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Analysis: It is All About the Environment for China

Given that it is the world’s largest importer of scrap, China’s announcement that it would ban some recyclable material coming into the country caught many by surprise.

Given that it is the world’s largest importer of scrap, China’s announcement that it would ban some recyclable material coming into the country caught many by surprise. It has left the impression that the recycling industry has been targeted, and to some in the general public, that what is being sent to China is low quality materials or waste. However, as is the case with almost any international issue, there is much more to the story.

China is facing a serious environmental crisis, and the Chinese Government has made cleaning up the country’s environment – and creating a “Beautiful China” – its number one priority. Their focus is not on any one industry, but across all sectors of the country’s economy regardless of the impact on jobs and production. A wide-ranging series of actions – including closures, aggressive enforcement, and the tightening of environmental controls – are being implemented in industries as far ranging as agriculture coal, oil and recycling.

China’s recent policy announcements affecting recycling are aimed at both its domestic recycling infrastructure and at imports of “solid waste.” It is the result, in large part, of years of China’s lack of attention to environmental compliance at domestic recycling operations and lax customs enforcement which allowed shipments of scrap mixed with garbage to be imported into the country by those who didn’t follow the rules.

During my most recent visit to China during the first week of December, I met with representatives from the Chinese Government and with Chinese industry associates and it became clear that the Chinese are struggling to distinguish between what is truly waste material that they do not want in their country at any cost and what is a valuable resource/recyclable commodity which they understand is needed as feedstock for manufacturing. And in their rush to meet President Xi Jinping’s directive to develop rules to prevent “foreign waste” from entering their country, they have created terms and standards inconsistent with the global trade.

One of the reasons I was in Beijing earlier this month was to participate in a Roundtable organized by the U.S. Embassy with representatives from six other foreign missions – the EU, UK, Canada, Australia, New Zealand, and Japan. ISRI was invited to voice concerns and answer questions about the impact of what China is doing on the global recycling industry. It was exciting to learn that the Embassies had formed a working group on the issue and were coordinating strategy and speaking to the Chinese government on behalf of our industry. ISRI is also, of course, coordinating with the BIR and our counterpart associations globally. And while in China we also met with the Recovered Paper Branch of the Chinese Resource Recycling Association (CRRA) who agreed to work with us and help in our communications with the Ministry of Environmental Protection.

The good news we learned through all of our meetings is that the Chinese Government is listening, which is the reason for the albeit modest improvement in the carried waste threshold proposed last month. We will of course continue to advocate directly with the Chinese Government and through the World Trade Organization, the US Government and our counterparts in China to obtain clarifications and make further adjustments to the carried waste standard, ideally though recognition of ISRI’s Scrap Specifications Circular.

The bad news is that Chinese regulators have limited time and ability to take in all of our comments as they are under tremendous pressure from the upper echelons of the Chinese Government to finalize their rules by the end of the year. In addition, AQSIQ is not prepared for the implementation of the ban for mixed paper and residential plastics scheduled to start on January 1 as during our meetings they could not answer questions as to the meaning of the terms. Thus, the likelihood of individual inspectors at the ports understanding what they are inspecting – and what they are looking for – is very low.

For all these reasons, ISRI is recommending that in preparing shipments for export to China to do the following:

  • Keep trash/waste out. Do not load dirt, wood, concrete, rocks or anything else that doesn’t belong in the container, as these will likely result in a rejection. This includes not scooping material from the bottom up – use other means wherever possible to load containers. Also, make sure that cardboard or aluminum cans, even though they are recyclable, aren’t in loads that aren’t cardboard or aluminum cans. Don’t give the inspectors an easy way to reject your load. Be extra vigilant when loading!  We can’t stress this enough.
  • Include more photos. Take more photos than what is required, and make sure they capture clean floors, properly sorted material, clean handling and loading, and quality/cleanliness of the material. Document the condition and contents of all shipments before export.
  • Be prepared for rejections. We anticipate a greater number of rejections of material before and after shipping, and it will not necessarily be related to scrap quality but unfortunately on misunderstandings by inspection officials as to what they are looking for.

To the extent possible, please keep records of your experience, including the reasons given for any rejections and share with ISRI. The more data we gather, the more we are armed to sort through these problems directly with the Chinese Government (you and your companies’ names will not be shared).

And remember, we are here to help. ISRI has resources to support the changes that you may need to incorporate in order to continue trading with China. Please let us know if we can help in any way. Contact myself or Adina Renee Adler, ISRI’s Sr Director of International Trade.

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