China’s Scrap Import Restrictions and Impact on Global Supply Chains

China’s Scrap Import Restrictions and Impact on Global Supply Chains

Executive Summary

  • From July 1, China imposed restrictions on imports of Category 6 products, which largely consists of high-grade scrap metals, that will be shifted from an ‘unrestricted’ to ‘restricted’ import catalogue and regulated through import licenses and quotas. The latest restrictions come following a Category 7 import ban on 32-types of scrap products and as part of Beijing’s efforts to cut solid waste imports to zero by 2020.
  • The combination of Category 6 and 7 restrictions threaten to create significant supply chain disruptions both for refiners who use scrap as raw material input and manufacturers who blend the scrap into their products. Since Beijing adopted its environmental campaign against solid waste in 2017, China has reportedly cut scrap imports by over 40 percent in 2018. Import volumes for scrap copper fell from 3.6 million tons in 2017 to 2.4 million tons this past year with Malaysia now emerging as the largest supplier of scrap to the Chinese market. 
  • Scrap metal exporters to China face challenges in being able to send scrap metals products amid ambiguity over different scrap categories, heavy port congestion due to restricted designated ports, longer customs processing times, and complying with strict contamination standards. China-based scrap importers and manufacturers could come across challenges when applying for licenses, quotas, proof of financial stability, and manufacturing conversion capability of scrap into refined materials.
  • Scrap metal traders face prolonged inspection on metal scrap containers and significant congestion at key seaports across China with an average vessels’ waiting time for up to 13-15 days. Since 2019, China has designated 18 specific ports that are permitted to accept solid waste imports including scrap metals including the Ports of Dalian, Fuzhou, Guangzhou, Huangpu, Nanhai, Nansha, Ningbo, Zhoushan, Qingdao, Shenzhen, Taicang, Tangshan, Tianjin, Waigaoqiao, Wuzhou, Xiamen, Xinhui, and Yangshan.
  • While most Chinese metal scrap producers have moved to other Asian markets to avoid strict regulations, rising challenges remain due to recent policy changes on scrap waste imports in Southeast Asian countries like Malaysia, Vietnam, Indonesia, Cambodia, and Thailand. At the same time, Chinese domestic metal recyclers are gaining momentum and embracing new changes within China as the global metal recycling industry continues to adapt. 

Background

Effective from July 1, 2019, China has restricted imports for an additional eight different scrap categories for Category 6 products that largely consist of high-grade metals. Although falling short of an outright ban, the government will shift Category 6 scrap items from an ‘unrestricted’ into a ‘restricted’ category, which will be regulated through import licenses and require quotas under the new policy. 

The latest move follows a series of measures taken to restrict scrap imports as part of Beijing’s objective of reducing environmental pollution and banning all scrap imports, including metals, by 2020. In July 2017, Beijing announced that it would be banning the import of 24 types of solid waste from January 1, 2018. This was followed, nearly a year later, by an announcement from the Ministry of Ecology and Environment (MEE) on April 19, 2018 that China would be banning 32 types of scrap materials in two phases. The first batch consisted of 16 types of scrap metals (referred to as Category 7) and included motor, wire, and cable scrap and came into effect on December 31, 2018. The remaining 16 types of banned scrap imports – which include some forms of stainless steel, auto, and vessel scrap – are set to come into effect on December 31, 2019.

Beijing’s concerted efforts to restrict scrap imports, particularly metals and plastics, has placed considerable pressure on foreign scrap exporters and China-based manufacturers who rely upon raw material inputs to blend the scrap into their products. For instance, the combination of the Category 7 ban and retaliatory tariffs on U.S. copper scrap imports have drastically decreased shipments from 688,000 tons (2017) to 275,000 tons (2018) to the point where it has created a shortage of recyclable raw materials that China-based manufacturers can use. Other regulatory barriers include strict licensing and quota requirements, inspection standards, heavy port congestion and longer customs processing times, and contamination standards that are considered to be technically infeasible.  

As part of the ongoing U.S.-China trade war, China also recently announced that certain U.S. scrap commodities including aluminum and copper will be subject to an additional 5% tariff on top of those imposed in 2018 effective from December 15, 2019. The additional tariffs bring the total tariffs for U.S. imports to 30% for copper and 55% for aluminum. 

