US EPA Recycling Rules: Practical Implications for Cross-Border Scrap Trade

The global marketplace for scrap materials is rapidly expanding, but with this opportunity comes significant regulatory complexity. Nowhere is this more evident than in cross-border scrap trade, where environmental and public health safeguards sharply intersect with logistical realities. At the heart of the U.S. regulatory landscape are the US EPA recycling rules, forming an intricate framework that governs how scrap—be it metal, paper, electronics, or plastics—moves in and out of the country.

For businesses participating in international scrap shipments, these rules are not just guidelines—they’re mandatory protocols that affect every aspect of trading, from documentation to port logistics and material categorization. Missteps can lead to serious consequences: fines, rejected shipments, or even business disruption. In this comprehensive guide, we’ll dissect the US EPA recycling rules' real-world impact on export and import decisions, focusing on shipment paperwork, grade eligibility, and port selection tactics. The goal? Equip scrap metal exporters, brokers, and compliance officers with actionable strategies that ensure legal compliance, operational efficiency, and a competitive edge in today’s global market.

Understanding the US EPA Recycling Rules: An Overview

The U.S. Environmental Protection Agency (EPA) stands as the primary federal entity regulating recycling and waste management across the United States. Its core mission is to protect human health and the environment, a goal achieved through implementing robust standards for waste handling, recycling procedures, and material transport.

Critical regulatory frameworks and rules impacting cross-border scrap commerce include:

• Resource Conservation and Recovery Act (RCRA): Governs the generation, transportation, treatment, storage, and disposal of hazardous and non-hazardous wastes. RCRA sets out standards for how waste and secondary materials, including scrap, must be managed throughout their lifecycle.

• Definition of Solid Waste (DSW) Rule: This is crucial for determining whether a material is a "waste" subject to RCRA or is considered a legitimate recycling feedstock, which may qualify for regulatory exclusions if managed appropriately.

• Import/Export Compliance (RCRA Section 3017): Specifies rigorous controls when hazardous waste or regulated recyclables cross U.S. borders, including procedures for notification, consent, manifesting, and recordkeeping.

• Documentation and Manifesting Requirements: The EPA enforces a strict paperwork trail for all regulated scrap shipments, from manifest systems to import/export notification forms.

Why does this matter for cross-border trade? Because U.S. regulations often carry over into bilateral or multilateral agreements with major trading partners such as Canada, Mexico, the European Union, and nations adhering to the Basel Convention. In many cases, states supplement federal rules with local requirements, creating a complex compliance patchwork that exporters and importers must navigate.

Section 1: Translating EPA Rules to Shipment Paperwork

If there’s one place where compliance failures most frequently occur, it’s in shipment documentation. For cross-border scrap transactions, the paperwork serves both as a legal defense and a quality control mechanism. By tightly aligning shipment documentation with EPA requirements, organizations can prevent delays, minimize liability, and smooth customs clearance globally.

1.1 Key Shipping Documents Under US EPA Recycling Rules

A. Uniform Hazardous Waste Manifest (UHWM)

The Uniform Hazardous Waste Manifest is the foundational document for shipping hazardous scrap. Mandated under RCRA, the manifest creates a transparent cradle-to-grave tracking system:

• Required when: Shipping hazardous scrap materials like batteries (e.g., spent lead-acid), certain spent electronics, or metal residues with regulated contaminants.

• Details included: Generator and facility ID numbers, accurate material descriptions, total weight, EPA hazardous waste codes (e.g., D008 for lead), packaging methods, and emergency contact information.

• Legal function: The manifest physically accompanies hazardous scrap during transit, is signed at each custody transfer, and serves as an auditable chain of responsibility.

B. Non-Hazardous Scrap Certification

For most non-hazardous recyclables (such as clean steel, copper, or aluminum scrap), a bill of lading will suffice. However, given the scrutiny at major U.S. ports, additional documentation—like material analysis certificates, letters of non-hazardous status from certified labs, or export declarations—may be required to demonstrate compliance.

C. Import/Export Notification Forms (EPA Form 8700-12)

Under both federal regulations and the Basel Convention framework, exporters and importers must file prior notifications for intended hazardous scrap shipments:

• EPA Form 8700-12: Used to update facility/filer information and activity status.

• OECD Notification and Consent Forms: Required for specific OECD country shipments; these forms must be processed and approved before materials depart U.S. soil.

