Heterogenous Plastic Waste

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PHILIPPINE PORTS AUTHORITY ee 23 January 2019 MEMORANDUM FOR ‘The General Manager FROM The Port Manager SUBJECT HETEROGENEOUS PLASTIC WASTE FROM TAGOLOAN, MISAMIS ORIENTAL This has reference with the heterogeneous plastic waste from Tagoloan, Misamis Oriental discharged from vessel Kaliroe V-852s-903n, of MCC Transport Singapore PTE Ltd. that arrived in Sasa Port on 19 January 2019 Respectfully forwarded the following details: 1. On 22 January 2019, during the conduct of the daily operational meeting, the representative from the Davao Integrated Port and Stevedoring Services Corporation (DIPSSCOR) notified the Sasa Port Terminal ‘Supervisor of the existence of the said cargoes inside the port, 2. Verification was immediately made and the following were revealed: 2.1 Submitted documents for entrance formalities did not include the list of containers nor adequately described in the inward manifest as part of the requirement in the application for NOA/ABA; 2.2 Special Permit for Co-loading, Export Declaration and Warrant Seizure and Detention and DENR Investigation/ Inspection Report were not Provided and/or submitted by MCC to PPA; instead those documents were secured from DIPSSCOR; ltem one (1) of the procedure details in the Integrated Management ‘System (IMS) and per PPA Memorandum Circular No. 11-2013 entitled Reiteration of Simplified Requirements for Vessel Entrance and Departure Clearance states that it is the Ship's Agent/ Representative who shall submit the required documents to the Authority. 3. Enclosed are pertinent documents from DENR and BOC, provided by the CHO and not by the Shipping Lines; 3.1 DENR- Region X Investigation/Inspection Report dated January 7, 2019; PORT MANAGEMENT OFFICE — DAVAO Tet Nos: 2023630641068: (08) 296.2589 mat pesevao@pacam ph /pmodeacgamaican 3.2 Copy of Decision made by the Bureau of Customs District Collector- Region X, Atty.Floro G. Calixihan, Jr.; 3.3 Warrant of Seizure and Detention issued by the Bureau of Customs Region X, Cagayan de Oro City, 3.4 Discharge Permit approved by the Bureau of Customs, Davao; 3.5 Special Permit to Load (Spl Permit for Co-Loading) issued by BOC CDO and Export Declaration with a complete list of container numbers. 4, The said cargoes from Tagoloan, Misamis Oriental will be re-exported back to its country of origin in South Korea using the Port of Sasa as transit point. The carrying vessel will be Spectrum N-802E-904N, that is ‘expected to arrive in the Port of Davao on 24 January 2019 @1900H and the expected time of departure in on 28 January 2019 for Pyongtaek, ‘South Korea; Currently, investigation and gathering of additional information is in progress. For your information and perusal. Enclosed: as stated AGANAPISGVOGAM Republic of the Philippines Department of Environment and Natural Resources, ENVIRONMENTAL MANAGEMENT BURE. ‘Office of the Regional Director Rogion -10, Macabalan, Cagayan de Oro Cty cs vr ORG ne vlsraic Te jo SAN 08 a January 7, 2019 ATTY. VLORO G. CALIXIHAN, JR. District Collector Bureeu of Customs Mindanao Container Terminal, PHIVIDEC Industrial Estate, ‘Tagaloan, Misamis Oriental 9001 ATTENTION: COLL. JOHN M, SIMON Port Collector SIR: ‘This pertains to the series of inspection jointly conducted by this Office and represcatatives from the Bureau of Customs on the fifty-one (51) 40-footer containers consigned to Verde Soko Philippines Industrial Corporation located at the Mindanao Interhational Container ‘Terminal Services Inc., PHIVIDEC, Tagoloan, Misamis Oriental. ‘The importations of the said containers are found to be in violation of the Department Administrative Order (DAO) 2013-22 or the “Revised Procedures and Standards for the Management of Hazardous Waste” the Implementing Rules and Regulations (IRR) of the Republic Act (RA) 6969 or the “Toxic Substances and Hazardois and Nuclear Wastes Control Act of 1990° for importation of mixed plastic wastes without Importation Registration and Importation Clearance before shipping the iixed plastic and for Non-compliance in the stated limiting condition for the importation of solid plastic materials on Table 10.1 of DAO 2013-22, which states that “No importation of heterogeneous and unsorted plastic materials, shall be allowed.” Further, the imported wastes are considered wastes collected from households with waste no. Y46 fisted in Annex U of the Basci Convention on the Control of ‘Transboundary Movements to another country or Party to the Convention. Please sce the reiative report attached, With this, it is highly recommended that the said illegally imported wastes shoitld be shipped back to its country of origin. Sincerely, ; Regional Direct eccived by: MO Page Loft e “us, ene PISTHC Republic ofthe Philippines Department of Environment and Natural Resources ENVIRONMENTAL MANAGEMENT BUREAU - X Office of the Regional Director , Macabalan, Cagayan de Oro City We INVESTIGATION /INSPECTION REPORT I Seeeeeceee Fa EES Investigation of the 51 containers consigned to Verde Soko Philippines Industrial Corp. Subject: Mindanao International Container Terminal Location: Service Inc., PHIVIDEC Industrial Estate, | | Tagoloan, Misamis Oriental | 3 Environmental Management Bureau-10 | Deca Bureau of Customs, Northern Mindanao I, EXECUTIVE SUMMARY : cn October 21, 2018 fifty-one (51) containers (40 footer) of cargo consigned to Verde Soko Philippines Industrial Corporation arrived at the PHIViDEC Port at Tagoloan, Misamis Oriental through the Vessel KALLIROE. ‘These containers were initially declared to contain plastic synthetic flakes based on its manifest document. No Importation Clearance was issued to Verde Soko