Tightening rules on the export of wastes from the EU and the import of scrap materials into southeast Asian countries is changing the flow of scrap materials, including plastics, paper, and metals, around the world.
This trend raises several questions. What impact is this having on the global waste trade? Why is this happening and how should recyclers respond to this trend?
EU waste shipment regulation reforms
In January 2023 the European Parliament adopted revisions to the EU Waste Shipment Regulations. Next, negotiations will take place with individual EU governments on tighter waste shipment laws.
According to the Parliament, EU exports of waste to non-EU countries reached 32.7 million tonnes in 2020 – representing about 16% of global trade in waste. In addition, around sixty-seven million tonnes of waste are shipped between EU countries every year.
What are the reforms and why are they being introduced?
The new rules (see below) are designed to “protect the environment and human health more effectively” and support the EU’s goals “of a circular and zero-pollution economy”:
- Banning the export of plastic waste to non-OECD countries and phasing out its export to OECD countries within four years.
- Banning shipments of all wastes destined for disposal within the EU, “except if authorised in limited and well-justified cases.”
- Banning EU exports of hazardous waste to non-OECD countries.
- Exporting non-hazardous waste for recovery only to those non-OECD countries that give their consent and demonstrate their ability to treat this waste sustainably.
- Requiring that waste shipped outside the EU must be managed in an environmentally sound manner – and demonstrated.
- Creation of an EU risk-based targeting mechanism to guide EU countries that conduct inspections to prevent and detect illegal shipments of waste.
- Digitalising the exchange of information and documents within the internal market, with a central electronic system to improve data reporting, analysis, and transparency.
Warning of commercial disadvantages and disruption of the global circular economy
The Bureau for International Recycling (BIR), an international trade association for the recycling industries representing around 70 countries, said it “fully supports regulations that aim at the protection of both human health and the environment, but also supports that recyclables can be moved to facilities that are environmentally soundly managed, and that raw materials from recycling should continue to be transported to manufacturing industries in the global circular economy”.
It warned: “There is a fine line between applying the proximity principle for wastes, keeping them in the EU, and commercially disadvantaging trading partners outside the EU, denying them resources.”
BIR President Tom Bird put out a strong message on the potential damage of this regulation on the international recycling industry and free trade of recyclables, calling them “thinly disguised back-door protectionism that puts our industry in danger while severely disrupting the global circular economy”. He added: “It should be blatantly clear to everybody that the trade of vital raw materials such as recycled metals should not be restricted, and BIR as an organization remains fully committed to ensuring exactly that.”
Meanwhile, the European Recycling Industries’ Confederation (EuRIC) said in a statement that the EU Parliament had “regrettably reinforced a one-size-fits-all approach to export restrictions. This means that the same restrictions apply to low-quality mixed plastic waste as for high-value raw materials from recycling for which access to European and international markets is essential to preserve the competitiveness of the European recycling industry. By failing to make this distinction, up to 80% of metals and paper recyclers expect losses in turnover, and up to 50% expect job losses”.
Emmanuel Katrakis, Secretary General of EuRIC said the EU “must establish rules that accelerate rather than impede demand for recycled materials.” He added: “Member States must now act swiftly to address our concerns or risk unprecedented levels of incineration and massive stockpiling of valuable resources in landfill.”
Bans on plastic waste exports proposed by the EU and UK
On the proposal to ban plastic waste exports from the EU, BIR said in a statement: “Plastics are taking a beating with the intention to keep all plastic waste in the EU. ‘EU waste, EU responsibility’ was the mantra. However, supplanting more recent EU classifications of plastics wastes with the slightly older Basel Convention codes will hamper intra-EU movements of plastic wastes to recycling and recovery facilities.”
As reported in UK-based recycling publication, MRW, a review of the UK’s net zero plans, captured in a report called Mission Zero, has recommended the ending of UK plastic exports by 2027.
The Recycling Association, a member association for recyclers based in the UK, has warned against such a ban. Former chief executive of the association, Simon Ellin, said previously in a statement: “Since the introduction of the new Basel rules, and the bans/restrictions on imports by many Asian countries, [UK] exports of plastics have largely been to EU countries and Turkey. Since these rules have come in, only around 2% of exports go to non-OECD countries now.
“This trade to Turkey and EU nations has helped to keep competition in the market and ensured that UK reprocessors work under a free and fair market.”
Plastic waste import bans in southeast Asia
After China banned the import of plastic waste in 2018, countries including Thailand, Malaysia and Indonesia became the alternative destinations of these waste shipments, becoming inundated, and causing them to react with their own plastic bans.
The Thai government’s complete ban on plastic waste imports starts in 2025, as it tries to reduce the environmental impact of plastics, as reported by Bloomberg.
Vietnam has also banned all imports of plastic scrap by 2025, following import bans introduced in 2020 on certain types of scrap and waste, including remelting scrap ingots and titanium.
Meanwhile, the Malaysian government’s ban on the import of plastic scrap, announced in 2018, is tightening up. Stricter enforcement is evident – shipping firm Maersk recently put out a message reinforcing its position that it does not accept the import of plastic waste into Malaysia on its ships. A ban is in place on its booking system for the relevant HS codes (3915 and 3205) and any false declarations will lead to banning.
The Malaysian government also implemented new guidelines and purity standards for the import and inspection of scrap metal and scrap paper at the start of 2022, as reported by SWEAP, as it seeks to increase the recycling of domestic material and end poor quality waste imports and illegal operations.
How can recyclers navigate this uncertainty
It is clear from our analysis that the era of open global trade of recyclables is ending as governments look to bring recycling back on shore in many geographies. Thus, recyclers need to plan for various scenarios by provider for tightening of export regulations.
They can also work closely with their industry associations to lobby government and regulators to ensure that barriers to free and fair trade are kept to a minimum and to ensure that any planned restrictions take into consideration the business and environmental impact.
Recyclers can invest in emerging AI based material composition and quality analysis solutions to ensure that their finished product reaches the requisite quality standards to ensure compliance with ever increasing export quality standards.
They can be agile to market and regulatory signals and trends by ensuring that they always have a range of both local and remote sales outlets for their finished products.
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