Import Customs Clearance of Secondary Aluminum: Comprehensive Coverage of Policy Dividends and Practical Key Points

The Popularity of Secondary Aluminum Imports is on the Rise: How Much Do You Know About Customs Clearance?

In recent years, as global attention to sustainable development has continued to increase, secondary aluminum, as an important green and environmentally friendly material, has seen a growing demand for imports. Against the backdrop of China's "dual carbon" strategy, the application of secondary aluminum has become a new consumption trend. According to relevant data, from 2021 to February 2022, cumulative imports reached 3.8742 million mt, up 17.8% YoY. After the implementation of new import regulations, the total import volume in 2022 was significantly higher than before, indicating a rapid rise in popularity. However, the customs clearance process for secondary aluminum imports is relatively complex. Do you understand the ins and outs? Today, let's provide a detailed explanation.

I. Interpretation of the Latest Policies

(I) Refinement of Raw Material Classification

On October 21, 2024, the Ministry of Ecology and Environment, jointly with the General Administration of Customs, the State Administration for Market Regulation, and four other departments, updated and issued Announcement No. 23, making important adjustments to the classification of secondary aluminum raw materials. Previously, importable secondary aluminum raw materials were uniformly classified as "cast aluminum alloy raw materials," but now they are subdivided into three categories: "pure aluminum raw materials," "wrought aluminum alloy raw materials," and "cast aluminum alloy raw materials." This change is significant. Taking wrought aluminum alloy as an example, it is mainly produced through hot or cold working for plastic deformation. Different series of wrought aluminum alloys, such as aluminum-copper and aluminum-manganese series, have unique processing characteristics and application fields. Separate classification can more precisely meet the differentiated needs of various industries for secondary aluminum raw materials, enabling enterprises to more accurately select suitable raw materials based on their production needs during imports.

(II) Relaxation of Import Restrictions

The announcement clearly states that secondary aluminum raw materials that meet the requirements are no longer classified as solid waste during the import process, fundamentally changing the nature of secondary aluminum imports and removing a major obstacle for industry development. Meanwhile, it stipulates that copper and aluminum must not be mixed during imports; they must all be secondary copper or secondary aluminum. Additionally, different categories of raw materials under the copper and aluminum items cannot be mixed in bulk. For example, copper wire nodules and copper pipe & tube cannot be mixed in bulk but can be packaged separately and imported in the same batch. Furthermore, new HS codes for secondary aluminum raw material import declarations have been added, such as multiple codes under Chapter 7602, covering different types of secondary aluminum raw materials, providing clear classification guidance for import declarations and greatly improving the standardization and convenience of the import process.

(III) Adjustment of Inspection Requirements

In the inspection process, the new regulations have brought significant changes. First, sensory inspection is adopted, where customs officers make preliminary judgments on the apparent characteristics, inclusion content, and physical content of aluminum or aluminum alloys in the goods through visual inspection and other methods. For goods whose compliance with standard requirements is unclear, further detection will be conducted based on the inspection methods specified in customs industry technical specifications or national standards, such as "GB/T 38472-2023 Raw Materials for Secondary Cast Aluminum Alloy". This means that if secondary aluminum raw materials show no obvious abnormalities in appearance, such as no excessive impurities and normal color, and are preliminarily judged to meet the standards, they may be exempted from the cumbersome laboratory testing process, greatly simplifying the import process, accelerating customs clearance, and reducing the time and economic costs for enterprises.