Category 6 Scrap Import Restrictions

Since July 1, the new Category 6 scrap import restrictions have transferred eight different types of scrap metals – which include high-grade scrap cast iron, alloy steel, iron and steel, copper, and aluminum  – from an ‘unrestricted’ to ‘restricted’ import catalogue that will be regulated through import licenses and quotas. 

China is the world’s largest importer of copper and aluminum scrap metal. Copper (HS Code 7404.00.0090) and aluminum (7602.00.0090) scrap and waste are the most significant items under Category 6, which can be recycled into new metal or used as a direct-melt by fabricators making copper products. China represented 36.1% of global scrap copper imports in 2018 with the largest exporters coming from the U.S. (14.2%), Hong Kong (13.9%), Japan (10.4%), and the United Kingdom (6.3%). For aluminum metals, which are similarly recycled and used for end-of-life products such as containers, vehicles, appliances, and industrial machinery, China accounts for 15.8% of world imports with the U.S. (32.5%), Hong Kong (14.5%), and Canada (7.7%) as the largest exporters. The remaining Category 6 scrap metals are either not imported into China or make up a relatively minor share of global imports. 

The Category 6 items largely differ from Category 7 (see Appendix Tables 2 and 3) in that it refers to materials with copper content of between 55 and 97 percent, which can be re-used directly in manufacturing as well as an extension of Category 7 scrap with less metal content. The Category 6 restrictions are mostly aimed at limiting the import volume of Category 7 scrap, which contains more impurities and a lower metal content while encouraging cleaner scrap which requires less processing. For instance, Category 7 copper scrap typically consists of lower-grade material such as radiators and engine motors that need to be dismantled before the metals are eventually extracted. The Category 7 restrictions focus on two different sets of 16 types of scrap products: the first set of 16-types of scrap came into effect on December 31, 2018 and largely consisted of scrap vessels and iron and steel slag; the second set of 16-types of scrap metals, which comes into the effect on December 31, 2019, includes items such as scrap stainless steel, tungsten, magnesium, and titanium.

Quota and licensing restrictions imposed

Companies that wish to keep importing Category 6 items are required to apply for import licenses and quotas from the MEE and demonstrate that they have the capacity to process the imported scrap into refined metal or semi-finished products such as copper cathode or rods. 

On April 19, Chinese environmental authorities announced that provincial departments of the MEE would start collecting applications for import licenses for Category 6 items from late May. Only plants that engage in copper scrap smelting and processing are allowed to file an application and importing firms would be subject to audits for accounts and finances as part of the approval process. Interim quotas have also been brought in place that will be set at a quarterly basis as part of China’s broader aim of banning all imports of metallic scrap below 99 percent purity by the end of 2020.

On June 20, the MEE issued its first batch of quotas for the country’s scrap metal importers which are valid for Q3 2019 with additional rounds of quotas to be released in the coming weeks. The first round of import quotas, which affect a total of 123 metal scrap importers, was mostly focused on Chinese copper scrap importers particularly in the Shanghai, Jinghua, Ningbo, and Taizhou regions but also include quota volumes for aluminum and ferrous scrap. On July 10, a second batch of scrap metal import quotas totalling 436,930 tonnes of copper (124,450 tonnes), aluminum (306,930 tonnes) and ferrous (5,550 tonnes) scrap was issued primarily focusing on firms in Guangdong, Xiamen, Shanghai, Ningbo as well as smaller volumes in Tianjin and Dalian. On August 14, a third import quota batch approved 99,370 tonnes of copper (87,680 tonnes), aluminum (11,290 tonnes) and ferrous (400 tonnes) scrap for delivery to the Port of Tianjin, Ningbo, Shanghai, Xiamen, Qingdao, Nanhai, Nansha, and Wuzhou. 

The application process for obtaining scrap metal import licenses could have a potentially adverse effect of consolidating the domestic market. Given that smaller firms are unlikely to have the resources to meet the strict environmental standards for scrap processing, more stringent standards have meant that the number of licenses that can be rewarded will be limited to firms that can afford more costly environmental equipment needed to meet them. For instance, companies have been required to adopt strict contamination standards that were introduced in March 2018 despite largely being considered to be technically infeasible. Under the standard, companies are required to maintain impurity thresholds for scrap imports to under 1 percent (non-ferrous), 0.5 percent (electric motors, wires and cables, metals and appliances, vessels, plastic, wood, smelt slag, and ferrous) and 0.3% (autos). 

