Plastic Waste Trade Watch
November 2021
This is the latest edition of the Plastic Waste Trade Watch, a monthly review of information from around the world on the international trade in plastic waste. It is produced by Basel Action Network's (BAN) Plastic Waste Transparency Project, which conducts campaigns, networking, research, and statistical analysis of the trade in plastic waste. The project publishes this newsletter summary each month and also maintains the Plastic Waste Transparency Hub website, which serves as an overall clearinghouse for News, Data, Campaigns, and Resources.

To join or sign up new members to the Plastic Waste Trade Watch, click here.
LAUNCHING: The Atlas of Plastic Waste
With this month's Plastic Waste Trade Watch issue, we are proud to announce the launch of a global interactive project: The Atlas of Plastic Waste. The Atlas is a collaboration between the Basel Action Network (BAN) and graduate students Matthew Gordon (Yale University) and Anna Papp (Columbia University). The project aims to harness human discoveries and inputs from satellite and computer technology to identify sites around the world where plastic waste ends up in the terrestrial environment. The goal is to raise awareness worldwide of the unsustainable characteristics of plastic and the large degree it has become an unwanted geographic feature of our collective landscape and Earth's biosphere.

We are soliciting submissions from each of you for the locations of plastic waste dumps to begin the creation of a global database of these sites. If you know of a major dump site (at least the equivalent volume of waste as a large city bus), please submit the information HERE.

We will use satellite data to view the user submitted dump locations this data will, in turn, refine the satellite’s algorithm to find more sites independently/automatically. The Atlas will ultimately contain data based on your submissions to our entry portal, as well as verified new locations discovered by satellite.

Help us create and build this Atlas by inputting known sites in your part of the world and likewise tell your friends to join in from their corners of the world. Together we can make this Atlas a comprehensive global snapshot and help the public and governments better understand the severity of the plastic malignancy on the Earth today.
Photo of the Month
Medan, Indonesia - A woman collects plastic materials at a landfill in North Sumatra province. According to the International Environmental Technology Centre, Indonesia produces more than three million tonnes of unmanaged plastic waste a year, of which more than one million tonnes ends up in the sea. Photograph: Dedi Sinuhaji/EPA
Trade Data Summary
The Basel Plastic Waste Amendments were enacted on January 1, 2021. They were designed to reduce the flows of dirty and mixed plastic wastes, in particular to developing countries. 
OECD countries, in general, continue to flood non-OECD countries with plastic waste. Portion (%) of 2021 (through August) plastic waste exported to non-OECD countries: Japan (89%), U.S. (50%), and E.U. (44%).
Japan has significantly increased plastic waste exports to non-OECD from 22 million kg/month in January 2021 to 51.3 million kg/month in September 2021.
U.K. Exports to Turkey fell from 30.3 million kg/month in February 2021 to 0.47 million kg/month in July 2021. They then increased to 1.2 million kg in Sept 2021.
  • Turkey: Decline in E.U. exports to Turkey from 70.8 million kg/month in March 2021 to 4.6 million kg/month in July 2021. Increased to 10.6 million kg in August 2021.
  • Non-OECD Countries: Huge increase in E.U. exports to non-OECD countries from 29.4 million kg/month in May 2021 to 44.1 million kg/month in July 2021. Decline to 40.9 million kg/month in August 2021.
U.S. plastic waste exports to non-OECD countries were 16.4 million kg in Sept 2021 (2020 average was 28.5 million kg/month). Increase in plastic waste exports to Mexico in September 2021 to 9.7 million kg/month (2020 average was 5.3 million kg/month).
More detailed plastic waste trade information is available in the data section of the Hub
Data Charts of the Month
Basel Implementation News
European Commission publishes draft of new Waste Shipment Regulation
Following months of stakeholder hearings and submissions, the European Commission published its draft Waste Shipment Regulation replacement legislation on November 17th. The long-awaited draft was a step forward in that it called for greater control over exports, but fell short of what NGOs hoped to achieve -- a total ban on exports of all wastes outside of the E.U. and for trade within the E.U. to strictly apply Basel control procedures.

