The zinc skimming and dross are formed in the galvanizing kettle as a result of reactions of the molten zinc with air and iron. Over 25% of the zinc used in the kettle gets converted into Dross and skimmings. The environmentally sound management of these materials is required to comply with the provisions of the Basel Convention as incorporated in the National regulations of the countries that have ratified this convention. The understanding of the regulations and the environmentally sound management of Zinc wastes generated in the galvanizing industry specially in the context of exporting these materials to India is therefore essential for the overall sustainability of this sector, as India not only has a large gap in the demand and supply of Zinc but there is also an increasing need for import of the Zinc rich reject materials in the country for the secondary production of Zinc.

1. Zinc Wastes from Galvanizing Industry and Basel Compliance for
their Imports in India
By
Dr R S Mahwar, Environmental Adviser, ILZDA
Former Additional Director, Central Pollution Control Board
(Ministry of Environment, Forest & Climate Change), Govt. of India, Delhi

2. Would it not be appropriate
to
classify zinc skimming/dross
as
by-products (not wastes)
of
galvanizing ?

3. Zinc Rich Materials Produced in Galvanizing
 Reactions of molten zinc with air & iron
 Over 25 % of the zinc in ht Galvanizing Kettle involved
 Reaction of zinc with air (oxidation)
 Product : Zinc Skimming (Also called Zinc Ash)
 Light and floats
 Zinc Content : 60 to 85 %
 Reaction of zinc with iron (alloying)
 Product : Zinc dross
 Heavy and settles
 Zinc Content : More Than 94 %

4. Zinc Skimming and Zinc Dross – Wastes or By-products?
 Zinc Content much higher than the mined zinc ores
 Other constituents contained also exist in zinc ores
 Zinc ores not classified as hazardous
 Basel Convention not applicable to Zinc ores
 Recycling of zinc skimming/dross is secondary metallurgy
 Secondary metallurgy is more environment friendly than primary
metallurgy
 Would it not be appropriate to classify zinc skimming/dross as by-
products of galvanizing ?

5. Global Importance of Zinc Skimming /Dross
 Total Production (2016) – 13.724 million tonnes
 Zinc usage (2016) – 13.861 million tonnes
 Deficit in (2016) – 1,37,000 tonnes
 Deficit (2017 upto November) – 4,85,000 tonnes

6. Global End Uses of Zinc
Source : http://www.ilzsg.org/static/enduses.aspx?from=1
( as viewed on February 25, 2018)

7. Zinc Metal industry Dynamics in India

8. Sector Demand of Zinc in India
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app6891/95/zinc-and-lead-in-india-a-marco-view-4-638.jpg?cb=1433141963

9. Galvanizing Wastes and Basel Convention (BC)
 BC- Annexure I
 Y-17 : Waste resulting from surface treatment of metals
 BC- Annexure III
 H11 : Toxic (Delayed or chronic)
Substances or wastes which, if they are inhaled or ingested or if they
penetrate the skin, may involve delayed or chronic effects, including
carcinogenicity.
 H12 : Ecotoxic
Substances or wastes which if released present or may present immediate
or delayed adverse impacts to the environment by means of
bioaccumulation and /or toxic effects upon biotic systems.

10. Galvanizing Wastes and Basel Convention(BC)
 BC- Annexure IV B
R4 : Recycling/reclamation of metals and metal compounds
 BC – Annexure IX List B
 B1080 :
 Zinc ash and residues including zinc alloys residues in dispersible form
unless containing Annex I constituents in concentration such as to exhibit
Annex III characteristics.
 B1100 :
 Galvanizing slab zinc top dross (>90% Zn)
 Galvanizing slab zinc bottom dross (>92% Zn)
 Hot dip galvanizers slab zinc dross (batch)(>92% Zn)
 Zinc skimming

