Are primary exporters of hazardous recyclable materials containing precious metals subject to export regulations?
Yes, generators of (hazardous) recyclable materials exported for precious metals recovery are subject to export regulations because they meet the definition of primary exporter ( §262.51) and are required to prepare a manifest in accordance with Part 262 Subpart B (Memo, Lowrance to Linson; February 5, 1991 and Monthly Hotline Report Question; October 1986). Q: Are lab samples imported from abroad subject to importing requirements? A: No, lab samples are conditionally exempt from the Federal hazardous waste regulations including the hazardous waste import regulations if the shipment complies with the sample exclusion in §261.4(d) (Memo, Straus to Rideout; April 27, 1989). Q: Are treatability study samples subject to the export regulations? A: If the generator of the samples meets the requirements of §261.4(e), treatability study samples are exempt from export regulations. The sample must be shipped to a laboratory or testing facility which is exempt under §261.4(f) or has an appropriat
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