II. Analysis of Importable Types of Secondary Aluminum

(I) Pure Aluminum Raw Materials

According to "GB/T 8005.1 Terminology of Aluminum and Aluminum Alloys", metals with an aluminum mass fraction of ≥99% are classified as pure aluminum (commonly known as Series 1). The main forms of import are secondary aluminum ingots or bulk aluminum that is bundled, bagged, or briquetted. Its raw material sources are extensive, including aluminum wire, conductive aluminum sheets, aluminum pipe & tube, aluminum billets, aluminum granules, aluminum cans, pure aluminum utensils, aluminum foil, pure aluminum processing scraps, and geometric scraps. When declaring imports, it is essential to specify details such as the raw material category (ingots, briquettes), raw material source, appearance and dimensional specifications, inclusion content, volatile matter content, total metal content, and aluminum content. In accordance with "SN/T 5762-2024 Inspection Procedures for Imported Secondary Pure Aluminum Raw Materials", the key aspects to be detected during the import of pure aluminum include radioactive contamination, inclusion content, and the physical content of aluminum and aluminum alloys. Among them, the total metal content in pure aluminum products should be ≥91%, with aluminum accounting for ≥99.5% of the total metal content. There should be no obvious non-metallic impurities or volatile substances such as oil stains, and inclusions should be ≤0.8%.

(II) Wrought Aluminum Alloy Raw Materials

Wrought aluminum alloys are mainly produced through plastic deformation via hot or cold working, such as aluminum-copper series (Series 2), aluminum-manganese series (Series 3), etc. (commonly known as wrought aluminum). Imports are also primarily in the form of aluminum ingots and bulk aluminum. However, due to their relatively low aluminum content purity, they are prone to carrying various impurities, such as copper inside aluminum pipes, paint on the surface, screws, copper pipes, circuit boards, plastic and glass, iron objects, adhesive films, non-metallic substances, sediment, and oil stains. According to current import requirements, these non-aluminum alloy substances are temporarily not allowed. The raw material sources are abundant, including extrusion scraps, sheet processing scraps, aluminum sheets, aluminum strips, processing scraps, forged aluminum wheel hubs, aircraft aluminum sheets, various aluminum utensils, aluminum wire, aluminum compacted briquettes, door and window aluminum semis, aluminum foil, etc. For such wrought aluminum alloys, the physical content of aluminum and aluminum alloys should be ≥91%, and inclusions should be ≤0.8%.

(III) Raw Materials for Cast Aluminum Alloy

Cast aluminum alloy is mainly used to produce casting products through methods such as casting or die-casting, including aluminum pistons, aluminum castings, etc. (commonly known as aluminum tense scrap). It typically comes in forms such as aluminum ingots, aluminum blocks, and aluminum shavings. According to the "GB/T 13586-2021 Recycled Aluminum" standard, its sources include aluminum pistons, aluminum castings, cast wheels, milled aluminum shavings, aluminum scrap, aluminum dross, etc. In terms of import detection, according to the "SN/T 5418-2024 Inspection Procedures for Imported Secondary Cast Aluminum Alloy Raw Materials", the total metal content should be ≥97%, the aluminum and aluminum alloy content should be ≥91%, and the inclusion content should be ≤0.8%.

III. Detailed Explanation of Customs Clearance Process

(I) Preliminary Preparation

Before initiating the import business of secondary aluminum, it is essential to fully understand China's latest import policies, regulations, and standards. This can be done by checking official websites such as the General Administration of Customs and the Ministry of Ecology and Environment to ensure that import activities are legal and compliant. Selecting a supplier with a good reputation and stable product quality is crucial. It is recommended to conduct a field trip to the supplier's production and processing environment, quality control system, review their past product inspection reports, and customer evaluations to ensure the quality of the goods. Special attention should be paid to conducting an aluminum content test on the secondary aluminum before shipment from abroad to understand in advance whether the goods meet China's import standards, avoiding detention or return due to non-compliance with aluminum content standards upon arrival at the port, which would increase costs and time losses.

(II) Document Preparation

A series of key documents are required for importing secondary aluminum. The contract should specify the rights and obligations of both parties in detail, covering core clauses such as the name, specifications, quantity, price, delivery method, and payment method of the goods. The invoice should accurately reflect the value of the goods. The packing list should clearly list information such as the packaging, number of pieces, and weight of the goods. The B/L is an important document for cargo pick-up. The certificate of origin is used to determine tariffs, and its authenticity and accuracy must be ensured. The quality certificate is indispensable and should include detailed information such as the supplier's name, raw material name, net weight, volatile matter content, inclusion content, aluminum and aluminum alloy content, total metal content, metal recovery rate, inspection results, the inspection stamp of the supplier's quality supervision department, and the standard number, providing a strong basis for customs review.

