In March, at the direction of the Basel Convention Conference of Parties, an Expert Working Group began to review the legally binding annex of the Convention that pertains to what is considered hazardous materials as well the annex that determines what are disposal and recycling operations.
The European Commission has proposed to redefine certain recycling processes as “treatment” rather than recycling. Then in June, the government of Norway submitted a proposal to the Basel Convention secretariat that plastic waste and scrap be moved from Annex IX [wastes not covered in the Convention] to Annex II [Categories of Wastes Requiring Special Consideration or “other wastes”], thereby placing plastic waste and scrap within the scope of the Basel Convention. Norway’s intent is to use the Basel Convention to address the marine litter crisis.
If both of these proposals are adopted, it can reshape our industry and how we trade scrap commodities. The European definition would consider processes such as dismantling, sorting, crushing, compacting, pelletizing, shredding, blending, and mixing as “mechanical treatment,” and thus not recycling. Norway’s plastics proposal would mean administrative burdens for plastic scrap traders worldwide. More troubling for U.S. companies that import or export plastic scrap is that it would place a severe restriction on trade
given that the United States is not a party to the Basel Convention, and thus, there are only limited exceptions to prohibitions on trade between parties and non-parties.
ISRI believes that the implications of adopting Europe’s definition would completely discredit the vital role recycling plays in the international economy. Adopting Norway’s plastics proposal would do more to discourage plastics recycling than it would help curb plastic waste in the oceans, and we believe recycling is part of the solution, not the problem.
ISRI has provided comments directly to the U.S. Government representatives that serve as observers to the Basel Convention, who are advocating on our behalf. ISRI also contributed to, and signed, a cross-industry letter to the Basel Convention secretariat outlining our concerns about this proposal. Furthermore, ISRI Senior Director for Government Relations & International Affairs Adina Renee Adler attended a Basel Convention conference in Geneva during the week of September 3 in which the parties reviewed the proposal (the final decision on how to take it forward had not yet been decided at press time).
ISRI is working aggressively through multiple channels to prevent these proposals from moving forward. Europe’s definition of recycling operations is still under consideration and will only be reported to meeting participants in September. Norway’s plastics proposal will be officially tabled at the meeting, and Basel Convention Members, with input from observers such as ISRI, will determine whether or not to pursue a more formal consideration of the proposal.