Port congestions resulting from cargo build-up

Ahead of the July 1 deadline, heavy congestion was reported at key scrap ports with importers rushing to import scrap metal shipments. The Port of Ningbo has experienced very strict customs inspections with claim deliveries of cargo in June 2019 taking up to 13-15 days as opposed to the usual 10 days. The Port of Sanshan, located in a key manufacturing region for aluminum products in Guangdong, stopped accepting cargo earlier than planned due to excessive stockpile build-ups. Chinese consumers warned suppliers of looming congestion at Sanshan as early as May with scrap exporters informed to avoid having cargo arrive between June 20 and July 20.  A demurrage and detention fee of around USD 100 (EUR 87.85) will be charged for containers held at the port in the event of customs clearance delays. 

The regulations have also affected the flow of lower-grade copper scrap to ports in Guangdong, which used to process half of all China’s imported copper scrap. This is because overall licensed tonnage for imports has been cut by 94% since December 2017 and no further licenses or quotas have been given to companies in the province at this point. As a result, Chinese processors have either begun to move to or have created facilities in developing countries to take advantage of less strenuous environmental regulations. 

Impact of China’s Scrap Import Restrictions

The combination of Category 6 and 7 restrictions threaten to create significant supply chain disruptions both for refiners who use scrap as raw material input and manufacturers who blend the scrap into their products. Since Beijing adopted its environmental campaign against solid waste in 2017, China has reportedly cut scrap imports by over 40% percent in 2018. Import volumes for scrap copper fell from 3.6 million tons in 2017 to 2.4 million tons this past year with Malaysia now emerging as the largest supplier of scrap to the Chinese market. The Philippines, which was the sixth-largest exporter of copper scrap to China in 2017, dropped to 18th place in 2018 as shipments from low-grade scrap suppliers came to a de-facto halt.  

The drastic reduction in scrap supplies has triggered domestic refiners and manufacturers to scramble for raw material substitutes needed to blend the scrap into their products. The latest Category 6 restrictions has already prompted Chinese copper importers to try and secure raw material alternatives from overseas such as blister and off-grade copper cathodes. Blister is a partially purified form of copper that is widely used in South American and African markets. Off-grade cathodes are a basic form of copper used to make products such as copper rods and tubes and have also emerged as another alternative to compensate for the lack of scrap. 

Another challenge facing market participants is how scrap metals are being classified in China. China is the only country to use its own set of standards under a ‘pass/fail’ assessment for imports despite the fact that there are more than 150 different specifications for non-ferrous scrap that include their own code words, descriptions, and maximum allowed impurities. For instance, China only classifies copper scrap as ‘solid waste’ under Category 6 and 7, meaning that it is likely headed for a near complete ban similar to that of scrap plastic. The scrap industry is currently pushing for a re-categorization of high-quality copper scrap from ‘solid waste’ to ‘resource’ to allow for continued supply as a way of removing it from the hit-list.  

Although the desire to reduce scrap imports into China is understandable from an environmental perspective, Beijing is arguably several years away from being able to realistically reach its target of zero scrap imports in a sustainable manner. Such a drastic reduction is likely to create greater uncertainties in the immediate term, particularly for refiners and manufacturers reliant on raw material inputs from scrap metals in China’s domestic market. 

New Supply Routes for Metal Scrap in Emerging Markets

China’s clampdown on scrap metals imports since the implementation of Category 7 restrictions in 2018 has prompted a widespread shift of Chinese-owned copper smelters and refining companies to Southeast Asian countries like Malaysia, Cambodia, Thailand, Vietnam, and Indonesia. The new route was established mostly for scrap metals to be dismantled in these countries and to be processed into higher-quality metals that meet Category 6 standards in order to be imported into China.

Jiangxi Copper was the first processing facility to be built in Malaysia with a capability to process up to 150,000 tons of copper scrap per year; it can also separate copper wire involving plastic waste. According to the global survey conducted by the International Copper Study Group, Malaysia’s total import of  metal  scrap had increased from 19,000 tons (2017) to 230,000 tons (2018) as scrap processing plants have increased. Kinnrich Copper Smelting Co Ltd. in Cambodia, Pt Dinxin Copper Smelter in Indonesia, and Lanxi Zili Copper Co. in Thailand have thrived in business despite the scrap ban in China. These plants remove plastics and other coverings from electricity cables, wires, and pipes in order to sell them as higher-purity material to refineries; the refineries then produce copper cathodes which are eventually traded as commodity grade metal.

