ISRI files comments with World Trade Organization

Filing is in response to China’s proposed scrap import standards.

December 18, 2017

The Washington-based Institute of Scrap Recycling Industries (ISRI) says it submitted comments in mid-December to the World Trade Organization (WTO) in response to notifications made by the China’s government Nov. 15, 2017, regarding proposed scrap import standards. While ISRI says it supports China’s strategy to improve the environment and encourage sustainable recycling, the association says it is concerned that the draft standards, if implemented, will lead to extensive disruptions in global supply chains. ISRI’s concern arises from the proposed standards not being in line with the globally recognized specifications the association has developed and the lack specific guidance from China for exporters.

In the submission, ISRI President Robin Wiener requests specific, written guidance on the definition of “other carried waste,” suggests that the allowable percentages align with ISRI specifications and requests more time to allow for global suppliers to understand the regulations for adequate compliance.

“ISRI understands that at the heart of China’s approach with the proposed GB (national) standards is an effort to identify what is ‘garbage’ so that China can rightfully prevent such material from entering the country,” Wiener writes in the submission. “We suggest the Chinese government revise its GB standards to very specifically define what is intended to be minimized in terms of the percentages listed, giving particular attention to distinguishing between unusable trash that should have gone to a landfill and recyclable materials.”

She continues, “Each proposed GB standard also contains a catch-all restriction for ‘other carried-wastes’ with a set threshold for the allowable percentage by weight. It is this last restriction that has raised concerns within ISRI and the global recycling industry as the percentages proposed are in many cases (but not all) out of line with global norms and established manufacturing tolerances.

“We anticipate additional questions about China’s scrap import regulations to arise as our industry tries to adapt to the regulatory changes and, therefore, we respectfully suggest an opportunity to meet with MEP (Ministry of Environmental Protection, SAC (Standardization Administration of China), AQSIQ (General Administration of Quality Supervision, Inspection and Quarantine) and other relevant authorities for a walk-through of the regulations, enforcement measures and other potential scenarios that could occur in the normal course of trade,” Weiner writes.

She goes on to suggest that the Chinese government delay implementation of the proposed standards in line with WTO guidelines. “Extra time is required for recyclers to fully understand China’s changing scrap import regulations and to make the necessary changes to comply with these new rules,” Weiner writes.

 The full text of the comments can be read on ISRI’s website.

The Solid Waste Association of North America (SWANA), Silver Spring, Maryland, also submitted comments to the WTO urging China to delay implementation of its waste import restrictions, urging the Chinese government to suspend the implementation of the restrictions until no earlier than Jan. 1, 2022.