods not being able to be
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used for their original purpose. In
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2022, after some negotiation, note 6 was
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added to the ENs in an effort to define
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the term original purpose which we will
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see in Heading 8549 as well as
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throughout this presentation.
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The original purpose per this note
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refers to the good's functional use as
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an electrical or electronic good. The
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keyword here is functional. We're going
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to get a lot more into this as we go
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forward.
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the actual explanatory note for Heading
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8549. You'll notice in the first line
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are that this is our first real
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reference to the term e-waste. This is
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showing us that the term is synonymous
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with electrical waste and scrap, that we
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will see used in this heading.
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From this note, we can infer that even
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things that were not originally class
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excited in chapter 85 as electrical
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goods can be classified in 8549 when
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they become waste. The note references
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anything requiring a plug or a battery.
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This is something important to keep in
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mind even though in my eyes and in my
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opinion, this probably needs to be
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flushed out a little in ruling and case
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examinations since it could add a little
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bit of confusion going forward and is
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something that we routinely brought up
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in the HSC negotiations. So again,
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another one of those theory points that
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we'll get through as we get through the
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presentation.
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Second part of the note states that the
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goods in this heading are only used for
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recovery, recycling or disposal. And if
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they are meant to be repaired,
00:13:44.283 --> 00:13:47.085
refurbished or renovated for any
00:13:47.085 --> 00:13:49.606
subsequent use either original or not,
00:13:49.606 --> 00:13:50.680
they cannot go into this heading.
00:13:50.680 --> 00:13:53.451
Simply being a used good does not mean
00:13:53.451 --> 00:13:57.858
that the item can be considered e-waste.
00:13:57.858 --> 00:14:00.788
That's another pretty critical point
00:14:00.788 --> 00:14:02.437
that I'll probably hammer in a few
00:14:02.437 --> 00:14:04.221
separate times throughout this
00:14:04.221 --> 00:14:06.651
presentation. So just bear with me on
00:14:06.651 --> 00:14:16.109
some repetition.
00:14:16.109 --> 00:14:19.321
One term you're going to see routinely
00:14:19.321 --> 00:14:22.068
in e-waste circles is the phrase end of
00:14:22.068 --> 00:14:24.005
life. What this means is when someone
00:14:24.005 --> 00:14:28.748
can no longer use a device for its
00:14:28.748 --> 00:14:30.308
intended original function. This is one
00:14:30.308 --> 00:14:31.959
term we'll use to define e-waste going
00:14:31.959 --> 00:14:33.610
forward and encompasses what we just
00:14:33.610 --> 00:14:36.449
talked about in terms of the explanatory
00:14:36.449 --> 00:14:39.003
notes.
00:14:39.003 --> 00:14:40.385
I also want to note that there is a
00:14:40.385 --> 00:14:42.843
court case that gives us some term
00:14:42.843 --> 00:14:45.128
knowledging and precedence to follow.
00:14:45.128 --> 00:14:47.308
It's a little dated from 1970. But
00:14:47.308 --> 00:14:50.364
U.S. versus David Studner gives us a
00:14:50.364 --> 00:14:53.987
waste definition of "that which has no
00:14:53.987 --> 00:14:55.696
original value or not value for the
00:14:55.696 --> 00:14:59.539
ordinary or main purpose of the
00:14:59.539 --> 00:15:01.748
manufacture," this really reinforces
00:15:01.748 --> 00:15:03.450
what we already discussed that anything
00:15:03.450 --> 00:15:06.357
that goes into Heading 8549 cannot be
00:15:06.357 --> 00:15:07.732
available to be used for its original
00:15:07.732 --> 00:15:11.716
purpose even with some sort of work to
00:15:11.716 --> 00:15:13.095
do. Sorry to sound like a broken
00:15:13.095 --> 00:15:14.492
record. But the original purpose issue
00:15:14.492 --> 00:15:17.997
is really important to this heading. And
00:15:17.997 --> 00:15:19.361
don't worry. You probably haven't heard
00:15:19.361 --> 00:15:21.265
me mention the last of it throughout the
00:15:21.265 --> 00:15:35.403
presentation.
00:15:35.403 --> 00:15:37.119
Here are a couple of definitions to keep
00:15:37.119 --> 00:15:39.211
in mind that were discussed in the notes
00:15:39.211 --> 00:15:42.236
that we already talked about. Remember
00:15:42.236 --> 00:15:45.087
the goods have to be imported with the
00:15:45.087 --> 00:15:47.122
intention to have one of these processes
00:15:47.122 --> 00:15:52.549
completed.
00:15:52.549 --> 00:15:58.512
My apologies, I didn't switch the slide.
00:15:58.512 --> 00:16:00.157
Recycling and recovery are similar and
00:16:00.157 --> 00:16:01.965
essentially mean that the goods are
00:16:01.965 --> 00:16:04.156
going to be processed to a extract
00:16:04.156 --> 00:16:08.175
resources or materials from the
00:16:08.175 --> 00:16:10.179
electronics. There are a variety of
00:16:10.179 --> 00:16:12.417
processes that can be used, depending
00:16:12.417 --> 00:16:14.133
upon the item, the state and what
00:16:14.133 --> 00:16:16.384
material could be extracted. Disposal
00:16:16.384 --> 00:16:19.847
is pretty much just the typical idea of
00:16:19.847 --> 00:16:21.221
sending the discarded goods to a
00:16:21.221 --> 00:16:24.402
landfill to sit forever.
00:16:24.402 --> 00:16:26.493
There are also facilities that do safe
00:16:26.493 --> 00:16:28.799
disposal of harmful chemicals or
00:16:28.799 --> 00:16:30.149
compounds that could be found in some of
00:16:30.149 --> 00:16:32.517
these items. That's also something to
00:16:32.517 --> 00:16:46.370
keep in mind.
00:16:46.370 --> 00:16:48.679
I put this slide together to give you an
00:16:48.679 --> 00:16:50.049
idea of a typical process of recycling
00:16:50.049 --> 00:16:52.988
or recovering items from e-waste. The
00:16:52.988 --> 00:16:54.200
first step is the collection of the
00:16:54.200 --> 00:16:58.478
items themselves. They're stored until
00:16:58.478 --> 00:16:59.969
the correct number is collected in order
00:16:59.969 --> 00:17:03.347
to make the processes worthwhile.
00:17:03.347 --> 00:17:06.333
This is probably the first, in this
00:17:06.333 --> 00:17:07.650
first step is where we will see most of
00:17:07.650 --> 00:17:09.177
the goods that we will come in contact
00:17:09.177 --> 00:17:10.667
with because this will be the
00:17:10.667 --> 00:17:19.228
importation process most likely.
00:17:19.228 --> 00:17:20.718
Storage will probably consist of keeping
00:17:20.718 --> 00:17:22.814
the items separate by what materials are
00:17:22.814 --> 00:17:25.873
meant to be extracted. The next step is
00:17:25.873 --> 00:17:28.719
the sorting, dismantling and shredding.
