The Government of Norway in June proposed to reclassify “plastic waste and scrap” as hazardous, thereby bringing such materials under the Basel Convention’s pre-trade informed consent procedures.
ISRI is concerned about the implications for trade in plastics scrap, and has expressed concerns in engagements with the Governments of Norway and the United States and by signing on to a multi-industry letter in opposition of the proposal.
This week, Senior Director for Government Relations & International Affairs Adina Renee Adler represented ISRI’s membership as an observer to the Basel Convention’s 11th Open Ended Working Group. The group meets on the alternate years when the Conference of Parties (COP) does not meet in order to stay abreast of issues being discussed in the Basel Convention’s various expert and technical working groups. It is not a meeting intended to decide to adopt proposals such as Norway’s, but it can determine the pathway for consideration. ISRI has been involved in Basel Convention work on environmentally sound management, electrical and electronic equipment “waste,” and the review of annexes governing disposal and recycling operations and Basel Convention-exempted materials – work on all of which was also discussed.
Within the last couple of years, Basel Convention parties have added their voice to the growing international drumbeat on marine litter, cresting this summer with Norway’s proposal. If enacted, exporters would have to apply for consent from the destination country before plastic scrap could be exported. ISRI has learned that there are consent applications – for materials currently under the Basel Convention jurisdiction – still pending after nearly two years in some countries that lack the capacity to quickly and technically review them. Furthermore, the United States is not a party to the Basel Convention; thus, U.S. companies would be allowed to export only in limited cases. Consent notifications are not free but a costly administrative requirement borne by the exporting companies.
Since the proposal was made in June, Norway has heard from many stakeholders, including ISRI both directly and through the U.S. Government (which is an official observer to the Basel Convention) and dissenters in Europe and other regions. As a result, a revised proposal was tabled at this week’s meeting to address the concerns we raised. There are two parts to the new proposal: (1) to add language to the Basel Convention that can make a clear distinction between “clean fractions of recyclable plastic materials” and “low-quality” plastics that are believed to be litter; and (2) to create a “Partnership for Plastic Wastes” under the Basel Convention that would serve as a forum for dialogue to develop non-binding guidelines to enhance materials management and eliminate litter.
Adina spoke up at the meeting to support a dialogue on these issues, but she also expressed concerns that a reclassification is not likely to address the underlying marine litter concerns. In concert with the Bureau of International Recycling (BIR), European Recycling Industries Confederation (EuRIC), American Chemistry Council (ACC) and other like-minded groups, ISRI promoted the benefits of recycling as part of the solution, which includes allowing cross-border trade of plastic scrap to continue unimpeded.
Please contact Adina directly if you have any questions.
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