One of the largest recycling trade groups in the United States wants China to revise its proposed ban on imported recycled scrap, saying it would significantly disrupt trade and do little to meet Beijing's goal of protecting the environment.
The Washington-based Institute of Scrap Recycling Industries Inc. said in formal comments to the World Trade Organization Aug. 20 that China's plans, first given to the WTO in mid-July, could also be a form of trade protectionism.
"ISRI fully supports the efforts [of China's government] to improve environmental protection and standards within its domestic recycling infrastructure," it said. "However, we disagree that a ban on the import of specification-grade scrap materials will help with those efforts."
China said its ban is needed to prevent illegal "foreign garbage" from entering the country, but the U.S. association argued that the quality of scrap materials to China have improved in the last 15 years, particularly after China enacted licensing requirements for exporters more than a decade ago.
"While incidents have occurred over the years of shipments of true 'garbage,' as well as non-specification, low-quality scrap being shipped into China under the guise of being recyclables, such incidents are now very rare, well under 1 percent of total container shipments," ISRI said.
ISRI and others in the global recycling industry are urging the Chinese government to clarify details, saying that uncertainty is causing significant confusion, particularly since Chinese manufacturers continue to depend on "high-quality scrap" supplied by the U.S. recycling system.
It's not clear, for example, how the ban would treat post-industrial sources such as high density polyethylene crates, buckets and drums, and whether it would apply to all post-consumer sources of plastics, or only those that have come into contact with potential organic contaminants, ISRI said.
Some groups are saying China will in fact allow post-industrial scrap. The head of the China Scrap Plastic Association said a government statement Aug. 16 indicates production scraps will be OK, but also acknowledged that many general questions remain about implementation.
ISRI also called on China to clarify what it considers waste, or garbage, and what it considers scrap that can be reused, and adopt official language to better recognize that distinction.
ISRI said it publishes hundreds of specifications for grades of recycled scrap materials and urged the Chinese government to officially recognize industry-wide standards like those. ISRI said the government of India references ISRI's specifications in its import standards.
The association supports China's efforts to crack down on non-compliant waste imports and offered its help. It also said illicit imports "in many ways" contribute to the poor quality of scrap processed in Chinese factories.
"We firmly believe that improvements to their operational practices would go much further to protecting the environment, and also to growing China's domestic recycling industry [with the support of international partners] than the use of import restrictions," ISRI said.
China accounted for 51 percent of global imports of recycled plastic scrap last year, ISRI said, although some industry officials said China is a larger market for European recycled plastic exports than North American exports.
ISRI also asked China to clarify the implementation dates noting that China's official notice to the WTO says imports will be forbidden by Dec. 31, but also says the policy would go into effect as of Sept. 1.
Other recycling associations agreed that significant questions remain.
"Frankly, we're still trying to figure it out," said Steve Alexander, president of the Association of Plastic Recyclers in Washington. "I don't think anybody really knows at the end of the day what this is going to look like. Hopefully in the next couple of months this will ferret itself out."
In a webinar for APR members, Alexander said there's concern that China's ban could hurt the market for bales of mixed plastics, particularly for polypropylene, which has been a particular focus for APR market development in recent years.
Apart from implementation questions, ISRI also raised concerns that a ban could be designed to protect China's nascent domestic recycling industry.
It noted a July 27 policy statement from Beijing that talked about accelerating domestic recycling so that locally collected materials could replace imports by 2019.
"Thus, imposing a ban on imports of recyclable materials can be construed as a protectionist policy to support this industrial development," ISRI said.