• Timeline: Exporters may face weeks or months in waiting for ‘prior informed consent’ from both U.S. and foreign authorities.

D. Certificates of Recycling or Recovery

Major destination ports, especially in the EU or China, now require Certificates of Recycling or Recovery post-import, verifying materials have been treated in accordance with both U.S. and importing country environmental protocols. Falsification or absence of these certificates is a common trigger for investigation or rejection at entry points.

1.2 Best Practices for EPA-Compliant Shipment Paperwork

1. Maintain Robust Records:
Federal rules demand that shipping manifests, notifications, laboratory reports, and certificates be archived for at least three years (some states require up to 10). Digital storage and retrieval systems are vital for audit preparedness.

2. Adopt the e-Manifest System:
The EPA’s e-Manifest program brings digitization and traceability to hazardous waste transportation. Participating in this system allows trading entities to track shipments in real time, instantly flag anomalies, and electronically comply with both U.S. and partner country regulations.

3. Attach Supporting Grade Documentation:
Include granular details in your paperwork: laboratory reports confirming non-hazardous status, high-resolution photos of the material, and descriptions that match specific industry standards (e.g., ISRI specs).

4. Interdepartmental Coordination:
Compliance is a team effort. Shippers, brokers, and logistics managers must routinely cross-check documentation details (weight, classification, origin/destination, EPA codes) to detect and resolve discrepancies before customs review.

Case Study:

A U.S. exporter shipping mixed electronic scrap to Germany was flagged for missing prior notification forms and ambiguous manifest details. The shipment was held for six months, incurring daily storage penalties and loss of market value. By standardizing paperwork templates and adopting the EPA’s e-Manifest solution, subsequent exports cleared customs within three days, highlighting the business impact of meticulous documentation and digital tracking.

Section 2: US EPA Grade Eligibility—The Impact on International Scrap Trade

The definition and classification of "waste" versus "scrap" under the EPA have direct commercial implications. Grade eligibility affects what can be traded, under what conditions, and how materials are taxed or regulated as they pass through U.S. borders.

2.1 Definition of Solid Waste, Scrap, and Recyclable Material

The EPA’s DSW Rule creates a nuanced distinction:

• Solid Waste: Materials discarded (abandoned, transferred for disposal, or inherently waste-like) fall under stringent hazardous waste controls.

• Legitimate Recyclable Material: Secondary materials managed as valuable commodities, processed to meet market specs, and not speculatively accumulated may qualify for less restrictive regulation.

Eligibility Criteria:

• There must be evidence of an established recycling market (e.g., contracts, price indices, ISRI grades).

• The material is handled to prevent releases (packaged, labeled, properly segregated).

• It does not contain significant contamination that could render it a hazardous waste (e.g., PCBs, solvents, heavy metals in excess of EPA limits).

Exemptions and Special Cases:

• Clean scrap metal: Uncontaminated, unprocessed metals being shipped for recovery usually enjoy broad exclusions under both RCRA and select state codes.

• By-product and residue streams: Items like circuit boards, shredded automotive scrap, or transformer cores might trigger hazardous waste regulations if they contain regulated substances like mercury, oils, or lead solder.

2.2 How Grade Eligibility Influences Shipments

Material Classification Challenges:
Customs authorities will scrutinize overly generic or vague shipment classifications and may demand on-demand laboratory verification. Errors can result in reclassification, shipment denial, or even civil penalties—especially if discrepancies suggest material misrepresentation.

Documentation Requirements:
For contested or "borderline" materials, presenting analytical lab reports or third-party certifications accelerates customs clearance and mitigates risk of misclassification. Robust supporting documents—even for non-hazardous materials—improve credibility and speed resolution of disputes.

Country-Specific Listings:
U.S. rules may differ from those of partners like China, Canada, or the EU, all of whom frequently update their lists of prohibited or controlled scrap categories. For example, following China’s National Sword policy, grade-specific restrictions have become a moving target, impacting everything from old corrugated containers to insulated copper wire.

Case Example:

A 2021 survey by the Institute of Scrap Recycling Industries (ISRI) found that over 60% of rejected U.S. scrap shipments involved grade or contamination issues—demonstrating the paramount importance of aligning export documentation and physical shipments with evolving eligibility criteria.

