SCRAP PROCEDURE

1. SCRAP PROCEDURE Presented by: CASAS International Brokerage, Inc. Wednesday, October 20, 2010

2. AGENDA • Background and effective dates • Procedure • Sample Letters

3. Background • Driven by the US Department of Agriculture in conjunction with US CBP • US CBP had been ordered to modify the process effective October 8, 2010 • Ports affected • Otay Mesa • Tecate • Calexico • Andrade

4. Background-cont. • Imports of Scrap would be allowed to cross any day during BULK cargo hours of operation. • Some of the scrap material being returned was contaminated or had been exposed to food products, contaminated food with larvae, or dead animals. • USDA noted that some shipments contained larvae, fungus, and other contaminants that could navigate to other cargo bound for human consumption at the CBP facilities. • AS a result, USDA took evidence up to the Washington level and immediate authority was given to stop all imports until a valid procedure was established.

5. Procedure • This procedure is only affecting plastic and cardboard scrap imports and requires 3 letters: • Signed letterhead statement from importer of record can be copy. • Signed letterhead statements from the producer/manufacturer must be original signatures • Signed letterhead statements for the hauler/transport company must  be original signatures and must  include the vehicle trailer license number and an approximate total weight of the shipment in kilograms or pounds • This information along with an invoice is sent to your Customs Broker for prefiling and eventual approval. Once authorized, shipment can proceed into US.

6. Letter Declarations • Indicate plastic and cardboard scraps were: • from the generator’s facility • (are) an industry-recognized scrap commodity • not obtained from landfills, recycling centers, or other domestic solid waste • not commingled with garbage as defined in Title 7 Code of Federal Regulations §330.400 - §330.403 and Title 9 Code of Federal Regulations §94.5 • not associated with fruits, vegetables, meats, or other plant or animal (including poultry) materials, AND • (are) clean and free of all soil, dirt, seeds and any other animal and plant products in accordance with Title 7 Code of Federal Regulations §330.300, Title 7 Code of Federal Regulations §330.400 - §330.403 and Title 9 Code of Federal Regulations §94.5.

7. Sample Letter-IMPORTER of Record- COPY OK U.S. Parent Company letter head We, (Name of U.S. Parent Company), have advised the company/companies identified in the enclosed attachments, of the U.S. Department of Agriculture (USDA) Animal and Plant Health Inspection Service requirements for the importation of cardboard and plastic scraps from Mexico. We recognize that shipments of cardboard and plastic scraps accompanied by the certification statements below, would provide enforceable, credible prima facie support that each such load is not garbage, as defined Title 7 Code of Federal Regulations §330.400 - §330.403 and Title 9 Code of Federal Regulations §94.5. These requirements include: Written certification from the producer/manufacturer of the cardboard and plastic scraps, that the material: Was generated at the generator’s facility, Is an industry-recognized scrap commodity, Was not obtained from landfills, recycling centers, or other domestic solid waste, Was not commingled with garbage as defined in Title 7 Code of Federal Regulations §330.400 - §330.403 and Title 9 Code of Federal Regulations §94.5. Was not associated with fruits, vegetables, meats, or other plant or animal (including poultry) materials, AND Is clean and free of all soil, dirt, seeds and any other animal and plant products in accordance with Title 7 Code of Federal Regulations §330.300, Title 7 Code of Federal Regulations§330.400 - §330.403 and Title 9 Code of Federal Regulations §94.5. Written certification from the hauler/transport company that the cardboard and plastic scraps, that the material: Was not obtained from landfills, recycling centers, or other domestic solid waste, Was not commingled with garbage as defined in Title 7 Code of Federal Regulations §330.400 - §330.403 and Title 9 Code of Federal Regulations §94.5. Was not associated with fruits, vegetables, meats, or other plant or animal (including poultry) materials, AND Is clean and free of all soil, dirt, seeds and any other animal and plant products in accordance with Title 7 Code of Federal Regulations §330.300, Title 7 Code of Federal Regulations §330.400 - §330.403 and Title 9 Code of Federal Regulations §94.5. If the shipment has been found to be contaminated with garbage, then the shipment may be refused entry into the United States. ______________________________________ _______________________________ Name of Signatory and Company Title Date Attachments: Certification of Producer/Manufacturer Certification of Hauler/Transport Company

8. Sample Certification of Producer/Manufacturer – Original Copy must be presented By signing this document, we, (name of Producer/Manufacturer Company), agree to comply with the requirements listed in Section 1(a-f) identified above in the (Name of U.S. Parent Company) statement outlining USDA’s entry requirements for cardboard and plastic scraps from Mexico entering the United States. Name of Producer/Manufacturer Company:______________________ Type of scrap: ____________________ Name of Hauling Company: _________________________________ _______________________________ Name of Signatory and Company Title Date NOTE: A copy of the signed U.S. Parent Company statement (cover page) and this Certification of Producer/Manufacturer document should accompany each shipment.

9. Certification of Hauler/Transport Company-Original Copy By signing this document, we, (the Hauler/Transport Company), agree to comply with the requirements listed in Section 2(a-d) identified above in the (Name of U.S. Parent Company) statement outlining USDA’s entry requirements for cardboard and plastic scraps hauled from Mexico returning to the (Name of U.S. Parent Company). We, (the Hauler/Transport Company), also agree to collect cardboard and plastic scraps to be returned to the (Name of U.S. Parent Company) only from the following producer/manufacturer companies identified below, as there companies have agreed to the requirements listed in Section 1(a-f) of the (Name of U.S. Parent Company) statement. Name of Producer/Manufacturer Company: _________________________________ Type of scrap: ­­­­______________ Weight (kg or lbs): ___________ _________________________________ Type of scrap: ­­­­______________ Weight (kg or lbs): ___________ _________________________________ Type of scrap: ­­­­______________ Weight (kg or lbs): ___________ _________________________________ Type of scrap: ­­­­______________ Weight (kg or lbs): ___________ _________________________________ Type of scrap: ­­­­______________ Weight (kg or lbs): ___________ _________________________________ Type of scrap: ­­­­______________ Weight (kg or lbs): ___________ ________________________________ Type of scrap: ­­­­_______________ Weight (kg or lbs): ___________ _________________________________ Type of scrap: ­­­­______________ Weight (kg or lbs): ___________ _________________________________ Type of scrap: ­­­­______________ Weight (kg or lbs): ___________ _________________________________ Type of scrap: ­­­­______________ Weight (kg or lbs): ___________ Name of Hauling Company: ___________________________________ ______________________________________ _______________________________ Name of Signatory of Hauler and Company Title Date Vehicle trailer license number: _________________________ NOTE: A copy of the signed U.S. Parent Company statement (cover page) and this Certification of Hauler/Transport Company document should accompany each shipment.

10. Key Contacts • Work with your broker if you have any pending questions. • Direct questions can be made to US Department of Agriculture • (301) 734-7633 • Monday - Friday from 8:00 am until 4:30 PM (East Coast time)