(III) Customs Declaration and Inspection

After the goods arrive at the destination port in China, the importer must declare to the customs within the specified time, generally within 14 days from the date of the vessel's declaration for entry. During the declaration, various prepared documents should be submitted through the international trade "Single Window", and the customs will review the documents. Subsequently, the customs will most likely inspect the goods, including verifying whether the name, specifications, quantity, weight, and other information of the goods are in line with the documents, checking whether the appearance quality meets the requirements, such as whether the surface is clean, whether there are serious flash or pores, and using professional equipment to detect whether the inclusion content, aluminum and aluminum alloy content, and other indicators meet the standards. If the customs has doubts about the quality of the goods, it may also take samples and send them to a professional laboratory for detection. The importer must actively cooperate to ensure the smooth progress of the inspection.

(IV) Tax Payment

Importing secondary aluminum requires the payment of tariffs and VAT. The taxes are calculated based on the dutiable value of the goods and the applicable tax rates. The dutiable value is usually based on the transaction price of the goods, which is reviewed by the customs in accordance with the law. Different types of secondary aluminum raw materials are subject to different declaration codes and tax rates. Common examples include 7602000020 - importable secondary cast aluminum alloy raw materials (aluminum ingots, scraps) that meet the standard requirements of GB/T 38472 (provisional tariff: 0, most-favored-nation tariff: 1.5%, VAT rate: 13%); 7602000040 - importable secondary pure aluminum raw materials, etc. The importer should, based on the tax bill issued by the customs, complete the tax payment within the specified time limit, usually within 15 days, through electronic payment or other means to avoid late fees and disruptions to the cargo pick-up process.

(V) Follow-up Supervision

After picking up the goods, the importer is not yet "off the hook" and still needs to accept follow-up supervision in accordance with China's relevant regulations. Within the specified time, the importer may need to cooperate with the customs and inspection and quarantine departments in verifying the use and flow of the goods to ensure that the secondary aluminum is used in legal and compliant production and processing fields, and to avoid irregular resale or unauthorized changes in use. If any issues are found during follow-up supervision, the enterprise will face penalties such as warnings, fines, orders for rectification, or even suspension of import qualifications. Therefore, it is essential to strictly implement the supervision requirements to ensure the standardization of the entire process of importing secondary aluminum.

IV. Case Sharing and Answers to Common Questions

(I) Review of Successful Cases

A well-known aluminum products processing enterprise planned to import a batch of secondary cast aluminum alloy raw materials from Malaysia for producing high-quality aluminum alloy castings. Before importing, the enterprise's procurement team conducted in-depth research on China's import policies and communicated repeatedly with the supplier to ensure that the raw materials met the standard requirements of "GB/T 38472 - 2023 Secondary Cast Aluminum Alloy Raw Materials," with indicators such as aluminum and aluminum alloy content, total metal content, and inclusion content all meeting the standards. At the same time, the enterprise prepared complete and accurate documents in advance, including a quality certificate that detailed the origin of the raw materials and the composition test report. After the goods arrived at the port, the customs broker promptly declared them to the customs. During the customs inspection, the enterprise actively cooperated, displaying the packaging and labeling of the goods on site, and providing relevant technical data to explain the production process. Due to thorough preparations, the customs found no issues during the document review and goods inspection, and the goods were smoothly released. The enterprise picked up the goods on time and put them into production, seizing the market opportunity.

(II) Q&A on Typical Issues

The key lies in ensuring that the imported secondary aluminum strictly complies with relevant standards in China. Firstly, the composition of the raw material should meet the standards. For example, for secondary cast aluminum alloy raw materials, the total metal content should be ≥97%, the aluminum and aluminum alloy content should be ≥91%, and the inclusions should be ≤0.8%. Secondly, there should be no obvious abnormalities in appearance, such as excessive impurities, flash, or pores. Furthermore, quality detection should be conducted in advance, and an authoritative detection report should be obtained and submitted together during customs declaration as strong evidence of the goods' compliance. If there is uncertainty about the standards, professional customs declaration agencies or relevant customs departments can be consulted before importation.

