Block 21: Specific Conditions or Objection Reasons
Block 21: Specific Conditions or Objection Reasons
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Block 21 — Quick Reference
Specific Conditions or Objection Reasons
Records any conditions attached to CA consent, or the stated grounds for a CA objection to the movement.
Basel Article
Article 6(2) & 6(4)
Rejection Risk
Low — Transcription field
Completed
After CA response only
What Block 21 Captures
Block 21 is a transcription field. It records verbatim or in summary the specific conditions that a CA has attached to its consent, or the grounds it has stated for objection. This block is only completed after CA responses are received — it has no content at initial submission. Conditions commonly attached by CAs include: requirements for specific transport documentation, mandatory reporting upon arrival at the facility, restrictions on the number of shipments per period, or requirements to notify the CA before each individual shipment under a general notification.
How to Complete Block 21
1
Leave blank at initial submission.
Block 21 cannot be completed before CA responses are received. Submit the initial notification with Block 21 blank.
2
Transcribe conditions accurately.
When a CA grants conditional consent, copy the conditions exactly as stated in their response letter. Do not paraphrase conditions in ways that soften or reinterpret them — the conditions are legally binding and must be reproduced faithfully.
3
If objection received — record the grounds.
State the CA name, date of objection, and their stated reason. Common objection grounds: incomplete notification (missing documents), waste classification dispute, facility permit concerns, or national policy restrictions on the waste type.
4
Comply with all conditions before shipping.
Every condition in Block 21 is a legal requirement. A shipment that departs without meeting stated conditions — even minor ones — is non-compliant and potentially illegal. Review Block 21 against your pre-shipment checklist before each movement.
Supporting Documents
- Specific Conditions / Objection Instructions (Block 21)- Official Annex V-A/V-B forms and completion instructions.
- OECD Decision – Consent Conditions and Controls- OECD decision text and movement/operation code instructions.
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Common CA Conditions for ULAB Exports
Typical conditions from CAs handling ULAB notifications: (1) Submit pre-shipment notification 7 days before each movement; (2) Provide arrival confirmation within 3 days of delivery; (3) Submit annual summary of all movements under the general notification; (4) Ensure carrier holds current ADR/IMDG certification for hazardous materials.
Common Errors → Correct Approach
❌ Wrong
Summarising CA conditions loosely rather than transcribing them exactly
✅ Correct
Copy conditions verbatim from the CA response letter. If the letter says “submit pre-movement notice 5 working days in advance”, that exact requirement goes into Block 21.
❌ Wrong
Filing Block 21 once and never updating it when new conditions are received from additional CAs
✅ Correct
Update Block 21 via amendment each time a CA responds with conditions. The completed Block 21 is a running record of all conditions across all CAs.
Frequently Asked Questions
Can I negotiate CA conditions after they are issued?
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In some cases, yes. If a condition is technically impractical or based on a misunderstanding of the operation, you can correspond with the CA to request a modification. The CA has discretion to amend conditions. However, you cannot simply ignore a condition because it is inconvenient — operate under the stated conditions until any modification is formally confirmed in writing.
What are the most common objection grounds from CAs?
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The most frequent objection grounds are: (1) incomplete notification — missing annexes or blank mandatory fields; (2) classification dispute — the CA disagrees with the Y-code or H-code; (3) facility concern — the receiving facility’s permit does not cover the declared operation; (4) national policy — the country prohibits import of that waste category. Most objections in categories 1–3 can be resolved by correcting the issue and resubmitting.
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DexMetal Expert Tip
Build a conditions compliance checklist from Block 21 before each shipment. List every condition from every CA and tick each one off before the truck departs. This one habit eliminates the most common post-consent compliance failure.
Section A Complete
You’ve covered all 21 blocks of the Basel notification form. Explore the full Knowledge Hub for supporting documents, country requirements, and PIC procedure guides.
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Block 20: Competent Authority Consent
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Basel Form Guide - All 21 Blocks