2.3 Pro Tips for Traders

• Partner with Accredited Labs: Fast, on-call testing and certification prevents last-minute holdups, especially for high-value or mixed loads.

• Regularly Audit In-House Processes: Annual or biannual compliance reviews help adapt documentation and shipping procedures to regulatory and market changes.

• Stay Informed: Subscribe to regulatory bulletins from ISRI, the EPA, and port authorities to receive timely updates on scrap grade acceptance shifts.

You’ve seen how paperwork and grade eligibility make or break a load. In this next part, we move from what the rules are to how to move within them—port strategy, routing, contracts, pack/label standards, and material-specific playbooks that keep your cargo moving and your risk dialed down.

Section 3: Port Strategy, Carriers, and Routing Under EPA/CBP Scrutiny

Regulatory risk doesn’t stop at your loading bay; it spikes where multiple agencies intersect—EPA, CBP, DOT/PHMSA, Coast Guard, state regulators, and port authorities. A practical port strategy reduces random inspections, demurrage, and surprises.

3.1 Picking the Right Port for the Right Load

Choose ports that routinely handle recyclables. Terminals and CES (Centralized Examination Stations) with recycling volume tend to know the drill—ISRI grades, contamination thresholds, and how to process e-Manifests.

Map state overlays. Some states layer stricter rules over federal baselines. If your material brushes against hazardous thresholds, route through states with predictable procedures and experienced hazmat carriers.

Pre-engage the local ecosystem. Brief your customs broker, drayage, and CES contacts before the cargo arrives. Share your grade photos, lab certificates, and any required notifications. Pre-advice reduces “documentation mismatch” holds.

3.2 Aligning Filings and Documents

Your trifecta must match: commercial invoice + packing list + B/L must tell the same story as the EPA documentation (e.g., e-Manifest data, prior notifications). Discrepancies (weights, descriptions, EPA codes) are the fastest way to earn an exam.

ISF/ACE data consistency. For ocean exports/imports, ensure what’s filed electronically mirrors the physical paperwork—down to units, packaging types, and waste/recyclable descriptors.

Label like you mean it. Even for non-hazardous loads, clear bale/pack labeling (grade, net weight, lot IDs) speeds exams and prevents “generic scrap” reclassification.

3.3 Carriers and Equipment

Hazmat-qualified when needed. If any portion of your shipment triggers DOT/PHMSA requirements, confirm your carrier’s hazmat credentials and emergency response plan.

Clean conveyances. Residues in containers or railcars from previous loads can cross-contaminate your shipment and shift its regulatory posture. Require pre-trip condition photos.

Section 4: State Overlays and “Mini-EPA” Realities

Federal rules set the floor. States can and do go further. Expect:

Different retention timelines for manifests and lab reports (3–10 years is typical range).

Material-specific quirks, e.g., CRTs, mercury devices, oils/PCBs, or certain shredder residues that trigger extra handling or recordkeeping.

Facility permits and transporter registrations that apply even if your company isn’t the final processor.

Practical takeaway: build a state overlay sheet per origin/destination state in your SOPs so operations teams aren’t guessing at the dock.

Section 5: Contract Terms That De-Risk Compliance (Without Killing the Deal)

Your purchase and sales contracts can prevent most compliance fights from becoming financial ones.

Regulatory Representations & Warranties. Counterparties attest materials are lawfully generated, legitimately recyclable, and accurately described, with no prohibited contaminants beyond agreed limits.

Right to Inspect and Reject. Preserve pre-shipment inspection (photos/video), on-dock sampling rights, and rejection rights for contamination or misdescription—without waiving regulatory duties.

Grade & Contamination Thresholds. Reference ISRI specs (or destination-country specs) and define measurable tolerance bands. Tie price adjustments to variance bands, not hand-waving.

Documentation Deliverables. List each required doc by name: e-Manifest ID, lab certs, prior consent letters, recovery/recycling certificates, bale maps, photo packs. Make payment contingent on document delivery and veracity.

Demurrage/Detention Allocation. If a hold stems from seller misdescription or missing notifications, costs sit with the responsible party. If it’s random exam, split per a pre-agreed schedule.

Force Majeure for Regulatory Actions. Narrowly draft so it doesn’t excuse fraud or negligence but covers bona fide policy shifts or extraneous agency actions.

Insurance. Require cargo and, as appropriate, pollution/environmental impairment cover. Ask for certificates of insurance naming you as additional insured where practicable.