More controls on exports of non-hazardous plastics to developing countries

On the other hand, the draft was far stronger than what the plastics and waste industry hoped for, particularly in efforts to begin to stem the tide of European exports of plastic waste. While the proposed legislation maintained the ban on exports of wastes for disposal, hazardous wastes for recycling, and Annex II (special consideration) wastes for recycling, in a departure from the past, the E.U. moved to further restrict exports of non-hazardous wastes (including plastics) to non-OECD countries. This was done by imposing a requirement to demonstrate facilities in the non-OECD country are operating legally and in an environmentally sound manner. This demonstration must be satisfied with independent audits ordered by the exporter and a definitive listing by the importing country asserting that a long list of criteria is met by the importing facility and the importing country. If the conditions are met, these exports can move under the normal control procedure of prior-informed-consent (PIC). PIC requires prior notification by the exporting country and written consent by the importing country before any trade can occur.

More monitoring of exports for recycling to OECD countries

With respect to exports to OECD countries (including Turkey) the E.U. will ban exports for disposal but not for recycling. For recycling, prior informed consent in accordance with the streamlined consent procedure stipulated by the OECD separate Council Decision on waste trade for recycling will be employed. However, the proposal did include a new article on special monitoring of the OECD shipments and receiving facilities, reserving the right to impose stricter provisions should they be necessary.

Creating an illegal double standard for less control on plastic waste within E.U.

The NGOs were gravely disappointed but not surprised by the E.U. maintaining their earlier decision to ignore the Basel Convention's new Plastics amendments when traded between E.U. member states. The E.U. has taken illegal measures to fulfill a promise to their industry that they would not regulate the new Annex II, Y48 (mixed and contaminated plastic waste stream). According to BAN as well as the Center for International Environmental Law, the E.U. assertion that the European Union Member States need not be bound by the Basel Convention trade rules with respect to trade in mixed and dirty plastic is unacceptable. The assertion is based on the faulty premise that plastic waste management in Europe is well under control and benign. But worse, the E.U. is making a very dangerous misreading of the legal requirements of the Basel Convention's Article 11, which does allow side agreements to Basel, but only if they provide an equivalent level of control.

Finally and very importantly, the Commission moved to make two dramatic improvements to the past regulation in a new Title VII.

New minimum definition of Environmental Sound Management

First, they redefined a minimum for the definition of what will be considered “Environmentally Sound Management” as being conditions and requirements which are “broadly equivalent” to those found in the E.U. All waste shipments cannot proceed without being environmentally sound. This new definitional minimum will be a powerful new obligation to minimize exports.

Major advancements on enforcement

Second, the E.U. proposed numerous improvements in E.U. enforcement mechanisms, including establishing a new task force, giving the Commission itself the right to inspect, and placing more authority on the European Anti-Fraud Office (OLAF).

-- Jim Puckett, BAN

E.U. Guidelines on Interpreting the New Basel Plastics Amendments Finalized (Guidance Document No 12)
With respect to new guidance on how to implement the new Basel Plastic Amendments in the current Waste Shipment Regulation, Correspondents’ Guidelines No 12 was finalized and is now available. The most significant part of the document concerns establishing a contamination level of 2% for exports outside of the E.U. and 6% within. BAN and EEB’s earlier comments on this draft regarding its worthy elements and flaws still stand. That critique can be found here.

The Basel Convention's 2019 Plastic Waste Amendments utilize the terms "almost free from contamination" as one criterion as to whether the plastic waste shipment will be uncontrolled. This term has not been given an international quantitative value, leaving the Parties to define it on a national basis. The following are known levels adopted by certain countries to date. If readers know of other country interpretations, please let us know. Click on the table below to access the PDF with active links.

-- Jim Puckett, BAN
Quotation of the Month
“We are supportive of a global agreement among nations that will accelerate a transition to a more circular economy by expanding systems and infrastructure to collect and repurpose plastic resources."
-- Joshua Baca, Vice President, Plastics Division, American Chemistry Council, voicing his support for a global plastics treaty to address the global plastic waste crisis which would not have been necessary if the industry had taken care to prevent plastic waste generation by not allowing its use in throw-away products and packaging in the first place. Now, after not having learned the lesson, the ACC wants a treaty that only manages plastic waste after it has been produced -- too little, too late.  
Graphic of the Month
As published in Plastic for Profit: Tracing illicit plastic waste flows, supply chains and actors by Global Initiative Against Transnational Organized Crime.
Videos of the Month
Top Stories
German plastic exports rise, containers rotting in Turkish ports
Germany has become a net exporter of Refuse Derived Fuel and mixed municipal waste for incineration, a change from six years ago when imports exceeded exports by a factor of four. Popular destinations for this exported waste lie within the E.U., to Denmark, Sweden, the Netherlands, and the Czech Republic, where exports quadrupled to 102,000 tonnes per year between 2016 and 2020.