for the importation of plastic synthetic flakes by EMB-DENR as required under DAO 2013-22 or the ‘Revised Procedures and Standards for the management of Hazardous Waste. Consequently, the Bureau of Customs (BOC) then issued Warrant of Seizure and Detention of the 51 containers on November 16, 2018. On November 26, 2018, SA II Renan Q. Azuer, agent of the Bureau of Customs Manila, conducted examination of at least 15 containers said to contain synthetic plastic flakes with the EMB-10 Regional Office representatives. It was found out that the contents of the 15 opened contaiuers were mixed wastes composed of assorted plastics such as plastic beltles; plastic straw, toothbrush, plastic cellophanes, plastic gloves, plastic utensils and metals, wood, rubber, soil, text tiles, and electronic wastes such as céliphone batteries and chargers and dry cell batteries. These are contrary to what was declared on its Bill of Lading as Plastic Synthetic Flakes. Table 10.1 of DAO 2013-22 provides that “No importation of heterogeneous and unsorted plastic materials shall be allowed”, Also, these imported mixed wastes are actually household wastes with No. Y46 listed in Annex 11 of the Basel Convention on the Control of Transboundary Movement of Hazardous Wastes. TAG eset mt Ruccieal by. lela 43cm : On December 3, 2018, a hearing of the seized containers was later conducted at the BOC Office at Macabalan, Cagayan de Oro City. Reports and other documents from the EMB-10, the BOC and the Verde Soko were exhibited. On January 4, 2019, the remaining 36 unopened containers were examined. The content of the containers were similar to the previous that were opened 1. BACKGROUND INFORMATION : Verde Soko Philippines Industrial Corporation (VSPIC} is a locator of PHIVIDRC Industrial Authority in Tagoloan, Misamis Oriental. The Company is constructing Plastic Pellet Processing, Plastic Briquette Processing Plant and eventuaily, a 300 KW Thermal Power Supply Project. It is specifically located at Sitio Buguac, Sta. Cruz, Tagoloan, Misamis Oriental. Said project is covered by ECC with reference no, ECC-R10- 1807-0022 issued on July 6, 2018. On July 18, 2018 VSPIC, thru Hazardous Waste Management Section, applied for Importer’s Registration Certificate with the EMB Central Office, A :argo shipment. arrived in the Port of Villanueva, Misamis Oriental within PHIVIDC area, Such cargo was consigned to VSPIC containing 5, 176.91 MT of Plastic Synthetic Flakes’ as declared in the Bill of Lading No. PCOO1. Subsequently, this Office received information that another shipment was intercepted by the BOC Tagoloan. Immediately upon receipt of that information, the EMB-EMBD personnel were sent to verify the alleged shipment. Based on the copy of the manifest, there were a total of 51 (#0 footer) containers of cargoes shipped from South Korea by Green Soko Co. Ltd consigried to VSPIC. Since the inception of this issue, this Office has been conducting a series of investigation with personnel form Central Office and other concerned LOU's. Based on the said investigations the two (2) shipments of VSPIC were not covered by pre-importation clearance required under DENR Administrative Order 2013-22 for “Importing recyclable materials containing hazardous substances without securing import clearance.” Warrant of Seizure and detention orders were issued by the BOC a nmannsaon ef 51 eomainor sansignad t Vonks Soke ~swcotgeion Rpt 2018, Pan Pal 12 7} « on the two (2) shipments. IL. FINDINGS AND OBSERVATIONS: |. On November 27, 2018, SA If Renan Q. Azuer, agent of the Bureau of Customs Manila, conducted examination of at least 15 containers said to contain synthetic plastic flakes together with the EMB-10 Regional Office representatives. It was found out that the contents of the 15 opened containers were mixed wastes which are composed of plastics, metals, wood, rubber, soil, text tiles, and electronic wastes such as cellphone batieries and chargers and dry cell batteries, These are contrary to what was declared on its Bill of Lading as Synthetic Plastic Flakes. The shipment is not covered by pre-importation clearance required under DENR Administrative Order 2013-22 for “Importing recyclable materials conaining hazardous substances without securing import clearance” which means it is considered illegal. 2, ‘The following were the contents of the 15 container vans that were opened; Container MSKU 1852619 Contents ‘Paper, rubber, caps of PET bottles, metal wastes, cloth, plastic cellophane, glass bottle, MRKU 4595467 ‘broken glass Z Styrofoams, plastic cellophanes, PET botties, cloth, broken glass, | RXU 9370724 Plastic, electrical wires, rubber, glass bottles, broken glass, PET bottles, rags, nylon nets, fabric, styrofoam, tin cans, brown glass bottles, papers, plastic | cellophanes, celiphone charges_| MRKU 0086543 Plastics, paper, rubber, tin can, electrical wire, rubber hose_ MREU_ Plastic, rubber, tin can, soil MRKU 0098420 Plastics, styrofoams, cellphone casing, metals, rags, MSKU 6707824 Plastics, aluminum tin can, foam glass bottle, paper, rubber hose, electrical wire, used battery _ MSKU 6438828 j Plastics, tin can, PET bottles, cellphone battery, wood chopsticks. CNIU 2152850 Plastics, broken glass, battery, electrical wire plastic bottle, nylon nets, papers, aluminum, foils 10 il MRKU 0880661 PONU 766 0948 Plastics, rubber, paper, aluminum tin can, plastic cellophane, plastic food container, tin can, plastic caps, [broken glass, electrical wire Plastics, washing drain hose, | styrofoam, sack bags, plastic hose, aluminum hose, plastic bottles, broken glass, electrical wires, tin cans, rubber shoes, Examination of $1 containers consigned to Verde Soko ~ investigation Report 