However, this new supply route to process scrap in emerging markets is starting to be threatened by rising global scrap imports that are piling up at their own ports. Most Southeast Asian nations have recently started to limit the import of mixed metal imports from overseas due to domestic environmental concerns and port congestion. Vietnam now only allows the import of high-grade mixed metal with minimum 99% metal content. Malaysian scrap suppliers also confirmed that a large number of copper scrap containers that were originally allowed are now being rejected by the customs officials since May 17, 2019. In one particular case, Malaysian customs detained several thousand tons of copper scrap imported from the United States, Europe, and Japan that were to be insulated into copper wires by Jiangxi Copper. 

While most processing plants have shifted abroad, other Chinese scrap recyclers are formulating strategies to process locally sourced waste with the optimistic view of strengthening China’s recycling industry in the coming years. Despite the restriction for low-grade materials and lengthy inspections, China still imported 2.5 million megatons (mt) of copper scrap in 2018 according to data from the General Administration of Customs. With this backdrop, local copper recyclers such as China Metal Resources Utilization aims to raise its scrap recovery volume from 56,000 mt to 160,000 mt in 2019 by expanding copper scrap processing capacity at its Sichuan plant. Other metal recyclers such as Chiho Environmental Group plans to form joint ventures with counterparts in India and Malaysia this year.

Outlook

Uncertainties surrounding the implementation of Category 6 restriction may cause scrap importers to temporarily halt long-term orders. Short term disruptions can be anticipated on the scrap trade flow into China in July with residual disruption to linger until at least August, as some importers had set a cutoff date for any cargo to arrive at the port by early June in order to have sufficient time to clear the customs. 

The new restriction also means that the availability of metal scrap in the global market will increase. There have been more materials in the U.S. market due to difficulties in shipping scrap into China which brought an increased investment on the US recycling plants with most investors coming from China. Reports in May 2019 suggested that some recycling plants that previously exported metal to China have renewed capability to process metal scrap following the Category 7 restriction. Chinese companies are already investing in plastic and scrap metal recycling plants in Georgia, Indiana, and North Carolina to make raw materials for manufacturers in China.

Around 400 million tons of metal are recycled worldwide and around 40 percent of worldwide steel production is made from recycled steel annually. As of June 2019, the global metal scrap industry was reportedly worth over USD 500 billion (EUR 439 billion), indicating that there is potential for metal recycling markets to grow.

Industry experts have also forecasted that electronic-waste (e.g., any product that is still working and has a plug and a battery) will increase considerably in the near future as recycling materials inside a discarded electronic device is more eco-friendly than mining for new metals. This is because electronic waste is mostly comprised of a variety of metal components such as iron, copper, aluminum, silver, gold, palladium, iridium, and rare earth metals and the value of a metal rarely decreases irrespective of the number of times it is recycled. Thus, in order to supply the growing global demand for metals, the rate of e-waste recycling will likely grow over the coming years. 

Recommendations

As China looks to intensify its clamp down on scrap imports, Everstream Analytics customers with an interest in the scrap metal recycling industry are advised to keep abreast of regulatory advisories from China in order to have time to strategize and adjust supply chain processes accordingly. The following recommendations are provided to mitigate operational and shipment delays:

  • Ensure China-based scrap importers have approved licenses: Prior to shipping any scrap metals to China, customers are advised to confirm with China-based importers to ensure that they are holding valid import licenses from the MEE. Companies should also monitor whether smaller-to-mid sized scrap importers may have been forced to consolidate or are experiencing potential financial pressures that could lead to insolvency due to the strict regulatory restrictions and environmental standards for scrap metals smelting and processing. 
  • Monitor pending import quotas and regulatory developments: Companies should monitor additional batches of quotas and licenses that are set to be approved in the coming weeks for importers of Category 6 scrap metals particularly in southern Chinese provinces with major scrap recycling hubs such as Guangdong. Depending on the total import quotas granted, this will have a considerable impact on the extent to which importers will be able to intake and thus the scrap inputs that will be available. In addition, the National People’s Congress (NPC) is also currently reviewing revisions to the Law on the Prevention and Control of Environmental Protection by Solid Waste, which was last deliberated in June 2019 and could bring about further regulatory developments. 
  • Expect longer berthing and customs processing times: Heavy congestion and prolonged customs processing times should be anticipated at the 18 designated sea ports that are permitted to accept approved imports of solid waste including scrap metals. These include the Ports of Dalian, Fuzhou, Guangzhou, Huangpu, Nanhai, Nansha, Ningbo, Zhoushan, Qingdao, Shenzhen, Taicang, Tangshan, Tianjin, Waigaoqiao, Wuzhou, Xiamen, Xinhui, and Yangshan. Moreover, the lack of valid import permits for scrap imports may potentially further exacerbate inspection times, causing delays in cargo clearance.
  • Verify if China-based scrap importers have applied for tariff exemptions: Customers should verify with China-based scrap importers on whether they have applied for tariff exemptions from 25% tariffs on copper scrap and other recycled metals from the U.S. that came into effect in April 2018. China’s Ministry of Finance (MOF) recently accepted applications on a case-by-case basis from June 3 to July 5 with Chinese importers eligible to receive exclusions of up to 100 percent of the tariffs. Specific products eligible for the waiver include non-ferrous scrap items and aluminum waste and scrap, but an earlier 25% tariff on recycled aluminum will remain in effect. 

Appendix

Below is a summary of how the policies developed, as monitored and reported by Everstream Analytics. 

January 1, 2018
China’s import ban on 24-types of solid waste comes into effect. 
 
March 1, 2018
China implements contamination standards for a wide array of scrap metals products. 
 
April 19, 2018
China announces it will ban 32-types of solid waste imports. The import bans come in two phases with 16-types (focusing on motors, wire, and cable scrap) banned on December 31, 2018 and another 16-types (focusing on stainless steel, auto, and vessels scrap) banned on December 31, 2019. 
 
August 23, 2018
China imposes a 25% retaliatory tariff on U.S. imports of scrap copper
 
December 31, 2018
First phase of the ban on 16-types on solid waste imports comes into effect as part of the 32-types of solid waste imports banned. 
 
June 1, 2019
China adopts new regulation to restrict automotive scrapping and eliminate illegal recycling and dismantling activities.  

June 3, 2019
China announces that Chinese importers are eligible to apply for exclusions to the 25% import tariffs levied on copper scrap and other recycled metals from the U.S. Applications are being reviewed from June 3 to July 5 with Chinese importers eligible for exclusions of up to 100% of the tariffs. 
 
June 20, 2019
China issues its first batch of quotas for the country’s scrap metal importers.  

July 1, 2019

China’s import ban on eight categories of high-grade Category 6 copper scrap including aluminum and iron and steel scrap comes into effect.

July 10, 2019
China issues its second batch of quotas for the country’s scrap metal importers.

August 14, 2019
China issues its third batch of quotas for the country’s scrap metal importers.

December 15, 2019
Chinese tariffs on U.S. imports of aluminum and copper scrap come into effect. 
 
December 31, 2019
Second phase of ban on 16-types on solid waste imports to come into effect as part of the 32-types of solid waste imports banned. 