00:17:28.719 --> 00:17:30.536
This can be done by a variety of
00:17:30.536 --> 00:17:33.150
different machines or by hand. This
00:17:33.150 --> 00:17:34.650
cuts up the items so they can be
00:17:34.650 --> 00:17:36.151
separated by the machines in the next
00:17:36.151 --> 00:17:40.063
step of mechanical separation. This
00:17:40.063 --> 00:17:41.593
leaves the constituent material that
00:17:41.593 --> 00:17:43.900
needs to be recovered by itself to be
00:17:43.900 --> 00:17:50.420
easily extracted or recovered.
00:17:50.420 --> 00:17:52.295
And then the final step is the actual
00:17:52.295 --> 00:17:56.013
physical recovery of whatever the term
00:17:56.013 --> 00:18:05.058
that may be.
00:18:05.058 --> 00:18:07.773
One of the things to look out for in
00:18:07.773 --> 00:18:10.578
these shipments of e-waste to show their
00:18:10.578 --> 00:18:11.492
end state is how they would be packaged
00:18:11.492 --> 00:18:12.765
for transport. They're typically going
00:18:12.765 --> 00:18:15.667
to be mixed shipments in bulk containers
00:18:15.667 --> 00:18:17.688
with little to no care in protecting
00:18:17.688 --> 00:18:19.070
them since they're going to be further
00:18:19.070 --> 00:18:21.561
destroyed. You might see a computer in
00:18:21.561 --> 00:18:24.810
the same box of crate as a bunch of
00:18:24.810 --> 00:18:28.519
electronic motors or batteries. They may
00:18:28.519 --> 00:18:30.549
be broken or cut up or obviously
00:18:30.549 --> 00:18:32.977
unusable in some other way.
00:18:32.977 --> 00:18:34.418
I put a couple of pictures here to
00:18:34.418 --> 00:18:37.066
illustrate a little bit of what I'm
00:18:37.066 --> 00:18:38.876
talking about. It's going to be pretty
00:18:38.876 --> 00:18:53.573
recognizable as used up waste.
00:18:53.573 --> 00:18:54.981
The three key components that I
00:18:54.981 --> 00:18:57.349
mentioned that would exclude
00:18:57.349 --> 00:18:59.754
classification in Heading 8549 are
00:18:59.754 --> 00:19:01.658
listed here. Their repair,
00:19:01.658 --> 00:19:04.680
refurbishment and renovation. Repair
00:19:04.680 --> 00:19:06.708
means that you fix or amend something to
00:19:06.708 --> 00:19:07.955
its original purpose. The goods that
00:19:07.955 --> 00:19:10.452
will be repaired are most likely
00:19:10.452 --> 00:19:11.986
nonoperational when come in but capable
00:19:11.986 --> 00:19:14.323
to be fixed up to function again. Based
00:19:14.323 --> 00:19:17.562
on what we've talked about so far, we
00:19:17.562 --> 00:19:19.319
know something like this could not be
00:19:19.319 --> 00:19:23.917
classified under Heading 8549.
00:19:23.917 --> 00:19:26.207
Refurbishment is similar but most likely
00:19:26.207 --> 00:19:27.423
goods to be refurbished or at least be
00:19:27.423 --> 00:19:29.708
somewhat usable at importation. They
00:19:29.708 --> 00:19:31.672
just need to be freshened up.
00:19:31.672 --> 00:19:33.979
Renovation is also not that far off
00:19:33.979 --> 00:19:36.942
from the others. That means more of a
00:19:36.942 --> 00:19:38.350
restoration either cosmetically or
00:19:38.350 --> 00:19:39.254
through an enhancement in the
00:19:39.254 --> 00:19:41.535
functionality.
00:19:41.535 --> 00:19:43.212
These terms may be used interchangeably.
00:19:43.212 --> 00:19:44.746
But they're definitely something to
00:19:44.746 --> 00:19:47.286
look out for since anything that's going
00:19:47.286 --> 00:19:49.186
to go through any of these processes,
00:19:49.186 --> 00:19:51.964
after importation, can't be classified
00:19:51.964 --> 00:20:03.856
as e-waste.
00:20:03.856 --> 00:20:06.103
Items that are going to be brought in
00:20:06.103 --> 00:20:09.061
for any repair, refurbishment,
00:20:09.061 --> 00:20:10.562
renovation are definitely going to be
00:20:10.562 --> 00:20:13.710
packaged differently for shipment. The
00:20:13.710 --> 00:20:19.829
packaging will be designed to preserve
00:20:19.829 --> 00:20:21.605
excuse me --. Or protect the items so
00:20:21.605 --> 00:20:23.853
as not to damage them in transport.
00:20:23.853 --> 00:20:27.663
This could be in foam, blister packs or
00:20:27.663 --> 00:20:29.688
bubble wrap. The very least they'll be
00:20:29.688 --> 00:20:31.033
packaged with other goods of the same
00:20:31.033 --> 00:20:33.997
type and condition. They won't be just
00:20:33.997 --> 00:20:35.462
loose in containers or intermingled
00:20:35.462 --> 00:20:37.582
among other items. You should also look
00:20:37.582 --> 00:20:41.354
out for where the items are going. Many
00:20:41.354 --> 00:20:42.855
of the refurbishment and repair
00:20:42.855 --> 00:20:44.665
facilities are dedicated to that
00:20:44.665 --> 00:20:46.780
purpose. Think of the cellphone repair
00:20:46.780 --> 00:20:49.626
shops that are springing up on every
00:20:49.626 --> 00:20:51.372
corner. I put a few photo on this slide
00:20:51.372 --> 00:20:54.620
to give you an idea of some this type of
00:20:54.620 --> 00:20:55.460
packaging that you should be looking out
00:20:55.460 --> 00:21:11.372
for.
00:21:11.372 --> 00:21:13.185
So now that we've gone through the
00:21:13.185 --> 00:21:14.652
basics of what should go at the heading
00:21:14.652 --> 00:21:15.975
level, let's go to the specifics of
00:21:15.975 --> 00:21:18.466
heading
00:21:18.466 --> 00:21:19.566
You're going to notice as we go through
00:21:19.566 --> 00:21:21.089
this, that the subheadings are pretty
00:21:21.089 --> 00:21:24.555
specific and seem pretty involved. I'll
00:21:24.555 --> 00:21:25.833
try to give a good idea based on the
00:21:25.833 --> 00:21:28.679
terms of what goes into this one.
00:21:28.679 --> 00:21:29.799
The first section of the heading is
00:21:29.799 --> 00:21:31.292
going to deal with batteries. I'm going
00:21:31.292 --> 00:21:33.070
to give you a brief definition of
00:21:33.070 --> 00:21:34.743
primary cells and accumulators since
00:21:34.743 --> 00:21:36.160
those are the two terms mentioned
00:21:36.160 --> 00:21:39.311
related to batteries.