2019 Page 3 of 122 ~~ Container | ‘Contents nylon nets, rubber gloves, metal rods PONU 1783061 Baca | hose, nylon nets _| Rubber, plastics, sack bags, foam, jute sacks, cloth, styrofoam, textiles, plastic hose, rubber, plastic bottles, glass bottles, tin cans, aluminum Plastics, tin cans, plastic 13 INBU 5235624 bottles, aluminum hose, rubber, broken glass, plastic straws, soil l Plastics, plastic cellophanes, ie MREU 6763599 PET bottles, rubber hose, sack bags, styrofoams, aluminum tin | cans, rubber, tin cans. HASU 4813319 Plastics, plastic straw, tin can plastic bottles, metals, | telephone wire, wood | chopsticks, foam, plastic cellophanes, sack bags, textiles, wood, aluminum tin cans | Examination of 1 containers consigned to Verde Soke inscotigation Report 2019 Page 4 af 72 ra 3. Oh January 4, 2019, the remaining thirty six (36) unopened container vans were examined; MRKU 595 876 2, PONU 132 877 2, PONU 79441 6, MRKU 467 347 2, MSKU 662 374 4, MRKU 012 339 6, MRKU 300 534 0, MRKU 565 828 2, MRKU 105 947 6, MRKU 439 562 2, CNIU 216 101 9, MRKU 017 002 1, MSKU 695 186 7, MSKU 007 440 0, MRKU 076 484 6, MRKU 089 671 3, MRKU 076 448 7, MAEU 637 235 8, PONU 1637401 4, Moxy 622 477 0, MRSU 385 953 1, MRKU 032 301 2, PONU 77143 2, MRKU 363 194 0, MSKU 172 644 1, TGHU 790 348 5, PONU 176567 0, MRKU 084 902 8, MRKU 022 513 0, MRKU 069 886 8, MSKU 861 386 9, MRKU 556 627 3, PONU 171991 0, MRKU 001 469 3, MSKU 115 504 4, and MSKU 629 275 4. These thirty six (36) containers, together with the first opened 15 containers are under the custody of the BOC and are in storage at the Mindanao International Container Terminal Service Ingoraorated, PHIVIDEC, Tagoloan, Misamis Oriental. 4, The following were the contents of the 36 container vans opened: CONTAINER ‘VAN CONTENTS 16 | MRKU 595 876 2 Mixed wastes (plastic bottles/cups, plastic cellophanes, Styrofoam, metals, diaper, rubber, foam, tin can, glass bottles, electronic wire, cable wire) 17 PONU 132 877 2 Mixed wastes (plastic bottles, tin can, glass bottles, styrofoam, electronic wire, sack, cosmetics, straws) 18 PONU 794416 Mixed wastes (plastic bottles/cellophanes, cable wire, net aluminum, shoes, umbrella, metal Styrofoam, rubber.) 19 MRKU 467 347 2 Mixed wastes (plastic bottles/cellophanes, aluminum, tin can, net, paper, toothbrush, Styrofoam, rubber slippers) 20 MSKU 662 374 4 Mixed wastes (rubber hose, plastic cellophanes, umbrella, Styrofoam, glass bottles, cloth, aluminum, cable, wire) al MRKU 012 339 6 Mixed wastes (plastic bottles, Styrofoam, tin can, plastic straw, glass bottles, sack, plastic cellophanes} 22 MRKU 300 534 0 Mixed wastes (Plastic cellophanes/bottles, umbrella, Styrofoam, tin can, toothbrush, metal) 23 MRKU 565 828 2 Mixed wastes (plastic cellophanes/bottles, cloth, aluminum, tin can, rubber gloves, shower hose, plastic straw, laminated plastic wrappers) 24 MRKU 105 947 6 Mixed wastes (plastic cellophanes/bottles, tin can, toothpaste, rubber slipper, plastic straw broken glass) 25 MRKU 439 562 2 Mixed wastes (plastic cellophanes/bottles, tin can, metal, rubber gloves, wood) CNIU 216 1019 Mixed wastes (plastic bottles/cellophanes/straw/gloves/spoon, tin can, printer, Styrofoam, cloth, electric fan) [Bramination of $1 containers consigned to Vande Sole ~ Investigation Report 2019 Page 6 of 12 Mixed wastes (plastic 27 | MRKU 017 002 1 | cellophanes/bottles/straws, tin cans, | sacks) Mixed wastes (plastic cellophanes/bottles/straws, tin can, 28 | MSKU 695 186 7 | oo c4s, cloths, broken glass, Styrofoam, paper box} Mixed wastes (plastic cellophanes/bottles/straws, tin can, 29 | MSKU 007 440 0 | “ith, glass bottles, electrical wire, broken glass) Mixed wastes (plywood, Styrofoam, plastic 30 | MRKU 076 484 6 | bottles/cellophanes/gloves/straws, tin can) Mixed wastes (plastic bottles/cellophanes, 31 | MRKU 089 671 3 | Styrofoam, umbrella, broken glass, vinyl tiles, rubber gloves, aluminum net) Mixed wastes (plastic cellophanes/bottles/straw, electrical wire, e-waste, razor blades, rubber, Styrofoam, keyboard, hose, sandals) 32 | MRKU 076 448 7 Mixed wastes (rubber hose, cloth, plastic 33 | MAEU 637 235 8 | cellophanes/bottles/straws, sandals, slippers, paper box, Styrofoam, foam) : Mixed wastes (appliance chord, plastic | bottles /cellophanes/straws/spoon, 34 | PONU 1637401 4 | aiuminum, broken glass, cloth, sandal, toothbrush, rubber slippers) Mixed wastes (plastic bottles/cellophanes, hose, tin can, broken glass, purse/bags, scissors, cloth, plastic lunch box, Styrofoam) 35 | MSKU 622 4770 Mixed wastes (plastic 36 | MRSU 385 953 1 | bottles/cellophane/straws, tin can, cloth, wood, broken glass) Mixed wastes (plastic bottles/cellophanes/straws, glass boitles, tin can, Styrofoam, notebook, keyboard, net) 37 | MRKU 032 301 2 j Mixed wastes (plastic i 38 | PONU 771432 | bottles/cellophane/lunchbox, glass j bottles, tin can, spray can) Bramination of 61 contairere consiznad to Verde Sake - investigation Report 2019 Page 7 of 12 39 MRKU 363 194 0 Mixed wastes (plastic bottle/ cellophane/straw, Styrofoam, tin can, metal, rubber ball, rubber slippers) “0 aL MSKU 172 644 1 TGHU 790 348 5 Mixed wastes (plastic bottles/cellophanes/straws, Styrofoam, tin can, bandage/gauze, glass bottles, broken glass, sacks) Mixed wastes (plastic bottles/cellophane, tin can, telephone wire, cloth, broken glass, Styrofoam, sack] 42 PONU 176567 0 Mixed wastes (plastic bottles/cellophanes/straws, cloth, tin can, e-waste, paper box, Styrofoam) 43 MRKU 084 902 8 Mixed wastes (plastic bottles/cellophanes, broken glass) 45 MRKU 022 513 0 Mixed wastes (plastic bottles/cellophanes/ straws, wood, tin can, electric bulb, Styrofoam, broken glass) MRKU 069 886 8 Mixed wastes (plastic bottles/cellophanes/straws, tin