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ISRI Comments on Proposed Revisions to China’s Solid Waste Law

ISRI reported last month that China is proposing to revise its Solid Waste Law to bring it into conformity with the Chinese Government’s vision for improving the environment and the regulatory measures already being put into place to protect the environment, including those that effect scrap imports into China.

In reviewing the proposed changes, ISRI found inconsistent uses of the words for “solid waste,” “trash” and “recyclable materials,” failing to provide the needed clarity to properly understand the proposed Article 29 that is translated as “It is forbidden to import solid waste.”

Late last week, ISRI submitted a set of comments to the Chinese Ministry of Ecology and Environment, which is leading the effort to collect comments. Noting that ISRI:
  • “…applaud[s] the Chinese Government’s identification of the need for manufacturers to design packaging materials and film coverings that are easy to recycle…”
  • “…request[s] that the Government take advantage of this opportunity to clarify, in writing, the distinction between what is trash (i.e., solid waste) and what is scrap (i.e., raw material)” and
  • Promotes scrap “as a substitute for carbon-intensive virgin raw materials…” because the import restrictions have “resulted in a significant increase in the production of” these “materials within China, doing much harm to [China’s] environment.”

Although the process for collection, reviewing, and incorporating comments is not clear, it is ISRI’s expectation that the new law will be implemented at the end of the year. Also, if Article 29 remains in its currently proposed form, it is possible we could see other revisions to China’s scrap import regulations, including imposing rules that become even stricter than they are now.

ISRI will continue to provide as much information and as quickly as we possibly can and to continue to advocate for free and fair trade and our industry’s interests throughout all these changes.

Please contact Adina Renee Adler if you have any questions.
 

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