With his vast knowledge and years of experience, Uladzimir Boltach, Director of Auto Salvage International and former UK and European Director at Autoparts Ltd, discusses the preparations required for the smooth running of used car parts exportation.
Being involved in the export of used car parts for over 15 years provided me with an opportunity to gain valuable experience in dealing with various complicated situations effectively. Working with the suppliers in the UK and other countries in Europe and the world, Environment Agency domestically and abroad, learning about customs requirements, good paperwork practices and global logistics networks broadened my understanding of the international trade in used car parts. You could encounter various scenarios that could hinder your export ability, and of which, could lead to serious implications.
I would like to share my recent experience of exporting used car parts from the UK to Eastern Europe, which I believe will help other businesses in the UK to be better prepared when exporting abroad. I was part of Autoparts then, a Belarus-based importer of used car parts from the UK.
This particular example occurred just before the New Year last year. When shipping a load out from SYNETIQ, an IAA company and the UK’s leading vehicle recycling and dismantling company, nothing led me to believe that we would have any issues in the transportation from the UK through Europe to its final destination in Minsk – such a route was usual.
The shipment was loaded as per normal procedure with over 2,000 units of used car parts, including engine and gearboxes, all the required paperwork was prepared and signed off under the professional guidance of Anastasia (Autopart’s Head of Foreign activity department), and the load departed without any unexpected delays.
Everything went well at the UK customs with the EU. The wagon went on to the ferry, which took it from Dover to Calais. The truck almost reached the EU and Belarus border when it was stopped by the Polish equivalent of the UK Driver and Vehicle Standards Agency (DVSA or VOSA as it used to be called before) near the city of Poznan for a routine check on 20 December 2021.
When it was stopped, the driver was questioned as to what he was carrying and was requested to open the trailer to check. The driver explained that he was carrying used car parts and had all the required documentation.
However, due to loose items in the back of the trailer packed by the Autoparts team, the inspecting officer saw the load as waste materials, not reused car parts. The car parts which were packaged were fine (the images shown were actually made by the representative of the Polish DVSA).
The trailer was further inspected by the Polish Environment Agency, where it was escorted to the quarantine area.
At that point, I contacted Ray Curry, SYNETIQ’s Operations Director and Chas Ambrose from the VRA, to inform them about the incident and asked them to provide supporting letters so that Polish authorities could release the goods. Ray and Chas’s supporting letters were very valuable; their statements confirmed that the load consisted of used car parts, not waste. Both statements were forwarded to the Polish authorities.
All the issues raised by Polish DVSA were communicated and passed to the transport company (driver of the trailer) rather than us as the buyer of the goods – this caused delays. Therefore, we took over all communication with the Polish DVSA, so they dealt with us directly to protect all parties involved.
Following this experience, my advice would be to always communicate with your haulage provider when such issues arise and don’t let the haulage company deal with it on their own. If we left it to the haulage company, the goods would most likely have been deemed as waste, even though all the rules and regulations of the Environment Agency in England were followed to extract the waste in England at a fully licensed facility and only reusable used car parts were exported.
As it was so close to Christmas and New Year, we didn’t hear anything back from the Poznan authorities until 5 January 2022, when the first correspondence was received expressing their view that the entire shipment seemed to be waste. This decision was made only on a brief check of the shipment; no thorough examination was made. Once we heard the news, we decided to find a local lawyer who could represent us in dealing with this matter and provide legal advice in Poland.
It took Anastasia (Autopart’s Head of Foreign Activity Department) a week to find a lawyer who could deal with the matter, and who had the required qualifications and skills. Under her professional guidance, the lawyer contacted the Poznan branch of the Environment Agency of Poland who dealt with the matter and found out that the local branch had to forward the case to the Polish EA head office in Warsaw; this is where the final decision on this matter had to be made.
Without notifying us, the Polish authorities in Warsaw contacted the Environment Agency in England (more specifically – the Repatriations, International Waste Shipments team) and asked for their opinion on the shipment. This is when, on 24 January 2022, SYNETIQ was contacted by the EA via email with the repatriation forms for completion even though the decision to repatriate goods hadn’t been made at that point in time, and we, as a buyer of the goods, was still dealing with the matter.
Ray Curry, Operations Director at SYNETIQ, contacted me to explain they had been asked to repatriate the used car parts, now incorrectly identified as waste, from Poland back to the UK.
This was the first time in 15 years of my career I have had to deal with such a matter. I was as astonished, as was Ray, when he received the email, and we knew straight away we had to act fast to prove that the used car parts in the shipment were not waste but re-usable and in good order.
Ray offered valuable input by providing a professional consultation on how to proceed in the matter further with all the years of experience he has amassed in the industry. He suggested to me to contact the representative of the Environment Agency in England directly and explain everything we do in more detail so correct conclusions could be established.
Following Ray’s advice, I contacted the EA representative of the waste repatriation team to find out how we could help them to make the right decision. I was asked to provide additional information so the EA in England could form their opinion on this matter. Information such as:
- Explain how the parts are assessed and deemed suitable for direct reuse without the need for further treatment or repair.
