On Friday, August 18, ISRI provided its official response to China’s scrap import ban by submitting written comments to the World Trade Organization (WTO).
The filing with the WTO is only one part of ISRI’s aggressive efforts to protect the industry as China looks to impose significant changes on the movement of scrap into China. Those efforts include high level discussions with the U.S. Government (both within the Trump Administration and on Capitol Hill), coordination with our counterparts throughout the world and with the BIR to ensure a comprehensive global effort, and communications with the Chinese government directly. While ISRI has offered support to the Chinese government in its need to improve environmental protection and standards within its domestic recycling infrastructure, we have been very clear that we disagree that a ban on the import of specification-grade scrap materials would help with those efforts. Our comments also seek to gain clarity on scope and timing of the prohibition, and suggest ISRI could offer information and training on operational best practices and information to aid in developing supply chains to ensure the efficient use of scrap materials, especially with environmental sustainability in mind. We also press for the Chinese Government to officially recognize ISRI Specifications.
The proposed ban is part of a larger effort on the part of the Chinese Government to put in place a comprehensive system for managing environmental issues, while also working to upgrade its domestic recycling infrastructure. An official government statement of policy, issued by China several days after the WTO Notice, provides a very good outline of the Chinese Government’s objectives and strategies related to this effort ("Notice of the General Office of the State Council on Issuance of Reform and Implementation Plan to Enhance Solid Waste Import Management System by Prohibiting the Entry of Foreign Waste" (Guo Ban Fa (2017) No. 70)). Those objectives and strategies appear to include:
- A desire to prohibit the import of “solid waste with major environmental hazards and intense public reaction by the end of 2017.” This is where the Chinese have targeted household plastic scrap, unsorted mixed paper and certain other materials.
- A gradual halt to “the importation of solid waste that can be replaced with domestic resources” by the end of 2019. It is not yet known what material might fall into this category, although rumours have been flying that “mixed metals,” commonly referred to as “category 7” materials may be targeted.
- An effort to “raise the thresholds for solid waste importation.” In the last week we have seen the release by the Chinese Government of an updated series of “Environmental Control Standards" (also known as “GB Standards”) for scrap and waste materials. While some of the changes are in line with best practices globally, they also include much tighter thresholds for the importation of paper and some nonferrous metals that are out of sync with global standards. ISRI is working with its counterparts around the world to coordinate a global response to these new standards.
- Strengthening controls and enforcement of illegal entry of waste/smuggling through greater enforcement by Customs. This has already started with increased inspections, greater scrutiny of documents, etc.
- “Refining laws, regulations and related systems.” This part of the strategy appears to include raising penalties for illegal smuggling of waste, a reduction in the number of ports of entry in China for imported scrap, as well as reductions in import licenses issued.
- An increase domestic recycling through a combination of infrastructure development, legislation (including extended producer responsibility schemes), R&D efforts, and public awareness.
Please contact Adina Renee Adler with any questions.