Urgent Compliance Investigation Request – Suspected Cargo Misdeclaration and Basel Convention Non-Compliance

[infomendelmetalurji-tech]

Container No: FFAU214049/4

• Origin: Rades Port, Tunisia

• Transshipment Port: Gioia Tauro, Italy

• Export Customs Classification: HS 38252000006

• Product Description: Boue de traitement / Boues d’épuration

• Concern: discrepancy between Tunisian customs classification and transport documentation

• Concern: Basel Convention compliance review request

Urgent Compliance Investigation Request – Suspected Cargo Misdeclaration and Basel Convention Non-Compliance

Dear Sir or Madam,

We respectfully request MSC to conduct an urgent compliance review concerning container FFAU214049/4 and the related shipment consisting of approximately eighteen (18) containers loaded through the Port of Rades, Tunisia.

Information and documentation currently available to us indicate a significant discrepancy between the cargo description declared to Tunisian authorities and the description reportedly appearing on the transport documentation.

The supporting documents in our possession include:

• Official tariff classification issued by the Tunisian Customs Administration classifying the material under HS Code 3825.20 as treatment sludge / industrial waste residues (“Boues d’hydroxydes métalliques épurées”);

• Commercial invoice describing the material as “Boue de traitement” (treatment sludge);

• Tunisian export customs declaration identifying the cargo as “Boues d’épuration” and classifying it under HS Code 38252000006.

These documents consistently characterize the material as treatment sludge / waste material falling within HS Code 3825.

However, we have received information suggesting that the cargo subsequently have been described in shipping documentation under HS Code 2825 and as copper oxide or other metallic compounds. If confirmed, such a discrepancy would raise serious concerns regarding:

1. cargo misdeclaration;
2. Customs classification inconsistencies;
3. Environmental compliance obligations;
4. Possible circumvention of Basel Convention procedures governing transboundary movements of waste;
5. Transportation of material requiring regulatory approvals different from those applicable to ordinary commercial products.

Furthermore, we have reason to believe that the consignee/importing entity may not possess the environmental permits or waste-processing authorizations that would normally be required for the lawful import and handling of industrial waste materials, should the cargo indeed fall within the scope of HS Code 3825 and applicable Basel Convention provisions.

In light of the above, we respectfully request to:

• Review all booking, shipping, and bill of lading documentation associated with container FFAU214049/4 and the related shipment;

• Verify the consistency of cargo descriptions throughout the transport chain;

• Confirm whether any amendments were made to the cargo description or HS classification after export customs clearance;

• Assess whether the shipment may involve materials subject to environmental or hazardous-waste controls;

• Notify the appropriate authorities should any material discrepancy be identified.

Given the potential regulatory, customs, environmental, and reputational implications, we kindly request that this matter be treated with appropriate priority and sensitivity.

We would appreciate being informed that this report has been received and forwarded to the relevant compliance personnel for review.

Thank you for your attention and cooperation.

Yours faithfully
Cem Celik
+905325798494
cemcelik71@hotmail.com