Importing Used / Refurbished Appliances into Malaysia: CoA, UEEE and the Extra DOE Checkpoint

Importing used or refurbished electrical appliances into Malaysia involves one extra environmental checkpoint compared with importing new goods: on one hand, regulated appliances must still meet the Energy Commission's (Suruhanjaya Tenaga, ST) Certificate of Approval (CoA) and ST-SIRIM safety-label requirements; on the other, "Used Electrical and Electronic Equipment" (UEEE) is regulated by the Department of Environment (DOE), because it may be classed as electronic waste (e-waste), triggering the transboundary-movement rules of the Environmental Quality Act 1974 and the Basel Convention. Both lines must be covered, or the goods can get stuck at customs.

Two checkpoints: safety vs. environment

UEEE: the trap refurbished goods fall into most easily

The DOE's Guidelines for the Transboundary Movement of Used Electrical and Electronic Equipment set out requirements for UEEE imported for direct re-use, repair or refurbishment. The crux is whether the shipment counts as e-waste:

• Transboundary movement of goods classed as electronic waste requires prior written approval from the DOE under sections 34B(1)(b) and (c) of the Environmental Quality Act 1974; as a party to the Basel Convention, Malaysia must follow the Convention's procedures for both import and export.
• Even goods claimed to be directly re-usable or refurbishable may be required to prove their functional condition, source and intended end-use, in order to distinguish "usable second-hand goods" from "electronic scrap".

In other words, a refurbished appliance is not simply a "cheaper new product": in the eyes of the regulations it is also a used item, and it may trigger both ST's safety certification and DOE's environmental approval at the same time.

Why used goods are harder to clear than new ones

When new goods are imported, the model test reports and specifications are supplied by the original manufacturer, so consistency is easy to prove. Used and refurbished goods, however, often get stuck on a few practical problems:

• Test reports are hard to obtain: if the same model was never ST/SIRIM-certified at the time, or the standard has since been updated, used goods often cannot produce a valid test report meeting the current standard.
• Doubtful model consistency: the refurbishment process may replace parts or mix batches, so the physical item no longer matches the original model specification and cannot rely on the existing CoA.
• Pressure to prove provenance: customs and the DOE may require proof that the goods are "functional items, not electronic scrap", including functional test records and a statement of source and intended end-use.
• High return-shipping and disposal costs: once goods are judged to be unapproved e-waste, the cost of returning or lawfully disposing of them may exceed the value of the goods themselves—a risk not to be underestimated.

So taking stock of the documents above before placing an order is far more economical than discovering after arrival that the goods cannot be cleared.

Practical steps for importing used / refurbished appliances

1. Classify first: confirm whether the item is an ST-regulated appliance and whether it falls under the DOE's UEEE/e-waste definition.
2. Check trade permits: importing certain electrical and electronic items requires an Approved Permit (AP) or import permit from MITI or other issuing authorities.
3. Obtain the CoA: regulated models still need a CoA; test reports and model consistency are the common sticking points for used goods.
4. DOE approval (if applicable): for regulated UEEE/e-waste, obtain the DOE's prior written approval before arranging shipment.
5. Clear customs + SIRIM on-arrival batch testing: after clearance, complete SIRIM on-arrival batch testing and obtain and physically affix the ST-SIRIM label before selling.

For the full picture of the CoA regime and the division of labour between ST and SIRIM, see the overview of electrical ST CoA and SIRIM certification; to maintain or change the registration of a given model later, see CoA renewal and model changes.

Frequently asked questions (FAQ)

Q: Does importing a used appliance always require a CoA? If it is an ST-regulated appliance, it is not exempt just because it is "used"—it still needs a valid CoA for that model and the ST-SIRIM label. The biggest difficulty with used goods is often being unable to obtain a test report that meets the current standard.

Q: Does a refurbished item count as new or used? For environmental control, a refurbished item is usually still treated as used equipment (UEEE) and may fall under DOE regulation; it cannot be treated as brand-new to sidestep the procedures for used goods.

Q: When do I need DOE approval first? When goods are classed as electronic waste (e-waste), their transboundary movement requires prior written approval from the DOE under section 34B of the Environmental Quality Act 1974, in line with Basel Convention procedures.

Q: Does an individual bringing one used appliance back to Malaysia for personal use need a CoA? Personal-use imports usually go through ST's Letter of Personal Use route, applied for on form ST(PE)4, which differs from the commercial-import CoA process; the current ST rules still apply.

Q: Do these rules apply to buying and selling used appliances locally? Resale of used goods already within the country does not involve transboundary UEEE control, but selling regulated appliances still requires ensuring the product was originally compliant and holds a CoA and ST-SIRIM label.

Self-check checklist

• [ ] Confirmed whether the item is an ST-regulated appliance
• [ ] Assessed whether it falls under the DOE's UEEE / e-waste definition
• [ ] Prepared MITI import permit / AP where needed
• [ ] Obtained a valid CoA for the regulated model
• [ ] For regulated UEEE, obtained the DOE's prior written approval
• [ ] Completed SIRIM on-arrival batch testing and physically affixed the label after clearance

Conclusion

Importing used and refurbished appliances runs on two parallel tracks: "safety certification + environmental control". Cross-checking the item against ST's list and the DOE's UEEE definition to decide which processes apply is far less trouble than scrambling for documents after the goods arrive.

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This article is compiled from official sources for reference only; actual compliance is subject to the latest official texts and reviews of the competent authorities.