00:21:39.311 --> 00:21:41.219
Primary cells are one time use batteries
00:21:41.219 --> 00:21:45.178
like your typical alkaline batteries in
00:21:45.178 --> 00:21:48.895
your task force TV remote. An
00:21:48.895 --> 00:21:51.012
accumulator is a rechargeable secondary
00:21:51.012 --> 00:21:51.913
battery like the Lithium battery in your
00:21:51.913 --> 00:21:52.917
laptop or other electrical device. So
00:21:52.917 --> 00:21:55.972
this section should cover pretty much
00:21:55.972 --> 00:21:56.817
everything you'll see from a battery
00:21:56.817 --> 00:22:00.252
standpoint.
00:22:00.252 --> 00:22:01.433
You'll see that it talks about waste and
00:22:01.433 --> 00:22:05.427
scrap which can be incomplete or diss
00:22:05.427 --> 00:22:08.732
assembled or cut up batteries. Other
00:22:08.732 --> 00:22:12.265
term that this section discusses is the
00:22:12.265 --> 00:22:13.535
term "spent." That means that they
00:22:13.535 --> 00:22:14.509
can't be charged anymore or there's
00:22:14.509 --> 00:22:17.344
though power left in them. This is what
00:22:17.344 --> 00:22:19.004
subheading note 6 that we previously
00:22:19.004 --> 00:22:33.293
talked about is referring to.
00:22:33.293 --> 00:22:34.506
This is what I was referring to when I
00:22:34.506 --> 00:22:35.534
said it's going to get a little
00:22:35.534 --> 00:22:37.623
complicated at the subheading level.
00:22:37.623 --> 00:22:38.909
The batteries are going to be further
00:22:38.909 --> 00:22:42.306
broken out by what material is being
00:22:42.306 --> 00:22:44.610
recovered or collected from them. You'll
00:22:44.610 --> 00:22:46.332
see multiple references to the recovery
00:22:46.332 --> 00:22:47.890
of lead from the batteries. Also
00:22:47.890 --> 00:22:52.543
cadmium or mercury are mentioned.
00:22:52.543 --> 00:22:55.567
Then other chemical types, based on how
00:22:55.567 --> 00:22:57.031
they're sorted. There's even a breakout
00:22:57.031 --> 00:22:58.435
for lead acid batteries that were used
00:22:58.435 --> 00:23:01.231
to start engines. Seems really specific
00:23:01.231 --> 00:23:03.285
but a good thing to keep in mind if you
00:23:03.285 --> 00:23:07.223
come across spent or wasted batterie
00:23:07.223 --> 00:23:08.689
It's important to know, the state,
00:23:08.689 --> 00:23:10.000
condition, and importation process
00:23:10.000 --> 00:23:12.622
considering classification and also to
00:23:12.622 --> 00:23:16.110
fully understand the chemical and
00:23:16.110 --> 00:23:17.798
material makeup of the batteries as well
00:23:17.798 --> 00:23:31.526
as their original use.
00:23:31.526 --> 00:23:33.236
The next section deals with those
00:23:33.236 --> 00:23:35.299
electrical and electronic items and
00:23:35.299 --> 00:23:36.799
components that are brought in
00:23:36.799 --> 00:23:39.947
exclusively for the recovery of precious
00:23:39.947 --> 00:23:41.354
metal. Many electronics contain
00:23:41.354 --> 00:23:44.593
precious metals that can be mined or
00:23:44.593 --> 00:23:46.099
extracted at the end of their life.
00:23:46.099 --> 00:23:47.380
These metals can be durable and are
00:23:47.380 --> 00:23:49.063
excellent conductors of electricity and
00:23:49.063 --> 00:23:52.237
are found in everything from your
00:23:52.237 --> 00:23:55.826
cellphone to your TV. Just to note, the
00:23:55.826 --> 00:23:57.829
term precious metal is defined in the
00:23:57.829 --> 00:24:00.074
tariff by note 4a to chapter 71. The
00:24:00.074 --> 00:24:04.103
three precious metals per the tariff
00:24:04.103 --> 00:24:08.310
definition are gold, silver, and
00:24:08.310 --> 00:24:11.210
platinum. Note 4be panned on the
00:24:11.210 --> 00:24:14.361
platinum to mean platinum, iridium
00:24:14.361 --> 00:24:16.075
osmium, palladium, rhodium, and
00:24:16.075 --> 00:24:17.984
ruthenium. Now, I don't know what any
00:24:17.984 --> 00:24:19.227
of those things are, but it's good to
00:24:19.227 --> 00:24:22.537
keep their names in mind.
00:24:22.537 --> 00:24:24.319
Again, this reinforces the idea that we
00:24:24.319 --> 00:24:26.252
must know the make up and what will be
00:24:26.252 --> 00:24:38.140
done to the items after importation.
00:24:38.140 --> 00:24:39.233
You may be asking, well, where are these
00:24:39.233 --> 00:24:40.880
expensive precious metals in my
00:24:40.880 --> 00:24:42.696
electronics? What are they actually
00:24:42.696 --> 00:24:43.727
used for? Here are some examples to
00:24:43.727 --> 00:24:44.663
consider before you start breaking up
00:24:44.663 --> 00:24:47.093
your electronics at your house like a
00:24:47.093 --> 00:24:50.709
prospector.
00:24:50.709 --> 00:24:51.967
gold's an excellent conductor that is
00:24:51.967 --> 00:24:53.805
good at high temperature and is very
00:24:53.805 --> 00:24:55.584
malleable. It's typically used on
00:24:55.584 --> 00:24:58.362
coatings for display screens, plating
00:24:58.362 --> 00:25:03.258
for semiconductors and other connectors.
00:25:03.258 --> 00:25:06.097
Silver has the highest conductivity of
00:25:06.097 --> 00:25:11.334
the metal elements. It can be sound in
00:25:11.334 --> 00:25:15.019
soldering, contacts and switches as a
00:25:15.019 --> 00:25:16.206
connection or conductivity point. It's
00:25:16.206 --> 00:25:19.105
also used in different types of
00:25:19.105 --> 00:25:20.604
batteries. Platinum or the other names
00:25:20.604 --> 00:25:22.819
we previously discussed that I won't try
00:25:22.819 --> 00:25:24.317
to pronounce again has a high
00:25:24.317 --> 00:25:27.374
conductivity and is very resistent to
00:25:27.374 --> 00:25:29.773
row roding. It's used in integrated
00:25:29.773 --> 00:25:33.614
circuits, fuses and frames as well as a
00:25:33.614 --> 00:25:41.474
variety of plating and coatings.
00:25:41.474 --> 00:25:43.374
There were a variety of different
00:25:43.374 --> 00:25:45.777
processes involved in extracting the
00:25:45.777 --> 00:25:47.346
precious metals. You can see from the
00:25:47.346 --> 00:25:49.317
note on the bottom of the screen that
00:25:49.317 --> 00:25:49.807
most of these are caustic and can be
00:25:49.807 --> 00:25:51.460
extremely dangerous. This will most
00:25:51.460 --> 00:25:54.614
likely be done in professional
00:25:54.614 --> 00:25:56.422
facilities dedicated to these processes.
