On October 28, 2016, the Administrator of the United States
Environmental Protection Agency (EPA) signed a
rule finalizing significant modifications to
the requirements governing the export and import of hazardous
waste. The rule changes will go into effect on December 31, 2016,
although, as discussed below, certain requirements will be phased
in over time. The changes will affect transboundary shipments
currently subject to 40 C.F.R. Part 262 Subpart H (regulating
hazardous waste shipments for recovery between the United States
and countries that are members of the Organisation for Economic
Co-operation and Development (OECD) other than Mexico and Canada),
as well as shipments currently subject to Subparts E and F
(regulating all other hazardous waste imports and exports). The
modifications make certain substantive changes to the requirements
of Subpart H, as well as expand the scope of that subpart to cover
transboundary shipments currently subject to Subparts E and