Outside of the E.U.’s borders in Turkey, however, 400 containers of German plastic waste are said to be stranded in Turkish ports after officials announced that the waste had been shipped illegally and denied entry. The waste was sent to be recycled by the company 2BPlast, which had lost both its Turkish and German recycling licenses and then attempted to send 218 of the containers to Turkish cement works for incineration, which Turkish officials disallowed. Turkish officials contacted German authorities to have them return the waste but the various authorities contacted in the Lander States refused to take responsibility for the waste, declaring they were not required to do so. One German company, Alba, even attempted to retrieve its share of 30 containers of the waste but was unable to since it was sold through an intermediary and finally to 2BPlast, so Alba no longer owned it. Now, Turkish authorities have apparently agreed to seek third countries as a solution with over 30 of the containers said to be moving to Vietnam. 
TerraCycle misleads customers, settles lawsuit
TerraCycle has settled a lawsuit against it and eight companies, including Procter & Gamble and Coca-Cola, by Last Beach Cleanup, a nonprofit that analyzes corporate claims and labels on recyclability and compostability of their products. The lawsuit alleged that consumers weren’t informed of limits on TerraCycle programs that meant their waste might not be recycled. In the settlement, the brands agreed to a change in labeling standards, including a disclaimer of “Limited Availability” and not to advertise products in the TerraCycle program as “100% recyclable,” and third party certification of what happens to the waste TerraCycle collects. On another front, TerraCycle is pressuring investigative journalists amid their discovery of U.K. waste that the company exported to Bulgaria for incineration, which flies in the face of TerraCycle’s claims of circularity. After talking to numerous waste export brokers about misdeclaring, bribing, and cheating on a customs declaration, one broker led them to a site in Bulgaria which contained 30 bales of TerraCycle waste identified by their labels.
Coca Cola, Unilever, Nestle etc. want to burn plastic waste
Large multinationals, including Unilever PLC, maker of Dove soap and Hellmann’s mayonnaise, are funding a new project in Indonesia to burn more plastic waste in cement kilns. This approach is promoted by these companies as a win-win, keeping trash out of landfills and providing cheap energy; however, in reality, waste incineration creates and emits POPS such as dioxins on top of carbon dioxide while creating toxic ashes which must be disposed, further burdening the often disadvantaged communities where these facilities exist. Similar projects have also involved other leading sources of plastic waste, including Coca-Cola, Nestle, and Colgate-Palmolive.

Scottish firm fined for illegal shipment
A Scottish recycling firm, Saica Natur, pled guilty to contraventions of waste shipment regulations and was fined 20,000 GBP for sending 51 containers of contaminated waste paper to China in 2016. The bales contained a multitude of contaminants, including nappies, plastic food and drink containers, and electronic equipment. Scottish Environmental Protection Agency (SEPA) investigators said that the overwhelming majority was not suitable for export.
Key Campaign Updates
U.K. Environment Act lacks urgency on exports
While the E.U. has moved to curtail exports of all wastes, the U.K. government has passed the Environment Act 2021, which stops short of any new restrictions or regulations on waste exports. However, the government argues that it gives the “powers which will allow the government to regulate, ban or restrict the import and export of waste, enabling us to deliver on our commitment to ban the export of plastic waste to non-OECD countries.” Relatedly, the U.K. may soon need to find new avenues for their plastic waste exports, as the E.U. has imposed 2% contamination rules for countries outside its borders. At present, the U.K. sends the vast majority of its plastic waste exports to the E.U.
Opinion of the Month
Six reasons why Boris Johnson is right about recycling – Maja Darlington of Greenpeace U.K.
New Resources
-- Plastic for Profit: Tracing illicit plastic waste flows, supply chains and actors – Report by Global Initiative Against Transnational Organized Crime

Upcoming Events
Should the E.U. ban all exports of its waste? – Webinar by ZeroWasteCities, December 7th, 2021 – 2:00PM CET
Plastic Waste Transparency Project