00:25:56.422 --> 00:26:00.101
So don't try them at home.
00:26:00.101 --> 00:26:01.755
Leaching is a way of converting metals
00:26:01.755 --> 00:26:02.946
into soluble salts, using caustic
00:26:02.946 --> 00:26:07.901
liquids. Smelting uses high pressure
00:26:07.901 --> 00:26:09.959
chemicals to separate the metal. Just a
00:26:09.959 --> 00:26:11.399
note that this is a different process
00:26:11.399 --> 00:26:14.051
than the metal smelting we see mentioned
00:26:14.051 --> 00:26:15.982
throughout the tariff, related to the
00:26:15.982 --> 00:26:19.544
manufacturing and processing of other
00:26:19.544 --> 00:26:21.168
metals. Electrolysis uses an electrical
00:26:21.168 --> 00:26:22.910
charge to deposit the desired material
00:26:22.910 --> 00:26:27.461
onto a cathode. This is just a really
00:26:27.461 --> 00:26:29.278
basic definition of each of these
00:26:29.278 --> 00:26:31.738
processes. My main objective here was
00:26:31.738 --> 00:26:33.239
to introduce some terms for
00:26:33.239 --> 00:26:34.613
familiarization. There are some really
00:26:34.613 --> 00:26:36.109
good and thorough information online
00:26:36.109 --> 00:26:37.516
about these processes if you're
00:26:37.516 --> 00:26:49.120
interested.
00:26:49.120 --> 00:26:51.213
The next session of the heading is going
00:26:51.213 --> 00:26:52.458
to deal with other electrical or
00:26:52.458 --> 00:26:56.761
electronic assemblies in printed circuit
00:26:56.761 --> 00:26:58.860
boards or PCBs. An assembly is a number
00:26:58.860 --> 00:27:00.446
or group of components that work
00:27:00.446 --> 00:27:02.974
together to perform a specific function.
00:27:02.974 --> 00:27:04.499
This is important to remember because
00:27:04.499 --> 00:27:07.251
it can't be something that we wouldn't
00:27:07.251 --> 00:27:09.801
consider an assembly. It won't be a
00:27:09.801 --> 00:27:11.711
single use item that doesn't have
00:27:11.711 --> 00:27:14.797
multiple parts to it.
00:27:14.797 --> 00:27:15.890
A good example of something that would
00:27:15.890 --> 00:27:17.728
go in here is a fully populated PCB with
00:27:17.728 --> 00:27:22.973
a variety of components. There are some
00:27:22.973 --> 00:27:24.754
repeated materials in the narrative
00:27:24.754 --> 00:27:27.090
section here and some new ones that we
00:27:27.090 --> 00:27:29.959
haven't seen before.
00:27:29.959 --> 00:27:32.431
There is reference again to battery
00:27:32.431 --> 00:27:34.452
technology. We'll have a brief
00:27:34.452 --> 00:27:36.329
discussion in the next slide about some
00:27:36.329 --> 00:27:39.201
of the other materials and technology
00:27:39.201 --> 00:27:50.745
discussed.
00:27:50.745 --> 00:27:52.365
Mercury switches are electrical switches
00:27:52.365 --> 00:27:53.798
that open or close a circuit when the
00:27:53.798 --> 00:27:55.761
element hits the electrodes either by
00:27:55.761 --> 00:27:57.694
movement or by the introduction or
00:27:57.694 --> 00:27:59.229
change in temperature. these are not
00:27:59.229 --> 00:28:06.500
wide lie used anymore. But older ones
00:28:06.500 --> 00:28:07.344
may come in for the mercury to be
00:28:07.344 --> 00:28:10.332
harvested.
00:28:10.332 --> 00:28:13.864
Glass from cathode ray tubes, devices
00:28:13.864 --> 00:28:17.952
are commonly found in old televisions
00:28:17.952 --> 00:28:18.943
and monitors. A CRT is a vacuum tube
00:28:18.943 --> 00:28:20.382
that has an electron gun that emits a
00:28:20.382 --> 00:28:24.563
beam. This glass can be harvested and
00:28:24.563 --> 00:28:25.936
turned into different things such as
00:28:25.936 --> 00:28:37.016
ceramic materials.
00:28:37.016 --> 00:28:38.855
The other elements and compounds that
00:28:38.855 --> 00:28:40.105
are mentioned in this section are shown
00:28:40.105 --> 00:28:42.908
here on this slide. Cadmium is used in
00:28:42.908 --> 00:28:45.594
batteries and coatings and pigments.
00:28:45.594 --> 00:28:48.461
Mercury is used in screens, batteries,
00:28:48.461 --> 00:28:51.484
and switches. Lead is used in batteries
00:28:51.484 --> 00:28:57.764
and as a strengthening or connecting
00:28:57.764 --> 00:29:01.414
compound. PCBs or poly color natured
00:29:01.414 --> 00:29:02.537
biphenyls are substances used for
00:29:02.537 --> 00:29:04.875
coolants and other fluids. They're now
00:29:04.875 --> 00:29:06.313
banned in the U.S. So we won't see
00:29:06.313 --> 00:29:09.934
these very often.
00:29:09.934 --> 00:29:12.378
All of these that are mentioned here are
00:29:12.378 --> 00:29:14.534
highly toxic and in most cases are not
00:29:14.534 --> 00:29:17.149
used commercially anymore. However they
00:29:17.149 --> 00:29:22.022
may be sent to various facilities that
00:29:22.022 --> 00:29:22.958
we mentioned before for their proper
00:29:22.958 --> 00:29:40.521
disposal.
00:29:40.521 --> 00:29:41.213
I know I said of there have been no
00:29:41.213 --> 00:29:42.236
rulings as of yet that give us an
00:29:42.236 --> 00:29:44.270
insight into Heading 8549. However,
00:29:44.270 --> 00:29:45.580
there are past rulings that can give us
00:29:45.580 --> 00:29:46.855
an idea how we should think about
00:29:46.855 --> 00:29:48.539
e-waste from a practical classification
00:29:48.539 --> 00:29:53.876
standpoint.
00:29:53.876 --> 00:29:55.742
H218910 is one that discuss circuit
00:29:55.742 --> 00:29:57.148
board that came in for the reclamation
00:29:57.148 --> 00:29:59.089
of various materials. They were
00:29:59.089 --> 00:30:00.910
imported in bulk and in different
00:30:00.910 --> 00:30:07.275
states. The rule states that per GRI3c,
00:30:07.275 --> 00:30:08.520
we use the predominant metal that will
00:30:08.520 --> 00:30:10.735
be reclaimed as the classification. As
00:30:10.735 --> 00:30:13.628
I said, this was prior to 8549 being
00:30:13.628 --> 00:30:17.273
published but does give us some insight
00:30:17.273 --> 00:30:19.651
into how we get into the various
00:30:19.651 --> 00:30:22.545
subheadings within the heading if a good
00:30:22.545 --> 00:30:25.199
qualifies as e-waste.