can, broken glass, Styrofoam) MSKU 861 386 9 Mixed wastes (plastic bottles/cellophanes/straws, tin can, paper box, Styrofoam) 47 MRKU 556 627 3 Mixed wastes (plastic cellophanes/straws/bottles, tin can, Styrofoam, cloth, paper box) 48 PONU 1719910 Mixed wastes (slippers, shoes, plastic bottles/cellophanes/straws, Styrofoam, wire, clothes, broken glass, headset, electrical wire) 49 MRKU 001 469 3 Mixed wastes (plastic bottles/cellophanes, wire, tin can, rubber boots, cloth, rubber shoes, cable wire, foil, plastic lunchbox, Styrofoam, rubber gloves) 50 MSKU 115 504 4 Mixed wastes (plastic bottles/cellophanes/straws, tin cans, broken glass, bags, paper box, cloth, sack burned plastics) MSKU 629 275 4 Mixed wastes (sacks, plastic bottles/cellophanes/ straws, broken glass, paper box, cloth) Figure 7 - The contents of the containers 5. The observations of the contents of each container were limited only at the container portal. Inside each of the remaining thirty six (36) containers were huge tonner bags of mixed wastes. Upon opening, the tonner bags were m open for visual examination. Figure 5 ~ The opened containers revealing the tonner bags en Bxamination of 51 contabers consigned to Vante Soko ~ Duestigation Report 2019 Page Gf 12 i Figure 7 - The contents examination . Other wastes identified during the examination were discarded printers, electric fans and keyboards which may contain lead, cadmium, mercury, hexavalent chromium, polybrominated biphenyls (PBs) and polybrominated diphenyl ethers {PBDEs} and busted LED lamps that may Contiin arsenic, These are identified as Waste Electrical and Electronic Fquipment (WEE) or “discarded electrical and electronic devices, including scrap materials intended for reuse, resale, recycling or disposal” is defined as Hazardous Waste in the DAO 2013-22. These wastes should be segregated and properly disposi in an appropriate disposal facility in order to prevent detrimental effect to the environment and human health. Ifthe hazardous wastes identified is improperly managed, the toxic Ghemicals as well as heavy metals contained within will probably bio- accumulate on the nearby rectiving water bodies or contaminate the soil. ‘foxic chemicals will later concentrate on the tissues of tolerant land or water organisms at successively higher levels in the food chain, “ Examination of 51 containers consigned to Verde Soko ~ Investigation Report 2019 Page 10 of 1 Ill. REMARKS: 1, The shipment of the 51 container vans declared as “synthetic plastic flakes” of VSPIC is not covered by pre-importation clearance required under DENR Administrative Order 2013-22 for “Importing recyclable materials containing hazardous substances without securing import clearance.” 2. Based on the findings of the series of inspections conducted on the 51 container vans showed that the container vans that supposed to contain. “plastic synthetic flakes” were found filled with mixed wastes containing assorted materials. This is in violation of the condition for the importation of solid plastic materials stated in DAO 2013-22, Table 10.1 which states that “No importation of heterogeneous and unsorted plastic materials shall be allowed.” 3. The imported wastes consist of mixed plastic wastes categorized under Waste No. Y46 listed in Annex II of the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their disposal str'ctly prohibits the export or movement to another country or Party to the Convention. IV. RECOMMENDATIONS: 1. The imported mixed plastic wastes should be shipped back by the Importer to the country of origin at their expense. 2. To ‘minimize possible leakage it is recommend, that the following containment measures be implemented but not limited to: a. Dry-up and/or remove moisture inside the containers. ». Provision of containment lining facility inside the containers at the portal area to prevent accumulated moisture to possibly leak out through the doors. Containment lining could be in material of: * Cement powder lining © Limestone powder lining «Absorbent cloth /material lining * Bentonite clay lining c. Emplacement of duct tape on the door lining at the exterior of the containers “Ww Beamination of S1 containers consigned fo Verde Sako ~ Investigation Report 2019 Page 11 of 12 j 3. A Notice of Violation (NOV) should be issued to the coy following grounds: . a. Importation of mixed plastic wastes without Importation Registration and Importation Clearance before shipping the mixed plastic. b. Non-compliance in the stated limiting condition for the importation of ‘solid plastic materials on Table 10.1 of DAO 2013-22, which states that “No importation of heterogeneous and unsorted plastic materials shall be allowed”. CHRISTOPHER €. MABAYLAN ENGR. IT JANS:! ‘U. JUMAU-AS Senior &MS Recommending Approval: Examination of 61 containore consigned to Verda Soko ~ frvestigaton Report 2019 Page 12 of 12, Republi the Piipines Department of Environment and Natural Resources 3 ENVIRONMENTAL MANAGEMENT BUREAU Office of the Regional Director Ce) eater ese, ‘The following ate the list of persontiel who conducted the examination of temalning thirty six (36) unopened container van consigned to Verde Soko Philippines Industrial Corporation located at Tagoloan PHIVEDIC Industrial Authority on January 4, 2019, to wit; NAME OFFICE/AGENCY 1. i0-1 JOEL PINAWIN BUREAU OF CUSTOMS 2.. 