11. Basel Compliance in Trans-boundary Movement
 Notification Document
 Provides the competent authorities of concerned countries with
information they need to assess the acceptability of proposed waste
movements
 The document includes space for the competent authorities to
acknowledge receipt of the notification and, where required, to consent in
writing to a proposed movement.
 Movement Document
 The document to accompany with the consignment of waste at all times
(Cradle to Grave)
 The document to be used by recycling facility to certify that the waste has
been received and recycled

12. Notes for filling the Notification Document
 Packaging types (Item no 7) : Drum, Bags, Bulk ..?
 Means of Transport (Item No 8): R = Road, T = Train/rail, S = Sea...?
 Recovery Operations (Item no 11) : R4 Recycling/reclamation of metals
and metal compounds
 Physical Characteristics (Item No 13) : Powdery/powder, Solid..?
 Waste Identification (Item no 14)
 Y Code : Y17
 H Code : H11 Toxic (delayed or chronic) & H12 Ecotoxic
 Notification Document to be prepared by each generator for each waste.
 Notification can be prepared for the transport of the entire quantity of
waste to be transported in a period regardless of the number of
shipments.
 The Quantity limit gets decided as per the recycling limits permitted in the
country of Import.

13. Processing of the Notification Document (ND)
 ND to be filled by the exporter & submitted to the Concerned Authority of
the Country of Export (CACE).
 The CACE to appraise the ND for its compliance to the country’s legislation
and Basel Convention requirements.
 The CACE to give a specific number to the ND and send it to the
Concerned Authority of the Country of Import (CACI).
 The document sent by the CACE to the CACI is called the “Prior Informed
Consent (PIC)”.
 The CACI to appraise the ND for its compliance to the country’s legislation
& Basel Convention requirements.
 The CACI to accept it if the proposed import is permitted (The importer is
an authorised actual user/recycler)
 The CACI to the acknowledgement of its receipt to the CACE after ensuring
the importer having all permissions required for import of the material as
per the details provided in the ND.

14. Indian Legislation for Import of Galvanizing Wastes
 Hazardous and Other Wastes (Management and Transboundary
Movement) Rules, 2016 (HW Rules 2016)
 Schedule- III , HW Rules 2016
 Basel No : B1080
Zinc ash and residues including zinc alloys residues in dispersible form
(i) Zinc content more than 65% (lead and cadmium equal to or less than
1.25% and 0.1% respectively) are allowed for import without Director
General of Foreign Trade license to recycling units registered with State
Pollution Control Boards (SPCBs).
(ii) Zinc content less than 65% ( lead and cadmium equal to or more than
1.25% and 0.1% respectively) permitted for import against Director
General of Foreign Trade license and only for purpose of processing or
reuse by units registered with the SPCBs.
 Industries meeting the requirements under (i) & (ii) above are eligible to
obtain permission for import from the Ministry of Environment, Forest &
Climate Change, Govt of India.

15. Indian Legislation for Import of Galvanizing Wastes
 B1100 :
 Galvanizing slab zinc top dross (>90% Zn)
 Galvanizing slab zinc bottom dross (>92% Zn)
 Hot dip galvanizers slab zinc dross (batch)(>92% Zn)
 Zinc skimming (Zinc content less than 65% will be regulated as per the
provisions of listed under B1080)
 Import permitted the actual user or to the trader on behalf of the actual
users authorised by SPCB without obtaining permission from Ministry of
Environment, Forest & Climate Change.
 PIC not required for Import of Zinc Skimming/Ash and Zinc Dross in India.
 Attestation of the ND by the Govt of India is required in case the CACE
requires so.
 Exports from countries which have ratified the Basel Convention require
the CACE to obtain the attestation of the ND by the Govt of India before
their their shipment.

16. Concluding Remarks
 The requirement of Zinc is increasing globally as well as India with the
increase in the development activities.
 Import of Zinc Skimming and Zinc dross in India has become an imperative
need.
 The gap between the demand and supply of Zinc in India is going to
increase further by leaps and bounds.
 There is strong need for the exporters as well as importers to have
complete understanding of the trans-boundary movement requirements.
 The Zinc Skimming and Zinc dross generated in the Galvanizing process
need to be better recognised as resources and not wastes.