We wish to express our sincere gratitude to YB Dato’ Sri and respected officers from Department of Environment – YBrs Dr. Nagulendran a/l Kangayatkarasu, Deputy Secretary General; YBrs. Pn. Norlin binti Jaafar, Director General; and En. Norazizi bin Adinan, Director of Kedah State for spending time with us amid their busy schedules. 

We would also like to take this opportunity to express our utmost appreciation to YAB Tuan Haji Muhammad Sanusi bin Md Nor, Chief Minister of Kedah; YB. Dato’ Wira Dr. Ku Abd Rahman bin Ku Ismail, Chairman of the Kedah Industry & Investment, Science Technology & Innovation and Higher Education Committee; and En. Noor Ikhsan bin Abdul Aziz, Chief Operating Officer of Invest Kedah for their undivided support in the development of non-ferrous metals industry.

It was an enjoyable meeting that we were encouraged to highlight industrial grievances on Proposed Guidelines for Importation & Inspection of Metal Scrap.  This is the session that our voices are being heard without further elaboration that had shed some light for our industrial sustainable development.  Our pursuit to further strengthen non-ferrous metal supply chain for the benefit of downstream manufacturing operators across diverse industries is now made possible.

Conversing with right person is always effortless when recipient can diagnose at different height in a practical and holistic manner.  ‘There is no perfection in this world’ do not need any further amplification.  Our Minister, YB Dato’ Sri and Dr. Nagulendran fully acknowledged the nature of metal scraps and the need of tolerance for hazardous waste.  However, such % got to be capped at a limit to safeguard our environment and 0.3% in previous guideline might turn up to be a good reference point.  This is in fact a demonstration of the spirit of Basel Convention in recognition of nature of metal scraps and allowance of certain magnitude to the extent that it would not cause hazardous to the environment. 

In addition, the pre & post shipment inspection was discussed from the perspective of economic feasibility and international best practices.  The imposition of inspection cost and 94.75% metallurgical content to limit majority of non-ferrous metal scraps from importation would be catastrophic for survival of individual upstream entity that at macro level would further dampen our manufacturing base and international competitiveness.

With the blessing from our Minister, Dr. Nagulendran will bring this matter to Ministry of International Trade and Industry (MITI) and a technical meeting (if necessary) will be arranged including the evaluation of this Proposed Guidelines against previous Importation Guidelines released by Department of Environment in January 2020. 

Dear members and associates, we trust after this meeting, the Proposed Guidelines would not be just implemented without a revision copy made available to the industry and without provision of necessary grace period.  We are confident that it will be a visionary and practical Guidelines to the industry. Certainly, all of us would have agreed that our industry needs to be regulated to ensure its healthy growth and environmental aspect must be taken with due care.

Let us stay safe and we will update from time to time.  Thank you.