10-1 OLIVER VALIENTE BUREAU OF CUSTOMS 3. EZEL RAGANDANG MAERSK SHIPPING LINES 4. SA-II ABDEL SULTAN BUREAU OF CUSTOMS 5. CHRISTOPHER A. MABAYLAN EMB-DENR 10 6. MARICRIS M. MORENO EMB-DENR 10 T. JASON T. BELGA EMB-DENR 10 8. JANSSEN BLAISE U. JUMAU-AS EMB-DENR 10 Prepared by; (8 M. MORENO ‘DMS: Save the Ozone Layer ‘Republi of he Pitipinse Department of Environment and Natural Resources ) ENVIRONMENTAL MANAGEMENT BUREAU. Office of the Regional Director Region-10, Masala, Cagayan de Oro City Telex No, (8) 856-9562 “the following are the list of personnel who Conducted the examination of at fount fifteen (45) container vans consigned to Verde Soko Philippines Industrial Corporation located at Tagoloan PHIVEDIC Industrial Authority on November 27, 2018, to wit; NAME OFFICE/AGENCY 1, JOHAMED L. PENDUMA. EMB-DENR 10 2. CHRISTOPHER A. MABAYLAN EMB-DENR 10 3, JANSSEN BLAISE U. JUMAU-AS. EMB-DENR 10 4, JASON T. BELGA EMB-DENR 10 5. BEN-ALI P. DECAMPONG. JR. EMB-DENR 10 6. ROSALINDA S. NAMATA VERDE SOKO PHIL. INDUSTRIAL 7. RONNIE ANTONIE E. YLAYA BUREAU OF CUSTOMS. 8. OSCAR M. GUAN BUREAU OF CUSTOMS: 9, RODIL P. FLANCIA BUREAU OF CUSTOMS 10.SA-II RENAN Q. AZUER BUREAU OF CUSTOMS. 11,SA-I JONATHAN L. BELMONTE BUREAU OF CUSTOMS. 12.SA-II GARY N. SICAT BUREAU OF CUSTOMS Prepared by: ay am Tere CH TEES Cw ETAT ‘Save the Ozone Layer ' | Republic of the Philippines Department of Finance Bureau of Customs Port of Cagayan de Oro Collection District x Cagayan de Oro City CONCURRENCE ‘hat we hereby concur to the Consolidated Report based on the series of Investication/ Inspection conducted by Environmental Management Bureau-Department of Environment and Natural Resources (EMB-DENR) and Bureau of Customs personnel on the 51x40 containers imported and declared by Verde Soko Philippines Industrial Corporation as “plastic synthetic fakes” and found to contain "mixed wastes“in violation of DENF: Department Administrative Order No. 2013-22 which implemented the provisions of Republic Act 6969 (The Toxic Substances and Hazardous and Nuclear Waste Control ‘Act of 1990) and found by this office without import clearance and misdeclared in violation of Sec, 117 in rel Sec. 1400 of the Customs Modernization and Tariff Act. COLL. JOHN P, SIMON ATTY. ROSWALI 1H J. PAGUE Port Collector Deputy Collecto} iministration/ Mindanao Container Terminal Sub-port Chief, kaw Bivision ATTY. FLOR¢ HAN, JR. Dist liector ce: EMB-DENR-10 Phividec industrial Authority Sealand-Maersk Shipping Lines DECISION This case arise from the importation of twenty forty containers (20x40) anid thirty one forty containers (31x40) of Plastic Synthetic Flakes by Verde ‘Soko ‘Philippines Industrial Corporation; from Green Soko Go. Lid, Pyouigtiek, Korea which attived on October 21, 2018 at the Mindanao Container Terminal Sub-port, Tagoloan, Misamis Oriental. ‘The’ consignee, Verde Soko, for purposes of brevity, is. a companfflocator of Phivedes Industrial Estate, a special’ economic zone created under Presidential Decree No. 538, as amended. Qn October 25, 2018 an Alert Order No, CDO119-2018 was issued by Ally, Flos G, Calixiban, Jn, District Collector against the above stated shipments of Verde Soko Philippines Industrial Corporation for violation of Sees, 117 and 1400.of the Customs Modemivation and Tariff Act, Further, on November 16, 2018 a Warrant of Seizire and Detention (WSD) was subsequently issued on the subject shipment. At-the hearing that ensued oa December 3, 2018, Verde Soko Philirines Industrial Corporation was represented, Atty. Mario Juni and the Bureau of Customs by Atty. Melvin S. Tan Jr. ‘Daring the heating, upon Motion of the Goverment Prosecutor, the two seizure tases wets consolidated. ‘Thus at the Preliminary Conference, ‘the Governniént Prosecutor marked in eviderice the following exhibits: EXHIBIT NUMBER | NATURE OF THE DOCUMENT A ~[inward Foreign Manifest EB ‘Warrant of Seizure and Detention No, 28-2018 fe | Dao No 13-22 series 2013, i “Table 10 of Recyclable Materials ! o TEMB-DENR 10 Report { | investigation Inspection 2018 No. 025 [Te carnposed of eight (8) pages with attached] attendance sheet and Mission Order, ~. TE -—_Bestnote issued by the Bureau of Custonis Likewise, the Government Prosecutor adopted the same exhibits {i Setaute Identification No, 28-2018 except for the Warrant of Seizure and Detention‘and marked instead the Warrant of Seizure No. 31-2018. Ox the other hand, Atty. Mario Juni, legal counsel for Verde Soko, smacked die following exhibits as follows: EXHIBIT "| NATURE OF DocuMENT ~~ NUMBER . i ‘Articles of incorporation 2 General information Sheet of ie Corporation a Phividec Industrial Authority Certification of Registration as Locator , BOC Certificate. of Registration . 5 [ BIR Registration dated June 19,3015 6 HECC issued by DENR 7 Flow Chart exhib ofthe processing System 1 ofthe Consigaee ar Application for import Clearance 19156 3 Analysis Report dated December 15, 2018 Jssued by the Ministry of Enviroment Korea 0 ‘Boatnote issued by BOC Ea Copy of the DENR ADM Order No 2.51 5) DENR Department Administrative Order Nov 19-22 is Contificate of Authentication Tasued bythe Philippine Embassy in Seoul South, Keres “s - Theteafter, the’pattics proposed the followitig issues to bé resolved as follows: ; %. : 1. Whether“ar aot SERDE SOKO bas violated any provisions of the Costonis Modertization and Tariff Act with the importation of fifty- one Gl) “forty footer (51x40) coniainers. said to. contdin “SYNTHETIC PPLASTIC FLAKES?” 