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Alert for U.S. Exporters to Canada

U.S. Exporters of Hazardous Waste to Canada Whose Consents Expire by June 30, 2018, or Those Wishing to Obtain New Consent, Need to Submit Export Notices to EPA by March 30, 2018.

Environment and Climate Change Canada (ECCC) is planning the launch of its new notice processing system (i.e., their WIETS equivalent system) on June 5, 2018. ECCC has informed EPA that they will not accept U.S. export notices from EPA after April 20. U.S. export notices that cannot be forwarded to ECCC by April 20 will have to be re-transmitted to ECCC after their new system has launched on June 5. U.S. exporters therefore need to submit any export notice proposing Canadian recycling or disposal to EPA by March 30 to provide time for review and error resolution prior to EPA notice transmittal to ECCC. However, please note that Canadian importers and exporters have a different deadline to submit notices to ECCC on their side, as shown in ECCC’s online message to Canadian industry here.  It is the March 30 deadline to submit notices to EPA for exports to Canada that is relevant to you. Exporters that do not wish to renew consents expiring by June 30, 2018, and exporters that have already submitted renewal notices, please disregard this alert.

We encourage all exporters proposing Canadian recycling or disposal to do the following prior to submitting their notice to EPA in WIETS:

  1. Closely coordinate notice content with your Canadian receiving facility to ensure that the Canadian import notice and U.S. export notice entries match. ECCC will not consent to notices if the entries do not match exactly.
  2. Get the Canadian import notice number from your Canadian receiving facility and list it as the ‘foreign notice number” in your export notice. Doing so will facilitate ECCC’s review process.
  3. Do not list a commodity code number (i.e., U.S. Schedule B code, U.S. Harmonized Tariff Schedule or HTS code) in your export notice. Canada does NOT want to see it in the U.S. notice.
  4. Prioritize which notices are most critical to obtain consent by May 25, and submit those notices to EPA first.

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