For different types of secondary aluminum raw materials, the detection methods and requirements vary. For pure aluminum raw materials, in accordance with the "SN/T 5762 - 2024 Inspection Procedures for Imported Secondary Pure Aluminum Raw Materials", the focus should be on detecting radioactive contamination, inclusion content, and the physical content of aluminum and aluminum alloys. The total metal content should be ≥91%, and within the total metal content, the aluminum component should be ≥99.5%. For wrought aluminum alloy raw materials, the physical content of aluminum and aluminum alloys should be ≥91%, and the inclusions should be ≤0.8%. Attention should also be paid to the impurities they carry, and currently, non-aluminum alloy impurities are temporarily not allowed. For cast aluminum alloy raw materials, according to the "SN/T 5418 - 2024 Inspection Procedures for Imported Secondary Cast Aluminum Alloy Raw Materials", the total metal content should be ≥97%, the aluminum and aluminum alloy content should be ≥91%, and the inclusions should be ≤0.8%. It is recommended to entrust professional third-party detection institutions for the detection work, as their reports are more credible and can provide effective support for import customs clearance.

In terms of packaging, the outer surface of the packaging should be attached with a label containing information such as the raw material name, size specifications, gross weight, net weight, total metal content, and the number of this standard, so that customs can quickly understand the basic situation of the goods. Regarding specifications, although customs do not have mandatory requirements for the shape of secondary aluminum imports, to facilitate inspection and transportation, it is advisable to ensure that the specifications of goods in the same batch are relatively similar. For example, the size and weight of aluminum ingots should be as uniform as possible to avoid inconsistencies that may cause problems during loading, unloading, and inspection, affecting customs clearance efficiency.

When conducting physicochemical analysis and detection, customs will test key indicators of secondary aluminum, such as radioactive contamination, inclusion content, aluminum and aluminum alloy content, and total metal content, in accordance with relevant national standards and industry specifications. Impurities such as paint and oil stains can significantly impact detection results. On one hand, they may obscure the true appearance characteristics of aluminum and aluminum alloys, interfering with the visual judgment of customs officers. On the other hand, during laboratory testing, they may affect the accuracy of chemical analysis, leading to misjudgments of indicators such as aluminum content and inclusion content. Therefore, before importing, efforts should be made to ensure that the surface of secondary aluminum is clean and free from excessive paint and oil stains. If there are a small amount of impurities, they should be declared in advance and a treatment plan provided.

Indeed, due to the special nature of secondary aluminum, customs has a relatively high inspection probability and sending samples for testing is also common to ensure that the goods meet the standards. Enterprises should first ensure that their documents are complete and accurate, truthfully declaring cargo information, including the source of raw materials, processing technology, and composition content. Secondly, they should strictly standardize cargo packaging and labeling to facilitate customs inspection. Furthermore, if customs inspection is encountered, enterprises should actively cooperate and promptly provide the required documents, such as quality inspection reports and production process descriptions, and patiently answer any questions raised by customs. If the goods are sent for testing, maintain communication with customs and testing institutions, follow up on the testing progress, so as to pick up the goods as soon as possible after passing the test and reduce delays and losses.

V. Industry Outlook

Against the backdrop of the "dual carbon" strategy, China's demand for secondary aluminum is showing a continuous growth trend. On one hand, aluminum processing enterprises are increasingly inclined to use secondary aluminum as a raw material to reduce carbon emissions and save costs. On the other hand, the rapid development of high-end manufacturing industries such as new energy vehicles and aerospace has also led to a growing demand for high-grade secondary aluminum. According to relevant forecasts, the market size of secondary aluminum in China is expected to further expand in the coming years. For enterprises importing secondary aluminum, this is undoubtedly a rare development opportunity. However, opportunities always coexist with challenges. Only by deeply understanding import policies, strictly controlling customs clearance processes, and ensuring that the quality of goods complies with regulations, can enterprises seize the initiative in the fierce market competition, achieve sustainable development, and contribute to the development of China's green aluminum industry.