Full Process Analysis of 2026 Recycled Steel Import Agency Services and Key Compliance Points

I.2026 Recycled Steel Import Market Background and Core Challenges

In 2026,China’s carbon peaking process enters a critical stage,and the emission reduction pressure on the iron and steel industry continues to increase.As the core raw material for short-process steelmaking,the import volume of recycled steel has increased by more than 40% compared with the same period in 2025,and the main sources are concentrated in developed economies such as Europe,the US and Japan.These regions have mature scrap steel recycling systems and advanced sorting technologies,but their export policies are becoming increasingly strict.In particular,the EU’s new 2026 Waste Shipment Regulation lists recycled metals in the key monitoring list.The primary difficulty faced by domestic enterprises is the significant increase in environmental access thresholds.The Ministry of Ecology and Environment (MEE) implements a "three mandatory inspections" mechanism for the radioactivity,inclusions and environmental approval of imported recycled steel,and the detention rate of single shipments caused by document discrepancies or test exceeding standards has increased by 15% year-on-year.Secondly,port supervision authorities have strengthened the verification of price authenticity,and the difference between customs valuation and commercial contracts has become a high risk point for tax difference recovery.In addition,recycled steel is a commodity subject to statutory inspection,and the consistency verification of goods in the commodity inspection link is extremely strict.If quality non-conformity is found after the goods arrive at the port,enterprises will face huge losses from return shipment or destruction.

II.Zhongshen’s Position in the Recycled Steel Import Chain

Zhongshen has been undertaking recycled metal import business since 2006,and has handled more than 3,000 batches of recycled steel customs clearance from Europe,the US and Japan.As a full-process agent,Zhongshen is not a simple customs broker,but a risk control center covering the front,middle and back ends of the supply chain.At the front end,the agency team directly connects with overseas suppliers and pre-audits the Pre-shipment Inspection Certificate (CCIC) to ensure that the matching rate between test data and domestic standards reaches more than 95%.At the middle end,the customs declaration and inspection teams implement parallel operation,cutting the waiting time in the traditional serial process by 60%.At the back end,Zhongshen assists enterprises in establishing environmental protection ledgers to respond to follow-up supervision and inspection by ecological and environmental authorities.This deeply embedded mode allows customers to focus on production scheduling and market sales,and completely outsource compliance risks and operational complexity.

III.Phased Disassembly of the Full Process of Recycled Steel Import

1.Document Pre-audit: Pre-checkpoint for Environmental Approval and Quality Certification

The first threshold for recycled steel import is the Import License for Restricted Importable Solid Wastes Usable as Raw Materials issued by the MEE,referred to as environmental approval for short.In 2026,the approval application window is shortened to once per quarter,and enterprises need to submit materials 45 working days in advance.Zhongshen’s intervention at this stage includes: assisting customers in preparing 12 basic documents such as scrap steel source certificates,overseas supplier registration certificates,and quality test reports; pre-evaluating key indicators in the test reports,especially whether the radionuclide specific activity is lower than the national standard limit of 0.5 Bq/g,and whether the inclusion weight ratio is controlled within 1.5%.A Zhejiang-based enterprise once had its approval application rejected because the test report did not indicate the radioactivity detection method.Zhongshen coordinated with overseas laboratories to supplement the methodological statement and completed the correction 72 hours before the window closed.

In addition to the approval,the Pre-shipment Inspection Certificate (CCIC) is another core document.Zhongshen requires overseas suppliers to provide CCIC certificate templates that meet the requirements of China Customs,and focuses on verifying whether the cargo description is accurate to the specific subheading under HS Code 7204 for ferrous waste and scrap,and whether the inspection date is within 7 days before shipment.The document pre-audit stage usually takes 5-7 working days,and Zhongshen controls the document discrepancy rate below 3% through a standardized verification checklist.

2.Port Customs Declaration: Technical Points of HS Code Classification and Price Declaration

The core technical difficulty of recycled steel customs declaration lies in the accurate classification of HS codes.In 2026,the customs has more detailed differentiation standards between 7204.41 (other alloy steel waste and scrap) and 7204.49 (other waste and scrap),which are judged based on the proportions of chromium,nickel and molybdenum in the alloy element content test report.Zhongshen’s customs declaration team will confirm the classification code in advance according to the heat number analysis report provided by overseas suppliers before the goods arrive at the port,so as to avoid document amendment and port detention caused by classification errors.In terms of price declaration,the customs implements dynamic price monitoring for recycled steel.Zhongshen updates the FOB price database of major ports in Europe,the US and Japan every month to ensure that the declared price is within a reasonable range.For long-term agreement customers,Zhongshen assists in applying for customs price pre-ruling,extending the price risk lock period to 90 days.

Another key point in the customs declaration link is the calculation of customs duty and value-added tax (VAT).The import duty for recycled steel is 0%,while the VAT rate is 13%.Zhongshen strictly distinguishes between payment for goods and freight during declaration,so as to avoid overpayment of taxes caused by including international freight in the dutiable value.For businesses settled by letter of credit (L/C),Zhongshen will check the consistency between L/C terms and the customs declaration form,especially whether the price term is FOB or CIF,to prevent foreign exchange settlement obstacles caused by term confusion.