End-2020
China aims to reduce solid waste imports to zero by the end of 2020.  
Table 1: Timeline of China’s Scrap and Recycling Policies
No.HS CodeType of wasteCertificate nameEnvironmental protection control standard for imported solid wastes as raw materials
17204 10 0000Waste and scrap of cast ironWaste and scrap of Iron & SteelGB 16487.6    
27204 29 0000Waste & scrap of alloy steel – OtherWaste and scrap of Iron & SteelGB 16487.6
37204 30 0000Waste and scrap of tinned iron or steelWaste and scrap of Iron & SteelGB 16487.6
47204 41 0000Waste and scrap of iron and steel frommachining (Turnings, shavings, chips, millingswaste, sawdust, filings, trimmings andstampings)Waste and scrap of Iron & SteelGB 16487.6
57204 49 0090Waste and scrap of iron or steel – otherWaste and scrap of Iron & SteelGB 16487.6
67204 50 0000Remelting scrap ingots of Iron or SteelWaste and scrap of Iron & SteelGB 16487.6
77404 00 0090Copper waste and scrap – otherCopper waste and scrapGB 16487.7
87602 00 0090Aluminum waste and scrap – otherAluminum waste and scrapGB 16487.7
Table 2: Solid Waste Items Restricted Under Category 6. Source: Ministry of Ecology and Environment
No.HS CodeName of wasteDescription
12618001001Manganese-containing granular slag generated during smelting of steel and iron, with a manganese content greater than 25% (including slag sand) Granular slag generated during smelting of steel and iron, with a manganese content greater than 25% 
22619000010Oxide scale generated during steel rolling Oxide scale generated during steel rolling  
32619000030 Steel and iron residue generated during smelting of steel and iron, with an iron content greater than 80% Steel and iron residue generated during smelting of steel and iron, with an iron content greater than 80% 
43915100000 Waste and scrap ethylene polymers and remnantsWaste and scrap ethylene polymers and remnants, excluding aluminum-plastic composite membrane  
53915100000 Waste and scrap ethylene polymers and remnantsAluminum-plastic composite membrane
63915200000  Waste and scrap vinyl benzene polymers and remnants Waste and scrap vinyl benzene polymers and remnants 
73915300000  Waste and scrap cholroethylene polymers and remnants Waste and scrap cholroethylene polymers and remnants 
83915901000  Waste and scrap polyethylene terephthalate and remnants Waste and scrap PET and remnants, excluding waste and scrap PET bottles (compressed)  
93915901000 Waste and scrap polyethylene terephthalate and remnants Waste and scrap PET bottles (compressed)
103915909000 Other waste and scrap plastics and remnants Other waste and scrap plastics and remnants, excluding cracked compact disc scrap 
113915909000 Other waste and scrap plastics and remnants Cracked compact disc scrap  
127204490010 Compressed piece of scrap automobile Compressed piece of scrap automobile  
137204490020 Metal and electrical appliance scraps mainly for the recovery of iron and steel Metal and electrical appliance scraps mainly for the recovery of iron and steel  
147404000010 Metal and electrical appliance scraps mainly for the recovery of copper (including waste electric motors, waste wires and cables, and metal and electrical appliance scraps) Metal and electrical appliance scraps mainly for the recovery of copper  
157602000010 Metal and electrical appliance scraps mainly for the recovery of aluminum (including waste wires and cables, and metal and electrical appliance scraps) Metal and electrical appliance scraps mainly for the recovery of aluminum  
168908000000 Vessels and other floating structures for breaking up Scrap vessels Scrap vessels 
Table 3: List of Solid Waste Included in the Catalogue of Banned Import Solid waste Effective December 31, 2018. Source: Ministry of Ecology and Environment
No.HS CodeName of wasteDescription
14401310000 Wood pellet Wood wastes 
24401390000 Other sawdust, wood waste and scrap Wood wastes  
34501901000 Cork waste Cork waste 
47204210000 Waste and scrap of stainless steel Waste and scrap of stainless steel 
58101970000 Tungsten wastes and scraps Tungsten wastes and scraps 
68104200000 Magnesium wastes and scraps Magnesium wastes and scraps 
78106001092 Other unwrought bismuth wastes and scraps Bismuth wastes and scraps  
88108300000 Titanium wastes and scraps Titanium wastes and scraps 
98109300000 Zirconium wastes and scraps Zirconium wastes and scraps 
108112921010 Unwrought germanium wastes and scraps Germanium wastes and scraps  
118112922010 Unwrought vanadium wastes and scraps Vanadium wastes and scraps  
128112924010 Niobium wastes and scraps Niobium wastes and scraps 
138112929011 Unwrought hafnium wastes and scraps Hafnium wastes and scraps 
148112929091 Unwrought gallium and rhenium wastes and scraps Gallium and rhenium wastes and scraps 
158113001010 Granular or powdery tungsten carbide wastes and scraps Granular or powdery tungsten carbide wastes and scraps 
168113009010 Other tungsten carbide wastes and scraps, except for granular or powdery ones  Other tungsten carbide wastes and scraps, except for granular or powdery ones  
Table 4: List of Solid Waste Included in the Catalogue of Banned Import Solid Waste Effective December 31 , 2019. Source: Ministry of Ecology and Environment

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