Section 6: Operating Playbooks by Material Type

Below are battle-tested, material-specific checklists you can embed into SOPs. Use them as “load recipes.”

6.1 Clean Ferrous & Non-Ferrous (e.g., HMS 1/2, PNS, Millberry, Taint/Tabor)

What to prove: legitimate recycling, clean stream, grade integrity.

Docs to prep: commercial set (invoice/PL/B/L), grade photo pack, mill/processor LOI/contract, any required export declarations, lab cert if borderline (e.g., oily residues).

Packing & labeling: uniform bales, visible grade tags, lot IDs, net weights.

Port notes: pick terminals that see metal daily; pre-advise with photos.

Common failure points: moisture/oil, embedded non-conforming items (plastic, rubber, OCC), vague descriptions like “metal scrap mixed.”

6.2 ULAB / Lead-Bearing Streams (spent lead-acid batteries, lead residues)

What to prove: correct classification, lawful movement, downstream smelter/recycler capability.

Docs to prep: e-Manifest (if applicable), notifications/consents, spill kit certs, emergency contact, lab analysis (lead/acid confirmation), downstream facility credentials.

Packing & labeling: no broken cases; lined pallets; acid-resistant wrap; hazard communication where required.

Port notes: route through ports and carriers comfortable with hazmat; ensure leak-proof conveyances.

Common failure points: acid leakage, misdeclared “cores,” missing prior consent.

6.3 E-Scrap / WEEE (mixed boards, devices, CRT glass, mercury-bearing items)

What to prove: not waste dumping; legitimate recovery; no prohibited components.

Docs to prep: prior notifications/consents (where required), lab certs for heavy metals/halogens, processor contracts, chain-of-custody SOPs, Certificates of Recycling/Recovery post-arrival.

Packing & labeling: segregate by category; protect from breakage; keep photo inventory by pallet.

Port notes: expect scrutiny; pre-share inventories and destinations with broker.

Common failure points: broken CRT funnels, commingled mercury devices, vague “used electronics” labels that read like disguised waste.

6.4 Plastics (regrind, pellets, clean post-industrial/post-consumer)

What to prove: cleanliness, traceability, legitimate destination processing.

Docs to prep: contamination lab report (moisture, ash, metals), source attestation, destination reprocessing capability evidence, photo pack.

Packing & labeling: sealed super sacks; clear polymer ID (e.g., “HDPE regrind—natural, MFI X”).

Port notes: plastics face heightened skepticism; your photo/lab evidence does the heavy lifting.

Common failure points: food/medical residues, mixed polymers, mislabeling flakes as pellets.

Section 7: A 90-Day Compliance Upgrade Plan

Days 1–15: Baseline & Gaps

Audit last 12 months of exports/imports: holds, rejections, reclassifications, demurrage costs.

Map each lane’s document set (commercial + EPA + destination-country extras).

Identify state overlays for your top two origin/destination states.

Days 16–30: SOPs, Templates, and Training

Standardize document templates (commercial and regulatory) and add a pre-sail checklist.

Create material playbooks (from Section 6) and add to your TMS/WMS.

Train sales + ops on description discipline and photo evidence standards.

Days 31–60: Port/Broker/Carrier Alignment

Hold joint calls with broker, carriers, terminal/CES—share your SOPs and evidence packs.

Pilot e-Manifest (where applicable) and set up document QC at booking + stuffing.

Days 61–90: Prove, Measure, Improve

Run two shipments per material type using the new SOPs.

Track clearance time, exam outcomes, demurrage, documentation errors.

Close gaps; lock contract clauses reflecting your new standards.

Section 8: Red Flags That Trigger Exams (Fix These First)

Descriptions like “mixed scrap” with no grade detail or photos.

Weight swings beyond normal tolerances between booking, manifest, and scale tickets.

Inconsistent HS codes across documents or countries.

Out-of-date lab reports or none for borderline materials.

Destination facility with no plausible capacity or history of lawful operation.

Residues in containers from prior hazardous loads.

Section 9: Two Mini Case Studies

Case A — Non-ferrous win:

Exporter added a two-page grade photo storyboard per container (bales → container stuffing → seal), plus polymer/metal purity lab slips where relevant. Clearance times fell from 8–12 days to 3–5, and random exams dropped because officers could validate the story at a glance.