3.Commodity Inspection: Dual Standards for Radioactivity Detection and Inclusion Control

Commodity inspection is the highest risk link for recycled steel import.In 2026,the "solid waste attribute identification" special campaign jointly carried out by the customs and the MEE has increased the on-site unboxing rate to 30%.Zhongshen’s response strategies at this stage include: submitting cargo photos and video materials to the port commodity inspection department in advance to apply for priority inspection; arranging special personnel to cooperate with unboxing on site,and immediately applying for re-test for suspected over-standard samples.Radioactivity detection adopts two-level confirmation of portable γ spectrometer and laboratory energy spectrum analysis.Zhongshen requires overseas suppliers to provide the γ dose rate background value before shipment as the comparison benchmark after the goods arrive at the port.

Inclusion inspection is another major difficulty.The national standard GB 16487.7 has clear limits for impurities such as wood waste,waste plastic and waste rubber.Zhongshen requires suppliers to provide sorting process videos before shipment to prove the implementation of the three processes of magnetic separation,winnowing and manual sorting.After the goods arrive at the port,if the commodity inspection judges that the inclusions exceed the standard,Zhongshen will launch an emergency sorting plan,coordinate the port sorting site and temporary workforce,and implement on-site sorting under customs supervision to avoid the return of the whole batch.In March 2026,a 200-ton batch of recycled steel from the US of Mr.Zheng’s company was detected with 2.1% inclusions.Zhongshen carried out 48 hours of emergency sorting to reduce the impurity rate to 1.3%,and the goods were released after passing the secondary commodity inspection,saving nearly RMB 800,000 of return loss for the customer.

4.Follow-up Supervision: Tracking Management of Environmental Protection Ledger and Usage Flow

Cargo clearance is not the end.The MEE requires import enterprises to submit the Imported Solid Waste Usage Report within 30 days after the recycled steel is fed into the furnace for production,recording the heat number,feeding volume and output steel billet volume in detail.Zhongshen assists customers in establishing electronic ledgers,associating customs declaration forms,commodity inspection certificates,warehouse receipts and production feeding records to form a closed-loop evidence chain.For on-site inspections by environmental protection authorities,Zhongshen provides rehearsal services and simulates the inspection process to ensure that the on-site management of enterprises meets the standards.Since 2026,some pilot regions require recycled steel import enterprises to install video monitoring.Zhongshen can recommend equipment suppliers that meet environmental protection networking requirements and assist in completing data interface debugging.

IV.Actual Case: Mr.Zheng’s Company’s Import Dilemma and Solution

Mr.Zheng runs a precision casting enterprise in Jiangsu.In early 2026,he planned to import 1,500 tons of recycled steel from Japan for auto parts production.During the first self-declaration,the waste description in the environmental approval application was too general,and the MEE required three corrections,delaying the construction period by two months.After the goods arrived at the port,they were detained for inspection by the commodity inspection authority because the CCIC certificate did not indicate the radioactivity detection points,resulting in a container detention fee of RMB 3,000 per day.After Mr.Zheng entrusted Zhongshen to intervene,the agency team first carried out traceability analysis on historical documents,and found that the test report of the Japanese supplier lacked the "non-radioactive substance declaration",a new requirement added in 2026.Zhongshen coordinated with the cooperative laboratory in Japan to supplement the declaration document and re-applied for expedited environmental approval.In the customs declaration link,the HS code and price were locked through the pre-ruling mechanism,shortening the customs clearance time from the average 14 days to 5 days.In the commodity inspection stage,Zhongshen submitted photos of the layered stacking of goods in advance to prove the uniform form of the goods,and successfully applied for exemption from unboxing inspection.The whole batch of business was finally delayed by only 7 days compared with the original plan,60 days shorter than Mr.Zheng’s independent operation,directly saving more than RMB 500,000 in port detention fees and capital occupation costs.

V.Core Value of Professional Agency: Triple Balance of Efficiency,Cost and Risk

The value of professional agency for recycled steel import is reflected in integrating scattered compliance requirements into standardized service modules.Through 20 years of data accumulation,Zhongshen has established a qualification database covering 30 core suppliers in Europe,the US and Japan,and can complete the preliminary compliance screening of suppliers within 24 hours.In terms of cost control,the agency service adopts the "basic fee + risk reserve" mode.The basic fee covers routine customs declaration and inspection,and the risk reserve is used to deal with abnormal expenses such as sudden commodity inspection and sorting,so customers do not need to bear unforeseen expenses.In terms of risk control,Zhongshen purchases import cargo insurance for each batch of business,and includes the solid waste attribute identification fee into the service package,so as to avoid customers paying extra fees due to unqualified identification.

The tightening of recycled steel import policies in 2026 is a long-term trend,and the cost-benefit ratio of enterprises building their own customs teams continues to decline.Zhongshen provides not only operational services,but also decision support based on industry know-how.For example,in the procurement link,the agency team can recommend customers to choose Shanghai,Ningbo or Nansha Port as the port of entry according to the commodity inspection strictness of different ports; in the contract term design link,it assists in embedding the claim clause for quality non-conformity and pre-shipment inspection right to reduce risks from the source.This deep value embedding makes professional agencies an indispensable link in the recycled steel import supply chain.

• During the document pre-audit stage,focus on verifying the matching between the validity period of the environmental approval and the cargo quantity to avoid certificate invalidation caused by excess import volume
• A detailed heat number composition analysis report must be provided during the customs declaration stage as the technical basis for HS code classification
• Proactively submit the pre-shipment sorting process video during commodity inspection to reduce the probability of unboxing inspection
• For follow-up supervision,establish the correspondence between customs declaration number and production feeding records to ensure the traceability of the environmental protection ledger
• When selecting agency services,verify whether it has actual performance in recycled metal import,rather than general general cargo customs declaration experience