ISRI submits comments on China to administration’s National Trade Estimate Report

Comments shed light on the evolving regulatory environment in China affecting scrap commodities imports into China.


The Institute of Scrap Recycling Industries (ISRI), Washington, submitted comments Oct. 25, 2017, to the Office of the U.S. Trade Representative (USTR) as the agency prepares to compile its annual report on foreign trade barriers.

The National Trade Estimate (NTE) Report traditionally includes a chapter on China and the challenges U.S. companies encounter doing business in China, ISRI says. The report is read by members of Congress and the global trade community, providing another venue to raise public awareness about China’s scrap import restrictions, according to the association.

The 2017 NTE Report on Foreign Trade Barriers is the 32nd in an annual series that highlights significant foreign barriers to U.S. exports, according to the USTR’s website.

“As with previous public submissions, ISRI argues about the potential negative impact China’s ban and contaminants threshold could have on the U.S. recycling industry when implemented by the end of the year as expected,” ISRI says. “ISRI continues to promote ‘Scrap is Not Waste’ and to encourage the adoption of ISRI Specifications as guidelines for material content and quality. ISRI also offers support to China as the government addresses its environmental problems.”

In its comments, ISRI says it supports China’s efforts to protect the environment and to increase recycling rates in China. “We have offered our support to provide information on best practices in the industry,” ISRI says in its concluding comments.

ISRI continues, “We agree and support the need to separate unusable waste from high value, specification-grade commodities scrap and will continue to advocate for the adoption of ISRI’s Scrap Specification Circular as the global standard for evaluating waste and scrap imports. Such collaboration would go much further to help China address its environmental concerns than would restrictions on imports.”

ISRI’s response can be read in full here.

For more information, contact ISRI Senior Director of International Relations Adina Renee Adler by email at aadler@isri.org