Scrap Export Documents: What to Prepare Before Alloy Scrap Ships

Which Scrap Export Documents Does Every Shipment Need?

Every alloy scrap shipment needs a commercial invoice, a packing list with weights per package and grade, a bill of lading, a certificate of origin and the correct HS code. Most also need a radiation-free certificate, and many buyers require a PMI or analysis report and photographs of the loaded container.

It helps to think of the file in layers. The commercial and transport papers prove what was sold and shipped; the safety papers prove it is not dangerous; the quality papers prove what grade it is.

The base layers are the ones most often forgotten, because no authority asks for them at the export port. They are the layers your buyer relies on when the container is opened.

HS Codes for Alloy and Stainless Scrap

Alloy scrap is classified by its base metal: nickel alloys under 7503.00, stainless under 7204.21, cast iron such as Ni-Resist under 7204.10, titanium under 8108.30 and tungsten carbide under 8101.97.

These are the internationally harmonised six-digit headings. National tariff lines add further digits. Confirm them with your customs broker, and use the same code on the invoice, the packing list and the export declaration.

How Should the Commercial Invoice and Packing List Be Written?

Write the invoice and packing list from the same weight sheet, describe the goods by grade, UNS number and form, and make the package total equal the invoice weight. These two papers are copied into every other document, so an error here repeats everywhere.

Commercial Invoice

• Description by grade and form: "Inconel 625 (UNS N06625) pipe scrap, cut, oil-free", not "nickel scrap".
• HS code, net weight per grade, price basis and Incoterm with the named port.
• Container and seal numbers once they are known.

Packing List

• One line per package: package number, grade, form, gross and net weight.
• Subtotals per grade, and a total that equals the invoice.
• Package numbers that match the labels on the bags, drums or stillages.

For pipe, plate and bar, a theoretical weight from the scrap weight calculator is a quick check that a declared weight is plausible before the weighbridge ticket arrives.

What Does a Radiation-Free Certificate Prove?

A radiation-free certificate states that the scrap was surveyed with a radiation meter and showed no reading above background. Many importing countries require one for metal scrap, and buyers increasingly ask for it even when their authorities do not.

A certificate that will stand up to questions records the date and place of the survey, the container numbers, the background reading and the highest reading on the material, and the instrument used with its calibration date. At the time of writing, the pre-shipment inspection certificate format that India publishes asks for exactly these readings, which makes it a useful model for any radiation certificate. Check the current format before shipping.

A radiation certificate covers the container it names. If material is moved to a different container after the survey, the certificate no longer describes the shipment.

Destination and Origin Rules to Know

The destination often adds documents of its own. India and the European Union are the two that matter most in this trade.

India. Imports of metallic waste and scrap generally need a pre-shipment inspection certificate (PSIC) issued by an inspection agency recognised by the Indian government. The procedures have provided alternative arrangements for some origins and ports, so check the current DGFT rules for the shipment's origin and port of entry. Where a PSIC applies, the inspection confirms the material matches its description and is free of radioactive and explosive material, and it happens at the loading point before the container is sealed. The full import process is in importing metal scrap into India, and the market itself in high-nickel alloy scrap in India.

European Union. At the time of writing, the revised EU Waste Shipment Regulation (EU) 2024/1157 applies from 21 May 2026, with new electronic procedures. Its tighter rules on exporting waste to non-OECD countries apply from 21 May 2027. That affects scrap flows from Europe to countries such as India. See Europe.

Decontamination. Scrap from chemical plants and oil and gas facilities often needs a written decontamination declaration, stating how the equipment was drained and cleaned.

Rules change. Always confirm current requirements with the destination country's authorities or your freight forwarder before shipping.

Incoterms and the Price Basis

Every export offer should state its Incoterm, the international rule that defines who pays for and carries the risk of each leg of the journey. The most common in scrap trading are FOB (free on board: the seller delivers onto the vessel at the port of loading) and CIF or CFR (the seller also pays the sea freight, and for CIF the insurance, to the destination port). Offers on different terms cannot be compared directly.

The Incoterm also decides who produces some of the documents. Under FOB the buyer's forwarder usually issues the bill of lading; under CFR or CIF the seller arranges it, and under CIF the seller also supplies the insurance certificate. Write the Incoterm and named port on the invoice exactly as in the contract.

Container Weight Rules and the VGM

Under the SOLAS convention, the shipper must declare a verified gross mass (VGM) for every packed container before it is loaded on a ship. Weigh containers at a certified weighbridge and keep the VGM record with the shipping documents.

The VGM is also a cross-check on your packing list. Gross mass less the container tare and packaging should come close to the packing list net weight. If it does not, find out why before the documents are released. Scrap containers also have strict payload limits, so check them before loading dense material such as solids or revert, which can reach the limit with the container still looking half empty.

When Does a PMI Report or Mill Certificate Belong in the File?

Include a PMI report whenever the buyer pays by grade, which in nickel alloy scrap is nearly always. Include mill certificates only when pieces can still be traced to the heat numbers on them.

A PMI report should link readings to package numbers, so a disputed bag can be found and re-tested; PMI for scrap lots covers what a good report contains, and the PMI inspection checklist gives the fields to record. A 3.1 certificate for a heat of 625 pipe adds value only if the stencils on the offcuts still show that heat number, as explained in reading an EN 10204 3.1 mill certificate.

Common Document Mistakes That Hold Up Scrap Shipments

Most document problems in alloy scrap come from vague descriptions, weights that do not reconcile, and certificates that refer to the wrong container. Each one is cheap to prevent at the export port and expensive to fix at the destination.

A decontamination declaration is worth writing properly rather than as a one-line statement. Name the equipment, the service it came from, how it was drained, flushed or cleaned, and who signed off. A tube bundle from a sour gas unit and an offcut from a fabrication shop carry very different risks, and the declaration should show you know which one you are shipping.

What Order Should Export Documents Be Prepared in?

Prepare documents in the order the material moves: grade evidence first, then inspection and safety papers, then weights, and only then the final invoice and transport documents. Working the other way round is how mismatches start.

The last step is the one most often skipped. Before releasing documents, read every paper against the others for the same five things: grade description, HS code, weight, container number and seal number.

Mipra Steel exports and supplies nickel alloy and stainless steel scrap described by grade, and handles import and export enquiries from Mumbai. Our nickel alloy scrap exporting page explains what we supply, and we'll review your enquiry with the grade, form, quantity and destination.

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