Plastic Waste Exports and the Norway Proposal

BPF Position

 

The BPF has for a long time been in favour of revisions to the current PRN/PERN system for providing evidence of ‘recycling’ under the Packaging Producer Responsibility regulations. The BPF is supportive of policies and legislation that help to accelerate the transition of the plastics recycling industry to a UK-based, resource efficient circular economy. Two key factors in enabling this transition are:

• A focus on the quality of sorted plastic raw-materials coming out of the UK’s households and commercial collection and sorting systems.
• A re-balancing of the relative costs and benefits associated with producing evidence of recycling for obligated companies under Producer Responsibility.

The high-level of dependence upon the export of plastic packaging (and other types of mixed, part-processed streams, such as WEEE and ELV derived plastic), has left the UK exposed to criticism that the nation is contributing to overseas sources of marine plastic pollution.

The business case for investment in UK-based recycling infrastructure has been undermined by the ease of access to export PERNs at much lower cost than incurred to create domestic PRNs by operating well-regulated recycling reprocessor plants under UK waste laws.

The BPF is therefore supportive of the Norwegian Proposal to enforce much tighter controls on the shipment of mixed, low-grade plastic exports, irrespective of their destination, because this creates a strong driver for an improvement in the quality of sorted plastics being produced in the primary sorting MRFs across the UK.

The description given for entry onto the B3010 ‘green list’ for single polymer raw-materials should create a driver towards an equivalent standard for export bale quality to that required for effective recycling in modern, UK-based re-processing plants. It will demand the introduction of sorted bale quality standards to place controls on the outputs from UK primary sorting MRFs.

UK exports of packaging waste have been on the rise dramatically in latest years. A report by the National Audit Office suggests that since 2002 the total amount of packaging waste exported abroad has increased six-fold while the total amount recycled in the UK has remained steady[iv].

It is estimated that around 65% of UK-collected plastic packaging material is exported as a ‘waste resource’ for downstream sorting and recovery in overseas markets[v]. In 2018, 650,000 tonnes of all types of plastic packaging (i.e. household plus commercial & industrial) was exported from the UK (see graph below). In the same year, less than 400,000 tonnes was recycled in UK based re-processor plants[vi].

Figure 1 – Plastic packaging recycling, source: 360 Environmental & National Packaging Waste Database (NPWD)

The control of this large-scale flow of plastics as a raw-material for onward re-processing is entirely dependent upon the declarations made by the exporting party when completing the necessary waste shipment paperwork.  In many cases, the simplest route to export is to use a ‘green list’ waste code that fits with the description of the type of plastic-rich waste in question and to state that the material is destined to be ‘recycled’ in a country and organisation where ‘broadly equivalent standards’ apply, when compared with UK- and EU-regulated operations.

Recently, there has been a massive and growing concern across the public, in the media and in world governments about marine plastic pollution, highlighted by the David Attenborough ‘Blue Planet 2’ documentary series. This public, political and media outcry has driven the ‘anti-plastics’ debate and caused many developed nations to review their own policies with regard to the shipment of plastics outside of the regulatory framework of Europe and into developing countries. It is becoming increasingly unacceptable for the Western developed nations to use countries with poor standards of waste management and regulatory control as the ‘preferred location’ to send their mixed plastics waste for ‘recycling’.

Following the closure of China’s ports to the import of all but the highest standards of waste material resources (e.g. less than 1.5% non-target material) at the end of 2017, there has been a rapid shift in the list of countries where the UK and Europe’s waste plastics resources are now being shipped to.  Latest data (see figure 2) indicates that Turkey, Malaysia, Poland, Indonesia, Vietnam have become the most common end-destinations for UK-exported plastic waste (with other European countries being used as shipping transfer points – e.g. the Netherlands, Germany).