00:30:25.199 --> 00:30:26.945
For instance, if a mixed shipment of
00:30:26.945 --> 00:30:28.725
various e-waste is brought in and we
00:30:28.725 --> 00:30:30.446
process for the material represented in
00:30:30.446 --> 00:30:34.439
different subheadings, we could use this
00:30:34.439 --> 00:30:35.837
ruling as a basis for where the shipment
00:30:35.837 --> 00:30:39.241
should be classified specifically.
00:30:39.241 --> 00:30:42.511
And if you put this together with the
00:30:42.511 --> 00:30:44.047
note that we discussed earlier, talking
00:30:44.047 --> 00:30:45.764
about mixed consignments, kind of gives
00:30:45.764 --> 00:30:54.437
us an idea of where shipments that have
00:30:54.437 --> 00:30:56.030
a variety of different end results to
00:30:56.030 --> 00:31:12.005
them, where they'll be classified.
00:31:12.005 --> 00:31:14.221
Another ruling would be 963790. This is
00:31:14.221 --> 00:31:16.772
another example of scrap printed circuit
00:31:16.772 --> 00:31:20.020
boards, published prior to 8549. In
00:31:20.020 --> 00:31:21.739
this one, the PCBs were found to be
00:31:21.739 --> 00:31:26.356
classified under heading 8517, based on
00:31:26.356 --> 00:31:27.537
their original functionality and not as
00:31:27.537 --> 00:31:31.192
waste and scrap.
00:31:31.192 --> 00:31:32.892
The requester in this case did not prove
00:31:32.892 --> 00:31:34.607
that the goods were inoperable and no
00:31:34.607 --> 00:31:37.228
longer fit for their original purpose.
00:31:37.228 --> 00:31:41.971
This really reinforces the definition
00:31:41.971 --> 00:31:43.220
much e-waste, that they must be proven
00:31:43.220 --> 00:31:46.836
not to be usable as originally intended.
00:31:46.836 --> 00:31:51.084
In also shows that we need to be as CBP
00:31:51.084 --> 00:31:53.955
and as we're reviewing this, we need to
00:31:53.955 --> 00:31:57.354
be pretty stringent on what we consider
00:31:57.354 --> 00:32:01.818
as inoperable and fit for original use.
00:32:01.818 --> 00:32:04.117
I would suggest bookmarking both of
00:32:04.117 --> 00:32:06.902
these rulings and reading the rationale
00:32:06.902 --> 00:32:08.588
at a later time. There is a lot of
00:32:08.588 --> 00:32:09.677
really good information in both of
00:32:09.677 --> 00:32:20.001
those.
00:32:20.001 --> 00:32:21.905
Okay. So what's better than some good
00:32:21.905 --> 00:32:24.091
unsubstantiated hypothetical questions?
00:32:24.091 --> 00:32:25.741
Again we can only interpret this new
00:32:25.741 --> 00:32:28.866
heading as we go since no concrete
00:32:28.866 --> 00:32:31.829
decisions have been written. Let's have
00:32:31.829 --> 00:32:40.320
some fun with a couple of examples.
00:32:40.320 --> 00:32:42.389
Can an item originally classified
00:32:42.389 --> 00:32:45.322
outside of chapter 85 or section 16 be
00:32:45.322 --> 00:32:47.948
considered e-waste at the end of its
00:32:47.948 --> 00:32:50.157
life? I didn't do a really fun graphic
00:32:50.157 --> 00:32:52.782
or survey in this page that you can
00:32:52.782 --> 00:32:53.688
interact with. But just think about
00:32:53.688 --> 00:33:02.860
what your answer would be.
00:33:02.860 --> 00:33:05.320
Remember the explanatory note to 8549
00:33:05.320 --> 00:33:07.160
talking about anything with a plug or
00:33:07.160 --> 00:33:09.068
battery. Again any goods that have a
00:33:09.068 --> 00:33:11.563
plug or require a battery will generally
00:33:11.563 --> 00:33:13.493
be e-waste at the end of their
00:33:13.493 --> 00:33:18.206
lifecycle.
00:33:18.206 --> 00:33:19.812
So it does say generally. So that's
00:33:19.812 --> 00:33:22.749
something you will have to keep in mind.
00:33:22.749 --> 00:33:24.366
But based upon the way that the
00:33:24.366 --> 00:33:26.895
explanatory note reads, leads us to
00:33:26.895 --> 00:33:29.267
believe that the answer to that question
00:33:29.267 --> 00:33:34.742
is indeed, yes. I realize that this
00:33:34.742 --> 00:33:36.178
could create some confusion going
00:33:36.178 --> 00:33:38.331
forward. But let's look a few examples
00:33:38.331 --> 00:33:48.752
to see what we think.
00:33:48.752 --> 00:33:50.972
So what about an electric guitar?
00:33:50.972 --> 00:33:52.184
They're originally outside of chapter 85
00:33:52.184 --> 00:33:55.217
or section 16 for that matter. But if a
00:33:55.217 --> 00:33:57.050
shipment is brought in of guitars that
00:33:57.050 --> 00:34:00.316
are nonfunctioning and broken up and are
00:34:00.316 --> 00:34:01.559
going to be sent to a facility to have
00:34:01.559 --> 00:34:05.806
their parts reclaimed, they could be
00:34:05.806 --> 00:34:07.679
classified under Heading 8549 if all of
00:34:07.679 --> 00:34:13.447
the other aspects of classification are
00:34:13.447 --> 00:34:17.331
met.
00:34:17.331 --> 00:34:18.830
Similarly, a medical device that
00:34:18.830 --> 00:34:20.813
function electrically like the sonogram
00:34:20.813 --> 00:34:22.591
machine on the bottom of the page are
00:34:22.591 --> 00:34:27.986
originally classified under chapter 90.
00:34:27.986 --> 00:34:30.268
However, if the PCBAs or complete
00:34:30.268 --> 00:34:31.613
devices even are imported in a broken
00:34:31.613 --> 00:34:33.419
down state for the harvesting of the
00:34:33.419 --> 00:34:36.445
metals, then they could also be
00:34:36.445 --> 00:34:41.937
classified under Heading 8549.
00:34:41.937 --> 00:34:43.684
Finally what about the video game
00:34:43.684 --> 00:34:45.394
system? If the circumstances are
00:34:45.394 --> 00:34:46.869
correct, then again I see some good
00:34:46.869 --> 00:34:48.145
reasoning that this could be classified
00:34:48.145 --> 00:34:50.457
under the e-waste provision. Remember,
00:34:50.457 --> 00:34:52.640
we are just interpreting the notes as we
00:34:52.640 --> 00:35:00.940
see them. So more work could be done or
00:35:00.940 --> 00:35:03.717
these opinions could change based on
00:35:03.717 --> 00:35:06.956
future rulings or opinions drafted
00:35:06.956 --> 00:35:15.413
either here or at the HSC.