Case B — E-scrap rescue:

A container flagged for “used electronics” got re-documented with device taxonomy, processor contracts, and hazardous component exclusions. The broker pre-briefed CES with the packet. Exam shifted from “full unload” to targeted pallet check, saving $4,000+ in handling and two weeks of delay.

Section 10: Your Practical Next Steps

Pick two lanes (origin state → port → destination country) and build lane-specific document packs.

Embed playbooks (Section 6) into your TMS/WMS as mandatory steps.

Harden contracts with compliance clauses, evidence deliverables, and demurrage allocation.

Stand up a photo + lab routine: every load, every time—no exceptions.

Measure clearance KPIs monthly and review with your broker and carriers.

Destination-Country Overlays, PIC Workflows, Insurance & the One-Page Pre-Sail Ritual

You’ve tightened paperwork, mastered grade eligibility, and aligned your ports. Now we go “outside the fence”—how destination-country rules change the game, how to run Prior Informed Consent (PIC) without delays, what insurance/financial assurance you really need, and a printable pre-sail ritual your team can follow every single time.

11) Destination-Country Overlays: What Changes Once You Leave the U.S.

11.1 OECD Controls (Green vs. Amber)

Green-list recyclables (OECD): Generally move under lighter controls, but still require accurate descriptions, evidence of legitimate recovery, and conformity with destination specs. Expect documentary spot checks—quality is everything.

Amber-list recyclables (OECD): Require PIC between competent authorities before shipment. You’ll submit a notification package and wait for explicit consent. Conditions (routes, facilities) often appear on the approval.

11.2 Non-OECD Lanes (Basel PIC)

Shipments to non-OECD countries typically follow Basel Convention processes. In practice: a formal notification, consent from all relevant authorities, and movement documents traveling with the load. Many countries demand post-recovery certificates too.

11.3 Country Modules (Operational Reality, Not Theory)

European Union

The Waste Shipment regime is strict on grade purity, contamination, and traceability. Even “green” metals/plastics face close inspection if quality is suspect. “End-of-Waste” criteria help—if you can prove the material is product-like, not waste-like.

Expect robust post-recovery reporting and active port/CES ecosystems (e.g., NL/BE) that understand recyclables but demand clean documentation.

Canada & Mexico

U.S.–Canada/Mexico shipments often still require PIC for amber materials; authorities are responsive but expect complete packets and consistent HS codes. Bilingual documentation helps.

Mexico: watch importer licensing and material-specific permits; pre-alignment with your broker is essential.

Turkey

High-volume ferrous lane with tight contamination expectations and changing documentary asks. Importer licensing, facility credentials, and recycling/processing capacity evidence reduce holds. Pre-advice your packet to the broker and terminal.

India

Plastics and E-waste need extra caution: think EPR linkages, import policy nuances, and port-by-port sensitivities. Provide lab results (moisture/ash/metals), processor contracts, and crystal-clear polymer/metal IDs.

China & ASEAN Alternatives

Mainland China remains highly restrictive; lanes have shifted to Vietnam/Malaysia/Indonesia/Thailand with licenses, pre-shipment inspections, and tight purity thresholds. Work only with facilities you can evidence as legitimate recyclers.

GCC (e.g., UAE, KSA)

Expect importer licenses, clean documentary trails, and fast exams when your photos + lab packs match physical reality. Port coordination matters; share your evidence in advance.

Bottom line: build lane binders—for each destination, store consent forms, importer licenses, facility credentials, port/CES preferences, plus recent “what triggered exams” notes.

12) Prior Informed Consent (PIC) — A Frictionless Workflow

12.1 Pre-Apply (Do Not Skip)

Lock the material definition (grade, spec, contamination thresholds).

Secure downstream facility credentials (permit, capacity statement, recovery method).

Obtain current lab analyses and a photo storyboard from source to packout.

Draft your routing (borders, transit states) and confirm each authority you must notify.

12.2 Notification Package

Include notifier details, generator and receiver info, exact material description, quantities, containers, routes, intended treatment/recovery, and financial guarantee details where required.

Submit to the competent authority and track acknowledgements. Corrections early save months later.

12.3 Consent in Hand

Read the conditions: validity dates, tonnage caps, approved facilities, transit corridors. If anything changes (facility, route, volumes), amend before moving.