2. Whether or not VéFde Soko violated DENR’ Department Admaistrative Order 13-227 i = Since the issues are closely intertwined with each other, the same shall be resolved jointly. The parties then are required to submit their respective Position Paper and Comment respectively within five (5) days from the termination of the Preliminary Conference, However, since i Respondent Verde Soko submitted its Position Paper beyond the preseribed period, thus, if shall be deemed a waiver on its part to submit the same. Hence, upon Motion of the Government Prosecutor, the case was submitted for r2solution pursuant to the Manual of Procedure for Forfeiture Cases. Tran be recalled that on October 21, 2018, the shipment of Verde Soko Philippines Industrial Corpotation consisting of twenty forty footer containets (20x40) and thiny one forty footer containers (31x40) of “plastic synthetic flakes” arrived at the Mindanao Container Terminal Sub- Port in Tagoloan, Misamis Oriental. However, Respondent failed to file its ‘goods declaration after the lapsed of 15 days front its aival, hence, the shipinents. were considered .as deemed abandoned in favor of the § government, On the other hand, as testified during the hearing, by Mr. Johamed L, Penduma of EMB-DENR-10, a Report issued by Environment and Management Bureau (EMB) of the Department of Environment and Natural ‘ . Resources on November 28, 2018, after the conduct of inspection and ‘investigation, stated therein that “(1) the contents of the fifteen (15) containers were mixed waste, which are composed of plastics, metals, wood, rebber, soil, textiles, and electronie'wastes which includes cellphone batteries, chargers and dry cell batteries. There are therefore, not in accordince with what was declared in the Bill of Lading. (2) Verde Soko has violated the provisions of Table 10.1 of DAO 2013-22 or the Implementing Rules and Regulations of RA6969 or the Toxic Substances and Hacardous and Nuclear Waste Control Act of 1990 for undertaking ‘importation of materials without having secured the Importation Clearance from EMB Central Office." xxx xcx moe xe. Based on the above cited Report, it is clear that the declaration of Verde’ Soko: Of the shipments. of 20x40 and 31x40 containers ste j “spnthietic plastic’ flakes” in the Bill of Lading is false, constituting + misdeclaration of the shipment. No less than the Customs Modernization and Tariff Act (CMTA) provides that misdeclaration is committed by wrong description ‘of the gous, to wit: “Section 1400. —-Misdeclaration, —_Misclassification, Unidervaluation in Goods Declaration. Misdeclaration as to quantity, quality, description, weight, or measurement of the goods, of misclassification’ through’ insufficient: or. wrong, description of the goods or use of wrong tariff heading resulting... < "to a discrepancy in-duty and tux tobe paid between what is * lcgally determined upon assessment and what is declared. 200 * x SHOR WAI 900K 200K A discrepancy in duty end tax to be paid between what ‘is Iegally: determined aod what is'declared amounting to more than thirty percent (30%) shall constitute.a prima facie evideust of fraad.” Nevertheless, the Supreme Court riled dhat'to warrant the forfeiture ofa shipment, thiere most be fraud, “rand” is never presumed. vo Algar, as witout Farolan, we cle that the fraud contemplate by law must be acmal and: ‘ =, gether fe inegtonl couse of ‘deception willfully and deliberately dose or rxoxted ‘tin onder 10 induce another to give up-tome right (Leansplobe “International, Ine vs. Court. of : ‘Appeals aud Comilssfonior of Customs, GR. No, “126634 January 25, 1999), Since. it was clearly established by, compelling evidevce that the sshipment’ of Verde Soko, Philippines Industcial Corporation fins been misdectared, hence, the shipment is subject to forfeiture. On the other hand, Respondent Verde Soko also failed to present daring the heating its covering Import Permits covering its shipments fom Environment Management Bureay, DENR Central Office, thus; violating Sec. 117 of the RA10863 otherwise known as the Customs Modemization and Tariff Act. Sec: 117 of the CMTA, provides; “Section 317. Regulated Importation and Exportation — Goods which are subject to regulation shall be or exported ing the n ‘goods declaration ot export declaration, clearances, licenses, and_any_other_requirems jot to importation or exportation. in case of importation, submission of, sequirements after arrival of the goods but prior to release from customs custody shall be allowed but only in cases “provided for by governing laws or tegulations.” Relatively, since, no import permits has been issued by FMB Central Office; the shipment of twenty forty footer containers (20x40) and thirty one forty fedter containers (31:40) of “plastic synthetic flakes” which axived’at the Mindaiizo Container Terminal Sub-Port in Tagoloan, ‘Misamis Oriettel, thus, violated the above proviso, hence; forfeitable. "Nenethéldg, subject shipments also violated DENR Department Administrative @rder No, 22-2013 (Revised Procedures and Statidards for the Matiagemat of Hazardous Wastes (Revising DAO 2004-36) as clearly ‘pronounced in the above stated Report of EMB-DENR having been found to concaitimixed waste WHEREFORE, by virtue of the authority vested in my by law, the allegations of. misdeclaration and Jacked of Import pemait from Environment: and-Management Division (EMB) of the Department of Environment ant Natural Resources DENR, having been established by ~fullicient evidence, itis hereby ordered that the shipment of twenty forty containers (20x40) and they one forty containers GBix40) of “plastic Synthetic fakes” subject oF the above proceedings, is hereby FORFEITED IN FAVOR OF THE GOVERNMENT OF THE PHILIPPINES. However, since the subject shipments of fifty one (51) forty containers of “plastic Snthetic flakes” having, found to contain mixed waste which includes toxic ‘materials thus, considered a5 injurious to public health, the same is SO ORDERED. Port of Cagayan de Oro, December 13, 2018 ATTY. FLORO os RR District Collector Republic of the Philippines Department of Finance Bureau of Customs Port of Cagayan de Oro Cagayan de Oro City Republic of the Philippines, SEIZURE IDENTIFICATION Praintitt, NO. 31-2018 versus 