00:35:15.413 --> 00:35:16.946
Here are some important things to
00:35:16.946 --> 00:35:18.563
consider as you're looking at shipments
00:35:18.563 --> 00:35:21.623
or situations where you think e-waste
00:35:21.623 --> 00:35:26.959
could come into play.
00:35:26.959 --> 00:35:29.359
Where is the item destined? Remember we
00:35:29.359 --> 00:35:31.652
want to know what kind of facility these
00:35:31.652 --> 00:35:33.334
things are going to. That could really
00:35:33.334 --> 00:35:39.105
tell us a lot, tell us a lot about
00:35:39.105 --> 00:35:42.109
what's going to be done after the fact.
00:35:42.109 --> 00:35:45.945
How is it packaged for transport? Is it
00:35:45.945 --> 00:35:49.527
loose and intermingled with other items?
00:35:49.527 --> 00:35:51.002
Has there any care taken in how they're
00:35:51.002 --> 00:35:56.337
packaged or protected? Are they only
00:35:56.337 --> 00:36:01.670
separated by certain things? What is the
00:36:01.670 --> 00:36:05.790
condition or state of the item?
00:36:05.790 --> 00:36:10.097
Again, similar to above, do they look
00:36:10.097 --> 00:36:13.026
broken down? Do they look like they've
00:36:13.026 --> 00:36:14.397
been used? Have they been destroyed in
00:36:14.397 --> 00:36:16.302
some way? What was their original
00:36:16.302 --> 00:36:21.857
intended use? Is this an electrical
00:36:21.857 --> 00:36:25.226
function or is it something els
00:36:25.226 --> 00:36:27.970
And then what will happen to them after
00:36:27.970 --> 00:36:30.403
importation? This should include what
00:36:30.403 --> 00:36:34.587
materials will be harvested out of them
00:36:34.587 --> 00:36:38.078
whether that's precious metal, whether
00:36:38.078 --> 00:36:41.329
that's some other item inside of there.
00:36:41.329 --> 00:36:43.510
And what will be the subsequent use if
00:36:43.510 --> 00:36:45.194
any? This should tell us is it going to
00:36:45.194 --> 00:36:46.941
be refurbished? Is it going to be
00:36:46.941 --> 00:36:49.154
rehabbed? Is anything going to be done
00:36:49.154 --> 00:36:52.592
to this to get it either back to its
00:36:52.592 --> 00:36:55.928
original use or some other use
00:36:55.928 --> 00:37:07.695
electrically?
00:37:07.695 --> 00:37:09.622
Okay. So that brings me pretty much of
00:37:09.622 --> 00:37:12.554
to the end of my presentation. I may
00:37:12.554 --> 00:37:15.025
not be quite as long as others. So you
00:37:15.025 --> 00:37:25.318
get a little reprieve from mine.
00:37:25.318 --> 00:37:28.189
Due to it being a new classification,
00:37:28.189 --> 00:37:29.815
there are some very limited information.
00:37:29.815 --> 00:37:32.684
But I did want to introduce it to
00:37:32.684 --> 00:37:34.150
everybody. So if there are any question
00:37:34.150 --> 00:37:40.330
out there, I don't-- I'll scroll through
00:37:40.330 --> 00:37:55.120
now and take a look.
00:37:55.120 --> 00:38:08.049
Okay. I'm not seeing anything as of
00:38:08.049 --> 00:38:12.068
yet. So I have one on here, what does
00:38:12.068 --> 00:38:16.378
CBP expect as proof?
00:38:16.378 --> 00:38:20.251
As of right now, I'm not specifically
00:38:20.251 --> 00:38:23.072
sure. I can't give anything in
00:38:23.072 --> 00:38:27.031
particular about one thing that would
00:38:27.031 --> 00:38:29.811
show us, you know, where it's going.
00:38:29.811 --> 00:38:34.555
There should be some sort of contract
00:38:34.555 --> 00:38:41.639
to the facility. That would be helpful.
00:38:41.639 --> 00:38:43.666
You know, where they were collected
00:38:43.666 --> 00:38:45.818
from. Are these just-- I think it's
00:38:45.818 --> 00:38:47.502
kind of a rotating thing as of right
00:38:47.502 --> 00:38:51.655
now. More information will come. But the
00:38:51.655 --> 00:38:53.275
more information the better that you can
00:38:53.275 --> 00:38:59.556
provide showing what will be done post
00:38:59.556 --> 00:39:01.652
importation and that the good is
00:39:01.652 --> 00:39:06.301
actually used up.
00:39:06.301 --> 00:39:08.708
Define end of life. Give me one second.
00:39:08.708 --> 00:39:19.124
I can go back to that slide. Okay.
00:39:19.124 --> 00:39:20.792
So end of life is just, it's not defined
00:39:20.792 --> 00:39:24.129
by the tariff. I did find a definition.
00:39:24.129 --> 00:39:27.625
It's essentially when a user can no
00:39:27.625 --> 00:39:29.314
longer use it for its intended function.
00:39:29.314 --> 00:39:31.682
If it has any use left for its original
00:39:31.682 --> 00:39:39.828
intended function, then we wouldn't
00:39:39.828 --> 00:39:50.149
consider that at the end of life.
00:39:50.149 --> 00:39:57.077
Give me one second. Is wasted scrap
00:39:57.077 --> 00:39:58.421
processing tracked to evaluate that the
00:39:58.421 --> 00:40:03.946
good is a remanufactured good? That I'm
00:40:03.946 --> 00:40:06.584
not sure. I'm not positive what the
00:40:06.584 --> 00:40:09.250
answer to that would be. I'm assuming,
00:40:09.250 --> 00:40:12.872
in some ways, it can be. That there
00:40:12.872 --> 00:40:22.417
will be-- something with a particular
00:40:22.417 --> 00:40:23.914
company showing that things have reached
00:40:23.914 --> 00:40:26.474
the end of their life, whether that be
00:40:26.474 --> 00:40:28.246
sort of a write out procedure or
00:40:28.246 --> 00:40:32.308
something like that. I don't
00:40:32.308 --> 00:40:35.180
necessarily know. Can't answer that one.
00:40:35.180 --> 00:40:39.547
I apologize.
00:40:39.547 --> 00:40:42.743
Does testing the item post import for
00:40:42.743 --> 00:40:45.515
failure mode prevent it from being
00:40:45.515 --> 00:40:48.954
considered waste? That is a really,
00:40:48.954 --> 00:40:50.513
really good question. I knew I would
00:40:50.513 --> 00:40:56.161
get some good ones since-- again, since
00:40:56.161 --> 00:41:01.113
this is an entirely new heading that we
00:41:01.113 --> 00:41:04.145
haven't had a chance to, I guess, you
00:41:04.145 --> 00:41:12.510
know, beta test with in particular
00:41:12.510 --> 00:41:15.256
situations. All of your questions are
00:41:15.256 --> 00:41:18.687
just as helpfu
00:41:18.687 --> 00:41:20.368
Does testing the item post import for
00:41:20.368 --> 00:41:24.769
failure mode prevent it from being
00:41:24.769 --> 00:41:25.983
considered waste? That's a really good
00:41:25.983 --> 00:41:27.231
question. I would have to look into
00:41:27.231 --> 00:41:28.951
that again a little bit more. I'll get
00:41:28.951 --> 00:41:35.468
to my name-- my contact information in a
00:41:35.468 --> 00:41:37.284
moment. So if you want to email that
00:41:37.284 --> 00:41:39.124
one to me at a later date, I'll try to
00:41:39.124 --> 00:41:40.460
get a better answer for that one. I
00:41:40.460 --> 00:41:43.835
have to really think about that one and
00:41:43.835 --> 00:41:47.487
maybe do a little bit of research.
