The National Waste & Recycling Association (NWRA) submitted comments Aug. 31, 2017, to the World Trade Organization (WTO) in response to the Ministry of Environmental Protection (MEP) of the People’s Republic of China. The Arlington, Virginia-based association joins other industry groups in making similar comments.
The comments state, “This ban will significantly impact the recycling industry in the United States as well as on the Chinese manufacturing that relies on these recycled materials. We respectfully request that the Chinese government reconsider this ban. Further, we support high quality standards for recyclable materials and support policies to achieve them. Ultimately, we believe that by using high quality standards, China ensures that its manufacturing sector has the raw materials needed to continue to produce goods while ensuring that the recycling industry remains viable into the future."
The comments also list “Items of Concern,” detailing which specific materials the NWRA says would affect the health of commercial and residential recycling, including polymers of ethylene, polymers of propylene, other plastics and unsorted recovered paper.
“These materials represent the residential and commercial recycling sector which our members support,” the comments state. NWRA cites “a significant amount of these materials are exported, mainly to China. In 2016, approximately 41 percent of paper recovered in the North America was exported, with about one-quarter of recyclable paper collected in the United States exported to Chinese mills. Similarly, more than 20 percent of postconsumer bottles and 33 percent of nonbottle rigid plastics from the U.S. were exported in 2015."
The comments also have sections that cover the uncertainty regarding the ban, support for high-quality materials, recycling benefits and problems resulting from this ban. NWRA provides the following recommendations:
- Enforce specifications for recyclable materials – NWRA supports bans on waste materials. However, the recyclable materials exported to China identified by the ban are valuable commodities that are used in the manufacturing on new products. We recommend that China enforce specifications on quality rather than outright ban these materials.
- Clarify definitions – NWRA requests that China clarify the scope of the ban so that we can understand exactly which materials are affected. Clear definitions and specifications for all materials affected are necessary to be able to disseminate information to recyclers for compliance. The lack of such definitions has led to significant confusion about what materials remain eligible for export.
- Delay the implementation – Should China elect to implement the ban, we request that the timeline be adjusted to allow for the development of alternative markets and solutions. Rather than implementing the bans by the end of the year, which could have a catastrophic impact on the United States’ recycling infrastructure, we request that the ban be implemented over a period of time. We recommend that the phase-out occur over a five-year period.
The full comments can be found here.