34X40 CONTAINER NOS. MRKU0896713 MRKU1059476, CNIU2152850, PONU1765670 PONU1637494, MRKUO170021, MSKU6623744 MRKU0014693, MRKU0123396, MSKU6224770 MSKU6951867, PONU1783061, PONU719910 MRKU0849028, MRKU0763599, MRKU4673472 MRKUO323012, MRKU0880661, MRKU0098420 PONU1328772, MSKUG438828, MSKU6707824 MSKU6292754, MRKUQ698868, CNIU2161019 MAEU6372358, INBU5235624, MRKUO764487 MRKU0086543, MRKU0764487, MRIU0086543 MRKU0225130, MRKUD764846 STC: PLASTIC SYNTHETIC FLAKES VERDE SOKO PHILIPPINES INDUSTRIAL CORPORATION Consignee. xX what TO: SP/CAPT. ANGELITO S, NAVARRO District Commander CPD-ESS This Port Posaunen 101 JOEL C. PINAWIN TOIC-Chief, Customs Intelligence and Investigation Service (CHS) This Port Greetings! WARRANT OF SEIZURE AND DETENTION WHEREAS, a shipment consigned to Verde Soko Philippines Industrial Corporation consisting of 31x40 containers ste: Plastic Synthetic Flakes arrived at the Mindanao Container Termisial on October 21, 2018 under Bill of Lading No. MCB452902; WHEREAS, an Alert Order No, CD0-119-2018 was issued by Atty. Floro G. Calixihan, 3r., District Collector upon the request of 101 Joel C. Pinawin, Supervisor, CUS “a ageinst the subject shipment on October 25, 2018 for violation of Sec.417 and Sec.1400 of RA 10863 (Customs Modemization and Tariff Act); WHEREAS, in two separate Memorandums of Dir. III Yogi Filemon L. Ruiz, Director, ESS and 101 Joel C. Pinawin, Supervisor, CIIS Cagayan de Oro bota dated November 7, 2018, they recommended for the issuance of Warrant of Seizure and Detention (WSD) for lack of Import Permit from Environmental Management Bureau of the Department of Environment and Natural Resources (EMB-DENR); WHEREAS, it was stated in the email reply of Geri-Geronimo R. Bafiez, Chief, Hazardous Waste Management Section, Environmental Management Bureau, Central Office, Quezon City, Manila to Atty. Allen Dela Cruz of the Environmental Protection Unit of the Enforcement and Security Services (ESS), Manila dated October 30, 2018 “that the shipments of Verde Soko Philppines Industrial Corporation was without claranice from their office’: NOW, THEREFORE, by virtue of the authority vested in this office in accordance with Republic Act 10863 (Customs Modernization and Tariff Act) and relevant customs rules and regulations, you are hereby ordered to forthwith take physical possession and custody of the above-described 31x40 containers which contained “Plastic Synthetic Flakes” and tum over them to the Property Custodian/Warehouse-In-charae, this Port for safekeeping, pending termination of the seizure proceedings thereon or untl ferther orders from this office, pursuant to and in strict compliance with the provisiorts of CMO 8-94 particularly on the matter of making a return of service and the submission of the Inventory Report or list of the articles seized. Port of Cagayan de Oro, 16 November 2018. ATTY. Fi i. HAN, IR. Di ce: ‘The Commissioner of Customs ‘The Deputy Commissioner, AOGG ‘The Deputy Commissioner, EG te ‘The Deputy’ ‘The Chairman, ACDC, This Port Copy posted: Bulletin Board, this Port Republic of the Philippines Department of Finance Purean of Customs Port of Cagayan de Oro Cagayan de Oro City Republic of the Philippines, SEIZURE IDENTIFICATION Plaintift, NO, 28-2018 versus 20X40 CONTAINER NOS. MSKU1726441, MRKU5566273, MSKUS613869, MRKU5958762 ; MSKU0074400, PONU7660948, MRKU3005340 é | tlie ‘TGHU7903485, MRKU3613252, MRKUSG58282 MRKU4595467, MRKU3631940, MSKU1155044 PONU7944116, PONU7771432, MSKU1852619, HASU4813319, MRSU3859531, MRKU4395622, RXU9370724 i STC: PLASTIC SYNTHETIC FLAKES 2 PO ey “ee VERDE SOKO PHILIPPINES INDUSTRIAL cer VEn* CORPORATION oN Consignee. I Padi TO: SP/CAPT. ANGELITO S. NAVARRO [sl District Commander y CPD-ESS posmwfer S/o This Port : Menage. 101 JOEL C. PINAWIN JOIC-Chief, Customs Intelligence and Investigation Service (CIS) This Port Greetings! WARRANT OF SEIZURE AND DETENTION WHEREAS, a shipment consigned to Verde Soko Philippines Industrial Corporation consisting of 20x40 containers stc: Plastic Synthetic Flakes arrived at the Mindanao Container Terminal on October 21, 2018 under Bill of Lading No. 578259588; WHEREAS, an Alert Order No. CDO-119-2018 was Issued by Atty. Floro G. Calixihan, Jr., District Collector upon the request of 101 Joel C. Pinawin, Supervisor, CIIS against the subject shipment on October 25, 2018 for violation of Sec.117 and Sec.1400 ‘of RA 10863 (Customs Modernization and Tariff Act); WHEREAS, in two separate Memorandums of Dir. TH Yogi Filemton L. Rutz, Director, ESS and 101 Joel C. Pinawin, Supervisor, CIIS Cagayan de Oro both dated November 7, 2018, they recommended for the issuance of Warrant of Seizure and Detention (WSD) for lack of Import Permit from Environmental Management Bureau of ‘the Department of Environment and Natural Resources (EMB-DENR); WHEREAS, it was stated in the email reply of Geri-Geronimo R. Bafiez, Chief, Hazardous Waste Management Section, Environmental Management Bureau, Central Office, Quezon City, Manila to Atty. Allen Dela Cruz of the Environmental Protection Unit of the Enforcement and Security Services (ESS), Manila dated October 30, 2018 “that the shipments of Verde Soko Philippines Industrial Corporation was without clearatice fom their office’: NOW, THEREFORE, by virtue of the authority vested in this office in accordance with Republic Act 10863 (Customs Modemization and Tariff Act) and relevant customs rules and regulations, you are hereby ordered to forthwith take physical possession and custody of the above-described 20x40 containers which contained "Plastic Synthetic Flakes” and turn over them to the Property Custodian/Warehouse-In-charge, this Port for safekeeping, pending termination of the