Figure 2 – Top 13 plastic export destinations 2018, 360 Environmental & HMRC

Evidence from overseas visits to these countries by organisations with a high level of concern about the handling and processing of imported waste plastics has shown that, in many cases, the non-target fractions of plastic and non-plastic waste contained in exported ‘raw materials’ do not get properly disposed of at the end destination. Recent Sky TV investigations indicated the very poor quality of these export bales, both in Malaysia and Eastern Europe[vii].  In many instances the unwanted reject-fractions from export shipments are simply burnt in open fires overnight or become the subject of numerous large-scale ‘accidental’ fires[viii]. Alternatively, those tonnages of the segregated, unwanted waste contaminants left after extraction of the value components are often simply dumped in uncontrolled landfill sites or escape into local waterways and rivers[ix].

Recent media reports related to those export destinations which are ‘closer to home’, such as Poland (in the European Union) and Turkey raise high levels of concern about the standards of waste management being practiced on imported plastics waste from the UK[x]. These news stories undermine and damage the reputation of those responsible export companies who are sending quality specified raw-material resources to overseas recycling operators who re-process plastic waste in well-managed factories and dispose of the residual waste fractions responsibly.

While these ‘worst-case’ examples of environmental damage resulting from poor treatment of exported waste are related to an unknown, but probably significant fraction of the total shipped tonnage, they do serve to indicate how difficult it is to establish and verify the application of ‘broadly equivalent standards’ in far-distant recycling operations. The problem is often made worse by the complex, multiple trading transactions that take place between the original export shipment point and the eventual location where bales are broken down and ‘reprocessed’.

There is currently no way to measure the proportion of waste plastic export shipments that are related to ‘rogue traders’ or the ones where Packaging Export Recovery Notes (PERNs) have been issued to evidence ‘recycling of the resources’, when in fact the material has essentially been discarded in a foreign land[xi]. 

 

Norway Proposal to the Basel Convention

 

In 2018 Norway has addressed the above concerns about the export of low-grade mixed plastics by making a proposal to amend the United Nations Basel Convention on the Control of Transboundary Movements of Hazardous Waste, by re-classifying mixed plastics and bringing them under the regime of Pre-Informed Consent (PIC)[xii].  There are three types of plastic waste categories proposed by Norway:

1. Annex II

Proposal for a new entry: Y 48 Plastic waste not covered by entry AXXX of Annex VIII or B3010 of Annex IX.

2. Annex VIII

Proposal for a new entry: AXXX Plastic waste containing or contaminated with Annex I [i.e. Hazardous] constituents to an extent that they exhibit an Annex III ‘hazardous’ characteristic

3. Annex IX: B3010 Plastic waste

The plastic materials listed below, provided they are not to an extent which prevents the recovery of the waste in an environmentally sound manner, mixed with each other, mixed with other wastes or contaminated. Consignments of such plastic material should be prepared to a specification and suitable for immediate recycling requiring only minimal further mechanical preparatory treatment processes, if any (NB: long list of polymer types follows).
 

Essentially this proposed change will mean that all mixed (non-hazardous) plastics will fall under the new Y48 listing and be subject to similar administrative controls to those currently used to regulate hazardous waste shipments under Basel convention rules. The rules of Pre-Informed Consent place an arduous level of administrative and financial burden on the exporting party and would effectively stop a large tonnage of mixed plastics from being exported under current ‘green list’ controls.

The description of the single polymer type, high-quality plastic raw materials under the B3010 listing will mean that only those plastics which have low levels of non-target contamination and other waste, will be able to be shipped to re-processing locations where recycling will then take place, ‘immediately’. 

The Norwegian Proposal is expected to be voted upon at the 14^th Conference of the Parties to the Basel Convention (CoP 14) in Geneva in April-May 2019. Given that a big number of developing countries have already taken action against imports of low-grade plastic waste, there is a good chance that the 187-member countries of the UN Basel Convention will vote in favour of adopting the proposal, although probably with some amendments and variations in scope and coverage. 