00:41:47.487 --> 00:41:48.637
Can outdated equipment be classified as
00:41:48.637 --> 00:41:51.351
scrap? I would guess no if it's still
00:41:51.351 --> 00:41:56.411
usable in its current state. Then my
00:41:56.411 --> 00:42:03.328
guess would be at this point would be
00:42:03.328 --> 00:42:04.709
no. But if never made it to the end
00:42:04.709 --> 00:42:08.512
use, scrap is part of the manufacturing
00:42:08.512 --> 00:42:12.533
process. Is it still e-waste or scrap?
00:42:12.533 --> 00:42:17.876
If it is going to be scrapped and not
00:42:17.876 --> 00:42:24.274
usable, I would think ye
00:42:24.274 --> 00:42:29.458
However, if it is coming off the
00:42:29.458 --> 00:42:31.445
manufacturing process and maybe that
00:42:31.445 --> 00:42:32.852
line just got shut down, and they're not
00:42:32.852 --> 00:42:36.408
going to use this particular item for--
00:42:36.408 --> 00:42:40.493
the company's not going to use it for
00:42:40.493 --> 00:42:42.487
that specific use but then gets sold off
00:42:42.487 --> 00:42:43.797
and brought in and we don't know what
00:42:43.797 --> 00:42:45.270
the end use is going to be, I will
00:42:45.270 --> 00:42:52.259
probably say no. But if it's coming in
00:42:52.259 --> 00:42:52.975
unusable to be scrap, then I would think
00:42:52.975 --> 00:42:55.971
yes.
00:42:55.971 --> 00:42:57.155
How will country of origin be determined
00:42:57.155 --> 00:42:58.245
with a mixture of parts that make up the
00:42:58.245 --> 00:43:01.174
cargo load? I was really hoping nobody
00:43:01.174 --> 00:43:02.238
ask that question because I just don't
00:43:02.238 --> 00:43:06.980
know the answer to it. That's a
00:43:06.980 --> 00:43:11.443
conversation for another day, I think.
00:43:11.443 --> 00:43:13.912
There's going to be a lot of-- I have a
00:43:13.912 --> 00:43:18.639
lot of concerns about country of origin.
00:43:18.639 --> 00:43:22.346
I just have not had the chance to dive
00:43:22.346 --> 00:43:26.000
in on how that will be determined. So I
00:43:26.000 --> 00:43:32.115
don't want to give really any indication
00:43:32.115 --> 00:43:38.100
one way or the other right now on the
00:43:38.100 --> 00:43:40.130
off chance that it confuses the issue. I
00:43:40.130 --> 00:43:41.815
don't want to confuse anybody because I
00:43:41.815 --> 00:43:43.877
just don't know the answer to that
00:43:43.877 --> 00:43:47.432
question.
00:43:47.432 --> 00:43:50.275
What implications will this have in the
00:43:50.275 --> 00:43:54.272
exportation process or AES? Numerous
00:43:54.272 --> 00:43:57.514
e-waste recycling facilities, export
00:43:57.514 --> 00:44:01.443
from the U.S.? It shouldn't have, from
00:44:01.443 --> 00:44:09.175
my standpoint, I don't think it will
00:44:09.175 --> 00:44:11.463
have huge implications on the AES
00:44:11.463 --> 00:44:16.016
process. It's something to keep in mind
00:44:16.016 --> 00:44:18.290
as far as, you know, how these things
00:44:18.290 --> 00:44:20.841
are classified going out. But as far as
00:44:20.841 --> 00:44:26.670
from a classification standpoint in my
00:44:26.670 --> 00:44:34.502
ways, it shouldn't have a huge impact,
00:44:34.502 --> 00:44:36.918
just these-- just know that the notes
00:44:36.918 --> 00:44:40.229
that we discussed outside of maybe the
00:44:40.229 --> 00:44:44.785
subheading notes, those are all
00:44:44.785 --> 00:44:46.065
nationally, internationally negotiated.
00:44:46.065 --> 00:44:50.057
So we would be, we're hopefully all
00:44:50.057 --> 00:44:53.078
following, every country is following
00:44:53.078 --> 00:44:54.328
the same rationale for where these
00:44:54.328 --> 00:44:57.446
things are goin
00:44:57.446 --> 00:44:58.356
Again I haven't gotten anything from the
00:44:58.356 --> 00:45:03.877
HSC. So we'll-- it shouldn't have a huge
00:45:03.877 --> 00:45:07.059
impact, I wouldn't think.
00:45:07.059 --> 00:45:08.217
Under the end of life, if the item
00:45:08.217 --> 00:45:10.430
cannot be used in the original function,
00:45:10.430 --> 00:45:12.270
however, is used as something else, is
00:45:12.270 --> 00:45:15.642
that considered scrap? And what would
00:45:15.642 --> 00:45:18.418
be the country of origin? We've
00:45:18.418 --> 00:45:19.823
discussed that. I'm going to ignore the
00:45:19.823 --> 00:45:23.844
fact that you said country of origin
00:45:23.844 --> 00:45:26.064
because, again, that's a tough question
00:45:26.064 --> 00:45:27.895
related to these right now. I just
00:45:27.895 --> 00:45:32.491
don't think now is not the forum to
00:45:32.491 --> 00:45:35.735
really dive into those.
00:45:35.735 --> 00:45:37.918
So though it can't be used for its
00:45:37.918 --> 00:45:41.005
original function, if it is functioning,
00:45:41.005 --> 00:45:42.784
electrically, my opinion at this point
00:45:42.784 --> 00:45:44.468
is that no it could not be scrapped
00:45:44.468 --> 00:45:50.100
because it still has a use. And it's
00:45:50.100 --> 00:45:54.846
not going to be, if you read through the
00:45:54.846 --> 00:45:56.806
subheadings I went through. It really
00:45:56.806 --> 00:45:58.286
seems they're wanting these items to be
00:45:58.286 --> 00:46:00.662
scrapped or disassembled or unusable in
00:46:00.662 --> 00:46:11.083
some way. So using for another
00:46:11.083 --> 00:46:14.048
function, I would think even if it's
00:46:14.048 --> 00:46:15.139
similar or another electrical function,
00:46:15.139 --> 00:46:21.880
I think that would exclude it.