seizure proceedings thereon or until further orders from this office, pursuant to and in strict compliance with the provisions of CMO $94 particularly on the matter of making a return of service and the submissian of the Inventory Report or list of the articles seized. Port of Cagayan de Oro, 16 November 2018. ATTY. FLORO. LUDCHAN, J. Collector ‘The Deputy Commissioner, 16 ‘The Chairmen, ACDC, This Port ‘The Warehouse-in-Charge, This Port ‘The Resident Auditor, COA, This Port. Copy posted: Bulletin Board, this Port T=] Bregs 9% January 15, 2019 | /t 4 The District Collector Bureau of Customs Port of Davao ‘asa, Davao City sir, DISCHARGE PERMIT is hereby eequested for MAERSK / SEALAND MAERSK COMPANY CONTAINERS LADEN ON BOARD M/V KALLIROE V 852S-903N was loaded from CAGAYAN DE ORO in will discharge SASA PORT for co-loading ETA January 20 2019 @ 0100hrs. In this regard. May we request the presence of custom personnel to please stand by during actual discharging operation to inspect. (SUBJECT TO CHANGE) QUANTITY ESCRIPTION 51 x 40 ‘DRY = DRY FULLS CONTAINERS 20 ‘DRY = DRY FULLS CONTAINERS x 20'RF= RF FULL CONTAINER ‘TOTAL CONTAINERS FOR DISCHARGING: FULLS CONTAINERS _/ EMPTY CONTAINERS ‘Thank you very much for your King consideration on this matter. FOR MAERK LINE / DAVAO riboy P. coauita Operation General Santos / Davao Supervisor Timon granted subject to custom aws, rues and regulation provided that no withérawal of ull Containers shall be made unless entry is FLED. Pr SALIC PANGANDAMAN sci ci ESS-CPD Davao District Office District Commander SUHARTO A. SUMAYAN Chief Cargo Control Unit Republic of the Philippines Department of Finance BUREAU OF CUSTOMS Port of Cas de Oro MCT-TAGOLOAN MIS. OR. TO. : The Customs Inspector on Board MV:_SPECTRUR N v.904N/oR suus Date SPECIAL PERMIT FOR CO- SLOADING SPECIAL PERMIT TO LO. COMMODITY : HETEROGENEOUS PLASTIC guTpPING LINES: _ MAERSK LINE att eee QUANTITY ;___51x48 CTNRS. DESTINATION SOUTH KOREA VALUE 14214,199 KGS EXPORT DECLARATION No._!0¢] 4) ATTACHED ARE: xx application for SPL Permit OTHER INFORMATION, ecie CAMPI we Sahrore, wenee sain PAL TNDUSTRIAL PRODUCTION. SUPERVISOR NEeTGORN . SIMON a eae stent * Port Collector of Customs’ OPY FOR CO-LOADING EXPORT DECLARATION p.5,¢ 9; _ DAVA® Department of Trade ard Industry ‘Eso F Soper: hae 0 VERDE SOKO PHIL INDUSTRIAL CORP. SITIO -BUGUAC, BRGY. STA. CRUZ, TAGOLOAN, MISAMIS ORIENTAL 9001 PHILIPPINES Choo Cireze Clouse F)sunie CJoriens in soem (fe o Ceca MCT-TAGOLOAN MIS. OR. (4-o1-11- 060) | N41, 204 MERE STKY ED. , LTD 80-94, HANYUJI-GIL, POSEUNG-EUP, PYEUNGTAEK-SI, GYEONGGI-BO KOREA Gaara cal Tel. +82 70 5066 0881 Fax +82 70 S066 0885 ahora MISAMIS ORIE! Gory eaten Tat | SOUTH KOREA “SRTEHET™L. canPILan ca a AV SPECTRUM N V,9@4N/OR SUBS. PRODUCTION SUPERVISOR me ial VEROE SOKO PHIL INDUSTRIAL CORP. isco oee TAGOLOAN, MISAMIS ORTENTAL MV KALLIROE v.8525 feacrdeciea an Tere Pareto ste ama pores McT-Tagelean January 13, 2019 Terms etPorit: —[] wn ron ci tom ra taaroe a Nev ae stemrenioeenraioes ‘Sooo ee 51x40 - HETEROGENEOUS PLASTIC WASTE 3915.3090 1,211,199 KGS» Ft eam nemare com amma tree ore = ae fi aaa : (PLS. SEE ATTACHED COPY OF DECISION/ i Fon RE-EXPORT ORDER FOR THE COMPLETE List |; OF CONTAINER/SEAL NOS. 20x48 AND 31x49) |, ! a cd ay fier [= vecrston oF soc oc, 13, 2018 seIZURE 101 Bf SEIZURE IOENTIFICATION NO. 81-2018 FOR & xt | — Re-EXPORTATION ORDER BEC. 18, 2018 SIGE! cusTons. ENTII 1x40. ‘BY THE DIST — INVESTIGATION/INSPECTION REPORT OF EMB-BENR X JAN. 58 We hereby crty al documeri nd ncmaonpoaiced ora pov aren ‘10 tothe Beal of our knowledge and bellat ve and correct » 28-2018 FOR 20x40 RICT coi F a i. enw ATO) NO-20I4 ~OFITO cAMP, PACH LU PRODUCTION SUPERVISGR § jOSC My cian ‘Preved Name: Deciarers Printed nempisioneire Terminal «reeae® recon ite owe —— LAN 2019-— AUTWORIZATION Tr AVTHQREATION nt ene: sn Ae: Trmaramaoaae Sa Tenement roam nacre gor spate ay BOS Copy NGO Ca OF 28.1. 1218..39232 (2896905234998 41.80 lb 850 heen ren asain ronan "con Complete lists of container nos. and seal nos. of the 51x40' split in 20x40' and 31x40" container vans re-exported to South Korea by VERDE SOKO PHILIPPINES INDUSTRIAL, CORPORATION which are said to contain HETEROGENEOUS PLASTIC WASTES, CONTAINER NUMBER EAL NUMBER CRXUNSTOT2A MLPHI201091 HASUAEII19 MLPH201 140 MRKU3005340 MUpHi201102 MRKU36I3252 MLpa1201121 MRKUIG91940 MLPHI201162 MRKUA95622 MLPH201104 MRKUAS95467 MLPHI201068 MRKUSS66273 MUPHI201069, MRKUSGS8282 MLPHTIZO1103 MRKUS858762 MLPHI201160 MRSUIBS9S31 MLPH 201165 MSKU0074400 MLPHI201152 MSKUIIS5044 MUPHI201070 MSKUIT26441 MUPHT201163 MSKUISS2619 MLPH1201096 MSKUBSIIE69 MLPHI201098 PONUTSCO9A8 MUPHTI201122 PONUTI71432 MUPHI201067 PONUTO#AI16, MLPHI201158 TOHUTSO8S MUPH2010665 TOTAL: 20x40' CONTAINERS ‘CONTAINER NUMBER: SEAL NUMBER ‘eNTU2152850 ‘MLPHI201124 eNIU2I61019 MLPHI201155 INBUS235624 MLPHI200161 MABUS372558 MLPH120106¢ ‘MRKUOO!4693 MLPH1201136 MRKUD0B6543 ‘MLPH1201093 MRKU0098420 MLPHT201125 MRKUOIZ5396 ‘MLPHI201101 MRK.UOF70021 MLPHI201154 mRKU0225130 MLPHI201061 MRKUD323012 MLPHI201099| MRKUDESSS68 MLPHI201094 MRKUD763599 ‘MLPH1201097 Page | of Pae 2 MRKUOTBGA87 MLPH1201062 MRKUOTEA8AS MLPHI2O1I6& MRKUDEAD028. MLPHIROUIST MRKUNRRO661 MLPHIZO1 168 MRKUGS9ETI3 MLPHI201005 MRKUIO59476 MLPHI201105 MRKUAG73472 MUPHI2OU1S7 MSKUS224770 MLPHI201138 MSKUG292754 MLPHIZOTSI MSKUSA8882 MLPHI201082| MSKUS623744 MLPHIZONI56 MSKUSTO7E24 MLPHI201125| MSKU6951867 MLPHI201155| PONUI328772 MLPHI201159 PONUIESTA94 MLPHT201065 PONUITISNO MLPHI201065| PONUI76S670 MLPHI201139 PONUITE3O61 MUPHT2O1151 1x40" CONTAINERS Prepared by: SARIP/B, MAROHOMSALIC Chidf, Cargo Control Section Page 2

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