- Images of loading showing how many of the parts were packaged properly to prevent damage and allow their re-use.
- Anything else that I thought would help the EA in England to come to a decision that these parts are not waste.
For clarity, the Polish authority did not request repatriation and only asked the EA in England to give their opinion on how to classify the load, waste or used car parts to be re-used. The Environment Agency in England started this process as this was a standard procedure they normally follow.
Here, I would like to point out that it is very important to have a good business relationship with your export buyers and work closely on rectifying issues. Good teamwork is integral not only within the business but with outside companies and contractors as well – especially when dealing with such complex matters.
Autoparts has always had good working relationships with the suppliers and strives to follow all the good examples set by the industry leaders to continually improve packaging, loading and paperwork practices. Every member of the company works hard to ensure full compliance is achieved when exporting used car parts from abroad. I was part of a great team back then and knew that we had a solid foundation to show that the used car parts on that shipment were in good condition allowing their re-use.
I, together with Anastasia, gathered all the data I was asked from the EA and more. This is what was provided to the EA in England:
- A separate PDF file with all the images of the loading process from start to finish. This is a normal practice for Autoparts as it speeds up customs checks at the EU border when such are
- The packing list, including loading reference numbers with the quantity of parts loaded on the shipment in question.
- A statement was provided to explain why not all the wheels, suspension components (axles, springs, etc.) and exhaust systems were packaged.
Basically, the statement said that due to the overall size of the car parts in question, not only was it impractical to package them but using excessive single-use plastic packaging harms the environment. Moreover, if we were to package every component, instead of one lorry taking the goods in question, we would most likely need two lorries to transport used car parts. We always strive to optimise our processes to be more carbon neutral, and we believe the fewer trips we do, the better for the environment.
- Autoparts company profile with images of the warehouse, the team, head office, etc., to prove it is a legitimate business selling used car parts.
- Links to the videos of the engine assessments which are done to each vehicle that is dismantled for car parts on every shipment sent from the UK.
Once the EA representative in England received all the information, they advised the Polish authorities that, as far as the EA in England was concerned, the items on our load were no longer waste. That meant if the Belarus authority were in agreement, which they were, then the EA in England would allow the load to continue. Thus, the load which was about to be repatriated was released the following week.
What are the main points learned from this experience?
You must communicate effectively with all parties involved, and avoid long delays when providing the required information. Be proactive, open and honest in your approach, as most people will help and do their best when asked. The EA in England, SYNETIQ and Ray Curry, in particular, VRA and Chas Ambrose, all have valuable input to make sure the correct decision was made by Polish authorities.
Any company exporting goods can find itself in such circumstances where an individual opinion can significantly impact the business. To protect your business from such situations, I have summarised the main points following my consultation with all the parties involved and the EA in England in particular:
- Regarding the issue of provenance, you must be able to prove that all the parts being exported have been purchased legitimately with a clear audit trail, whether it was a vehicle purchased for dismantling or parts bought individually or in bulk. Your paperwork has to be in good order (invoices, export declarations, etc.), so it can be produced for relevant authorities whenever requested.
- The car parts must be fit for reuse without any further repair; it must be certain that they are to be used for their original intended purpose, and they are handled and stored in a manner to ensure they are not damaged. Good loading practices are so important so that when your shipment is inspected abroad, no questions are raised about the re-use of car parts.
- They should be assessed to determine functionality, quality and condition. Quality checks are important, so it is advisable to double-check parts for damage before loading.
- How they are stored and packed during transport will also indicate if they are non-waste. So they must be packed to avoid damage where possible. I understand that not every company does complete packaging of all items in their export loads, so the more professional the loading is, the less likely the parts in the load will get damaged when transported.
- All parts should be accompanied by detailed documentation and an inventory. Ideally, each part should also have an attached label or marking which relates to the list of parts supplied and allow it to be distinguished from all the others. Information to be included should be item description, quantity of each type of part, and price/value of the items.
- You may also want to include the following statement on the invoice – ‘All items listed originate from de-registered UK vehicles and are sold as working used parts for reuse only.’
- You could also state that the parts were tested by a suitably trained person on a specific date and found to be in working order. Your packing checklist could include the following statement – ‘The used car parts are found to be in working order’ and dated and signed by a trained person on the day of loading.
- Finally, I would advise photographing the loading process from start to finish so you can show every section of your load to the interested parties if/when inspected.
Regulatory authorities outside the UK may take a different view about whether a part is waste or not. It is always worth checking with the regulatory authority as you have to comply with their requirements.
I am now running my own company, providing export/import consultancy and exploring new export opportunities establishing sales channels in different countries and regions in Europe, Africa and Asia. I am fully aware of the responsibility placed on the exporter. I hope that my experience will help others avoid such situations or deal with them more effectively.
If, after reading this article, you still have questions, you can contact Uladzimir via his LinkedIn (www.linkedin.com/in/uladzimirboltach) or email him at info@asi-group.co.uk directly, and he will gladly provide further consultation.