00:46:21.880 --> 00:46:23.097
Would we see over the country who worked
00:46:23.097 --> 00:46:26.005
it into final stage of finished product?
00:46:26.005 --> 00:46:28.418
That is one way, that is one thing that
00:46:28.418 --> 00:46:34.998
I'm considering would be the answer. But
00:46:34.998 --> 00:46:38.113
there are some-- I believe there are
00:46:38.113 --> 00:46:39.490
some different ways to look at waste and
00:46:39.490 --> 00:46:43.048
scrap with origin. I did look through
00:46:43.048 --> 00:46:48.575
some of those. So-- but I didn't want
00:46:48.575 --> 00:46:51.287
to get into them too much here. You
00:46:51.287 --> 00:46:53.159
might be correct. But that's something,
00:46:53.159 --> 00:46:56.028
if you wanted to email me after the
00:46:56.028 --> 00:47:01.111
factor if anybody wanted to have that
00:47:01.111 --> 00:47:04.074
issue in a ruling request, that would be
00:47:04.074 --> 00:47:04.791
helpful so we can kind of get through
00:47:04.791 --> 00:47:07.259
everything.
00:47:07.259 --> 00:47:08.800
How will you be able to tell if it's
00:47:08.800 --> 00:47:10.271
really a scrap shipment? The import
00:47:10.271 --> 00:47:11.678
export say it could be a shipment of
00:47:11.678 --> 00:47:13.545
Chinese goods attempting to avoid
00:47:13.545 --> 00:47:15.606
section 301. What checks will be applied
00:47:15.606 --> 00:47:19.066
to an entry?
00:47:19.066 --> 00:47:21.782
There are a variety of different things
00:47:21.782 --> 00:47:24.342
we can check. Again, the big tell is
00:47:24.342 --> 00:47:28.339
going to be how it's packaged and where
00:47:28.339 --> 00:47:32.610
it's going. You know, if that entire
00:47:32.610 --> 00:47:40.040
part of the process is being
00:47:40.040 --> 00:47:43.221
circumvented, if they're sending it to a
00:47:43.221 --> 00:47:46.873
place that's not technically a recycling
00:47:46.873 --> 00:47:50.794
center or something like that but
00:47:50.794 --> 00:47:54.267
they're still dumping everything in
00:47:54.267 --> 00:47:59.134
mixed shipments, yeah. There are a lot
00:47:59.134 --> 00:48:02.464
of different things we can look at.
00:48:02.464 --> 00:48:05.465
I think-- I'm not specifically sure
00:48:05.465 --> 00:48:07.553
what-- it's going to be a case-by-case
00:48:07.553 --> 00:48:09.929
basis with what we look at. Again, I
00:48:09.929 --> 00:48:12.423
really think one of the most telling
00:48:12.423 --> 00:48:15.855
things is going to be how it is-- is the
00:48:15.855 --> 00:48:18.473
process with which it's been brought in.
00:48:18.473 --> 00:48:21.689
You know, in general, a lot of it is
00:48:21.689 --> 00:48:23.602
going to be just dumped into the back of
00:48:23.602 --> 00:48:32.026
a truck or into crates were either, not
00:48:32.026 --> 00:48:33.152
separated or separated only by material.
00:48:33.152 --> 00:48:35.555
You should be able to tell by invoices,
00:48:35.555 --> 00:48:39.736
things like that.
00:48:39.736 --> 00:48:41.209
Export country be the country of origin.
00:48:41.209 --> 00:48:43.611
I apologize, everyone. I'm not going to
00:48:43.611 --> 00:48:50.754
address the country of origin right now.
00:48:50.754 --> 00:48:52.190
Yeah, please file-- if you want to put a
00:48:52.190 --> 00:48:54.466
ruling together, we can really dig into
00:48:54.466 --> 00:48:57.495
it. Or if we want to have an off line
00:48:57.495 --> 00:49:04.669
conversation, we can do that
00:49:04.669 --> 00:49:10.471
Can you the slide up with the contact
00:49:10.471 --> 00:49:12.441
information? Yes. Apologies. I meant
00:49:12.441 --> 00:49:21.700
to do that just now. Yes, we can
00:49:21.700 --> 00:49:23.763
track-- okay. Yes, that's correct. I
00:49:23.763 --> 00:49:25.818
was going to mention the 301 issues
00:49:25.818 --> 00:49:31.875
here. Most of it is, I think half of it
00:49:31.875 --> 00:49:34.492
is split half and half. 25% or 7.5% in
00:49:34.492 --> 00:49:38.025
the entire heading. So there are define
00:49:38.025 --> 00:49:39.865
firstly some issues with where it's
00:49:39.865 --> 00:49:44.477
coming from. Again, because there's not
00:49:44.477 --> 00:49:45.542
going to be a quote/unquote substantial
00:49:45.542 --> 00:49:47.098
transformation, it's going we're going
00:49:47.098 --> 00:49:48.009
to need to look at in the future. The
00:49:48.009 --> 00:49:53.058
intent of the presentation was more of a
00:49:53.058 --> 00:49:54.530
classification and introduction than to
00:49:54.530 --> 00:49:55.866
really get into-- these are really good
00:49:55.866 --> 00:50:01.610
questions. I really appreciate them.
00:50:01.610 --> 00:50:04.761
And I hope that you got something out of
00:50:04.761 --> 00:50:06.387
that. And if you need anything else,
00:50:06.387 --> 00:50:08.970
here's my contact information as well as
00:50:08.970 --> 00:50:12.249
Howard who is my associate. Reach out
00:50:12.249 --> 00:50:22.387
to one or both of us. Again, any ruling
00:50:22.387 --> 00:50:23.641
request that you feel are necessary, we
00:50:23.641 --> 00:50:28.507
will be happy to examine even the
00:50:28.507 --> 00:50:30.032
country of origin issue, I'll be happy
00:50:30.032 --> 00:50:36.803
to examine it. Again, I'm treading
00:50:36.803 --> 00:50:38.298
lightly with the country of origin
00:50:38.298 --> 00:50:39.860
because I don't want to give false
00:50:39.860 --> 00:50:41.359
information that I haven't really vetted
00:50:41.359 --> 00:50:44.480
yet.
00:50:44.480 --> 00:50:48.503
So yeah, hopefully that makes sense.
00:50:48.503 --> 00:50:52.593
But we're almost at our hour. That's
00:50:52.593 --> 00:50:56.059
all I have. I want to thank everybody.
00:50:56.059 --> 00:50:59.647
And please feel free to reach out if
00:50:59.647 --> 00:51:01.330
you need anything from they. And I
00:51:01.330 --> 00:51:03.205
believe Chrissi has a few things to say
00:51:03.205 --> 00:51:14.948
right at the end.
00:51:14.948 --> 00:51:16.913
>> This concludes our webinar for this
00:51:16.913 --> 00:51:18.288
afternoon. This is a reminder that this
00:51:18.288 --> 00:51:20.334
webinar will be posted on the CBP

00:51:23.061 --> 00:51:23.061
enjoy the rest of your day.