12.4 During Transit

Movement documents travel with the load. Keep seal numbers, weights, and container IDs consistent with the packet. Any diversion? Inform authorities as prescribed.

12.5 Post-Recovery

File certificate of receipt and certificate of recovery within required windows. Close the loop; a clean record accelerates future consents.

Typical PIC killers: shipping before consent; vague descriptions; inconsistent HS/EPA codes; missing transit-state consents; no financial guarantee where required.

13) Insurance & Financial Assurance That Actually Covers You

13.1 Cargo & Logistics

All-Risk Cargo (ICC A preferred): Declare scrap as scrap; misdescription can void claims. Cover the whole journey (inland → port → ocean → delivery).

General Average & Salvage: Ensure your policy responds, and your team knows how to issue GA bonds fast.

Stock Throughput (STP): Useful if you hold stock in warehouses; seamless cover from storage to transit.

Carrier Liability Limits: Understand Hague-Visby/COGSA caps—don’t rely on carrier liability to make you whole.

13.2 Environmental/Pollution

Environmental Impairment Liability (EIL)/PLL: Critical for hazmat-adjacent recyclables (ULAB, certain WEEE). Ask for transportation pollution extensions or a contingent auto endorsement where relevant.

13.3 Financial Guarantees / Bonds

PIC Financial Guarantee: Some authorities require a bank guarantee/surety to cover repatriation or cleanup. Line this up before filing.

CBP Continuous Bond (U.S.) and customs sureties elsewhere: ensure limits reflect your cargo values and duty/tax exposures.

13.4 Contract Alignment

Bake insurance requirements into contracts: minimum limits, additional insured, waiver of subrogation, and evidence of insurance (COI) delivered before loading.

14) The One-Page Pre-Sail Ritual (Print This)

Goal: A single yes/no pass that prevents 90% of holds and claims.

Material locked: ISRI grade/spec + contamination thresholds confirmed in writing.

Photos complete: Source → prep → packing → stuffing → seal; filenames date-stamped.

Lab results current: Match the load (lot IDs on reports/photos).

Docs triangulated: Invoice, PL, B/L, HS codes match EPA/PIC descriptions and weights.

PIC status: Approval letters on file; conditions (facility, route, validity) reviewed; no changes pending.

Transit states cleared (if any).

Importer/facility credentials: licenses, permits, treatment method proof on file.

e-Manifest/notifications (if applicable): IDs recorded; copies archived.

Container hygiene: clean, dry, odor-free; no residues from prior haz loads.

Pack & label: grade tags, lot IDs, net/gross weights visible and consistent.

Seals recorded: seal numbers on B/L + photos; scale tickets reconciled.

Broker pre-brief: packet (photos, labs, consents) shared before terminal in-gate.

Port/CES heads-up (sensitive lanes): contact confirmed.

Insurance active: cargo + GA; pollution/EIL if needed; COIs saved.

Financial guarantee (if required): executed and referenced in the file.

Carrier fit-for-purpose: hazmat creds if relevant; emergency contacts shared.

Exception log: any variances documented + approved by compliance.

Archive & retention: digital folder named __; retention timer set.

Green-light sign-off: operations + compliance.

Post-arrival tasks scheduled: receipt/recovery certificates due dates on calendar.

If you can’t answer “yes” to all 20, don’t sail.

15) Quick Scenarios (How This Plays Out)

EU Amber E-Scrap:

Notifier submits full PIC with device taxonomy, hazard exclusions, processor permits, and a financial guarantee. Broker pre-briefs CES with photo inventory. Result: targeted exam, 3-day clearance, zero repacks.

India Plastics Regrind:

Exporter adds moisture/ash/metals lab slips, polymer ID + MFI detail, and destination reprocessing capability letter. Clean sack labeling plus photo storyboard. Result: no reclassification, routine release.

Turkey Ferrous:

Lane binder includes importer license, port SOP, and contamination cap in the contract. Pre-advice photos sent to the terminal. Result: reduced random exams and predictable turn times.

Where We Go From Here

You now have a destination-aware playbook, a clean PIC workflow, and a pre-sail ritual built for speed and audits. Next, I can translate this into lane-specific SOPs (e.g., HMS → TR via East Coast; Millberry → EU via NL; ULAB → NA via land/ocean), complete with binder checklists and email templates for brokers, terminals, and authorities.