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NRL Matters No. 18

revised July 2007

Import, Export and Sale of Radioactive Materials

Anyone wishing to import or export radioactive materials must obtain a consent pursuant to section 12 of the Radiation Protection Act 1965.  Consent is also required if radioactive materials are sold within New Zealand.  The National Radiation Laboratory (NRL) administers the consent process under delegated authority from the Minister of Health.  This document explains the consent process adopted by the NRL.

Registration of Importers, Exporters and Vendors

Applications for consent can only be made by registered persons or organisations.  The purpose of registration is to reduce unnecessary paperwork.  A simple one-page application form requests basic contact information meaning that this information does not need to be repeatedly provided with all future consent applications.  Registrants must advise changes to their registration details as they occur.  No fees are payable for registration.

General consents for unsealed sources[1] and approved sealed sources[2]

In respect of unsealed sources and approved sealed sources the NRL does not require prior knowledge of every proposed import or sale within New Zealand.  Importers and vendors can therefore apply for a general consent authorising multiple imports and/or sales.  This reduces compliance obligations and helps to clear goods through New Zealand Customs efficiently.

In granting a consent, the NRL will impose conditions which include requirements to maintain accurate records, use correct tariff codes, file quarterly transaction returns and undergo compliance audits. 

General consents also specify maximum monthly limits able to be supplied to each end-user.  Supplies in excess of these limits require individual consents.  The limits are set at levels that are unlikely to be exceeded in normal circumstances.

The fee is $7.50 per consignment for imports and $5.00 per consignment for sales within New Zealand.  A consignment may include more than one source so long as there is a single vendor, single transaction date and single end-user.  Invoices are rendered quarterly in arrears based on transaction returns and information provided by New Zealand Customs.

An import consent issued to an importing agent authorises both the importation and the on-sale to the end-user.  Only one fee is payable.  

Individual consents in all other cases

Individual consents are required for:

• the export of any sources,
• the import or sale of sealed sources other than approved sealed sources, or

• the import or sale of unsealed sources or approved sealed sources in the absence of a general consent or in excess of the levels allowable for general consents.

Individual consents must be obtained before the transaction takes place.  For imports and exports the fee is $100 per consignment for high activity sources[3] and $20 per consignment for all other sources.  For sales within New Zealand the fee is $15 per consignment.  Invoices are rendered monthly in arrears.

Who is the Importer?

Often an importing agent has an interest in the import and clears the goods through New Zealand Customs even though they are consigned to another party.  In these circumstances the agent is regarded as the importer and must obtain the consent and comply with its conditions.

Are any sources exempt?

Regulation 4(3) of the Radiation Protection Regulations 1982 provides for exemptions applicable to imports, exports and sales.  Additional exemption criteria applicable to sales are set out in Regulation 4(1).  Consent is not required for exempt sources.

Licensing

Importing agents must appoint a licensee to manage the safe care of sources if:

• sources will come into the agent’s physical possession, and

• the agent will do anything other than simply store those sources.

This means that an agent who splits a single import consignment for on-sale to several purchasers within New Zealand must appoint a licensee because the agent does more than simply store the sources.

Arrangements with New Zealand Customs

The NRL and New Zealand Customs have agreed on a number of initiatives to assist in administering the consent process as it relates to imports and exports.  These will provide for continued efficient clearance of sources together with reporting on imports and exports for comparison with quarterly returns filed by consent holders.

[1]     Radioactive materials are often simply referred to as sources.  Sources can be sealed or unsealed.  Sealed sources are permanently sealed in a capsule or closely bound and in a solid form.  The capsule or material must be strong enough to maintain leak tightness under the conditions of use and wear for which the source was designed and also under foreseeable mishaps.  Unsealed sources are any sources that do not meet the definition of sealed sources.

[2]     Currently restricted to certain iodine sources used in medical applications.

[3]    The International Atomic Energy Agency classifies sources from 1 (most dangerous) to 5 (least dangerous).  Category 1 and 2 sources are regarded as high activity sources for which additional regulatory requirements are imposed.  For further explanation of the IAEA categories see www-pub.iaea.org/MTCD/publications/PDF/te_1191_prn.pdf

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