 

European Union Position on Norway Proposal

 

The European Council has recently published a draft Council decision detailing the negotiating position to be taken by the EU at CoP 14. The position broadly supports the ethos of the Norway proposal, but with a strong indication that ‘intra-EU’ shipments of mixed waste plastics should be exempted from the pre-informed consent procedure, because existing EU regulations on waste shipment are already adequate for the required level of control on these waste movements between member states[xiii]. The Council decision states that:

‘The envisaged act will contribute to:

– improving controls on plastic waste exports,

– supporting the environmentally sound management of plastic waste,

– reducing risks that plastic waste finds its way into the environment, and

– preventing the global environmental problem of marine litter.’

 

Timescale

 

It is not realistic to expect the plastics recycling industry to make a rapid and sudden shift away from export routes as the basis for delivering over half of the recorded recycling tonnage for UK obligated producers. The BPF is therefore keen to be involved in a debate about the length of time it will take to make the scale and scope of transition required to create a much higher proportion of domestic recycling infrastructure than the current status in early 2019. As a starting point for this debate we would offer the following proposal:

• Over a period of three to five years, implement the necessary regulatory changes to ensure a significant reduction of plastic packaging exports of the total UK used-packaging collection tonnages (i.e. from both household and commercial and industrial collections). There is also a need to anticipate international transfers of waste for chemical recycling.

• Define and implement a set of quality standards to be applied at the output point from primary sorting facilities for both household and commercial plastic waste resources. This set of quality standards should be based upon the bale quality produced by modern, well-managed MRF operations supplying into existing UK and EU-based re-processing plants (see example of possible grading in appendix 1).

• Ensure that the tonnage of plastic raw materials being sent for export recycling is subject to auditable and regular sampling analysis to provide a reliable and trusted evidence base that ‘broadly equivalent’ standards are applied at the end-destination re-processing operation.  This should include independent visits to the overseas re-processing factories with a particular focus upon the disposal routes used for the non-recyclable, residual contaminant fractions removed during the local sorting process.

 

Appendix 1 – Example format for baled plastics quality specifications to be applied to export to overseas countries

A grading system could be created based upon 3 levels to define ‘single polymer type’ under B3010 listing for sorted plastic bales:

• Grade A - 98% of the bale is the target ‘single polymer and pack format’; remaining 2% can be non-target other plastic but similar format; 1% maximum non-plastics contamination.
• Grade B - 95% of bale is target ‘single polymer/pack format’; remaining up to 5% can be non-target other plastic types; up to 2.5% non-plastic contamination.
• Grade C - 90% of bale is target ‘polymer/pack format’; up to 10% non-target polymer types, but same pack-format; up to 5% non-plastic contamination.

Any baled packaging material where the target polymer/pack format is below 90% - a sub-standard, low-grade BALE, which will yield 10 to 25% as ‘residual waste’ during sorting/washing/re-processing (i.e. labels; moisture; product residues; caps; contaminating non-plastics; films etc).  This lower grade of material should only be sent to countries where there is absolute confidence (to be evidenced with documentation) that the receiving nation does have an adequate waste control system in place to avoid any escape of the residual materials into the environment.

Organisations that are involved in the export of significant tonnages of waste plastic resources must provide independently audited and traceable evidence routes that allows the tracking of their export materials into the receiving countries and right through to the end-destination where recycling and re-processing takes place (under Duty of Care). This would enable proof that the residual fractions left post-recycling are being handled with equivalent standards to UK/European nations.

Use the above grade A, B or C levels to determine the degree of vigour applied by the enforcing authorities in terms of the level of scrutiny applied to the end-destination for frequency of auditing of tonnages.   [i.e. anybody shipping Grade C - would have to apply a higher level of: 1) Sampling evidence at the point of loading. 2) Frequent audit visits to the receiving country. 3) Documented mass balance and end-disposal methodology used for the residual fractions. 4) These checks to be reported and signed-off by a respected and trusted organisation].

 

 

References