Open Letter to Basel Convention Delegates and other Interested Government Entities:
We are writing to urge you to support the removal of "B3010: solid plastic wastes" from Annex IX of the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal, and the placement of "Y48: Solid plastic waste, not containing Annex I materials to an extent exhibiting Annex III characteristics, that is contaminated by other materials, and/or mixed with other types of waste, and/or mixed with other plastic materials to an extent which requires special consideration in order to ensure environmentally sound management and minimize the risk of the waste ultimately reaching the marine environment" on Annex II (wastes requiring special consideration) as proposed by Norway. This would make it clear that waste and scrap plastic, while not definitively designated as hazardous waste, would nevertheless be subject to the Prior Informed Consent (PIC) control procedure of the Basel Convention.
Problem
The global production and trade of waste plastic has grown tremendously over recent decades. However, much of this plastic is single-use and of little or no recycling value, or is destined for processing in substandard recycling operations, often in developing countries that may lack meaningful and adequate regulation or effective enforcement. While this problem has been identified, we currently lack sufficient means to properly quantify and track this potentially damaging trade -- and no means to control it should there be concerns. Without such controls, this form of global plastic dumping under the name of recycling may become epidemic with severe global consequences, including an exacerbation of the marine debris crisis.
Until January this year, China was the main recipient of the world's plastic waste, and was forced to burn or bury the residual trash from other countries that couldn't be recycled, leading to massive environmental pollution and public health impacts in host communities processing imported plastic scrap. China has responded to calls to clean up its act by banning the importation of waste plastic and focusing on the collection and recycling of plastic waste generated domestically. Now that China has closed its borders to foreign waste, we are discovering that massive volumes of the same have started to arrive in the ports of Southeast Asian countries, with possibly even less capacity to manage the waste in an environmentally sound manner.
The dangers that plastic poses to the environment and human health are well established. Plastic is now found in all major water systems -- in its visible form it poses a huge threat to marine life and in its broken down form (i.e. microplastic and nanoplastics) it enters the food chain and eventually accumulates in human bodies. When burned in an incinerator, plastic releases persistent organic pollutants, a multitude of toxic emissions, and greenhouse gases. When proper protections are not in place, recycling workers and informal waste pickers are exposed to dangerous and unjust working conditions, and must risk their lives and health to earn a livelihood. We can no longer allow such a dangerous material to be shipped across the world without proper monitoring and controls
Action Required
- Removing "B3010: solid plastic waste" from Annex IX;
- Placing "Y48: Solid plastic waste, not containing Annex I materials to an extent exhibiting Annex III characteristics, that is
- contaminated by other materials, and/or
- mixed with other types of waste, and/or
- mixed with other plastic materials,
to an extent which requires special consideration in order to ensure environmentally sound management and minimize the risk of the waste ultimately reaching the marine environment" on Annex II.
This action will ensure that we take the first step towards the transparency and control over plastic waste we desperately need. This step will remove the presumption that "solid plastic waste" is non-hazardous and ensure immediately that category A3050 will be more fully applied for used plastic materials. And, to finalize the necessary action, as signalled by Norway, the placement of "solid plastic wastes" on Annex II as noted above will provide a proper framework where plastics will be subject to transparency and shipment restrictions if needed.
Conclusion
Countries have a right to know exactly what is being sent to their shores so that they can make informed decisions that fit the needs of their citizens and their environment. Right now the global and transboundary flows of plastic are largely hidden and countries are faced with finding out about arrivals only after it is too late to take preventative action or careful consideration of the consequences of the import.
While China's move to ban plastic imports has sent an important message to the world about the harmful impacts of plastic waste, it has also set in motion many thousands of tons of potentially polluting plastic waste all looking for a new destination, with likely devastating consequences if nations are not allowed the right to know and react to new waste flows.
It was precisely for this reason that the Basel Convention and the Prior Informed Consent procedure were created. With a slight adjustment of the annexes of the Basel instrument, we can respond effectively and expeditiously to the current dangerous plastic waste trade and provide early warning and protection to vulnerable countries around the world.
We the undersigned organizations therefore urge your support to the Norwegian Proposal to:
- remove B3010 from Annex IX;
- and to place "Y48: Solid plastic waste, not containing Annex I materials to an extent exhibiting Annex III characteristics, that is
- contaminated by other materials, and/or
- mixed with other types of waste, and/or
- mixed with other plastic materials,
to an extent which requires special consideration in order to ensure environmentally sound management and minimize the risk of the waste ultimately reaching the marine environment" on Annex II.
Thank you for your consideration,
Alaska Community Action on Toxics (USA)
Amigos de la Tierra (Spain)
Association 3 Hérissons (France)
BaliFokus/Nexus3 Foundation (Indonesia)
Basel Action Network - BAN (USA)
Both ENDS (Netherlands)
Center for International Environmental Law - CIEL (Switzerland/USA)
Center for Public Health and Environmental Development - CEPHED (Nepal)
Centre for Environmental Justice/Friends Of The Earth Sri Lanka (Sri Lanka)
Centre for Environment Justice and Development (Kenya)
CESTA/Friends Of The Earth E El Salvador (El Salvador)
CHEM Trust (UK)
Citizen Consumer and Civic Action Group (India)
Consumers' Association of Penang (Malaysia)
CREPD (Cameroun)
Danmarks Naturfredningsforening (Denmark)
Development Indian Ocean Network - DION (Mauritius)
Drakenstein Environmental Watch - DEW (South Africa)
Drustvo Ekologi brez meja (Slovenia)
Eco-Accord (Russia)
Ecological Waste Coalition of the Philippines (Philippines)
Ecology Center (USA)
Environment and Social Development Organization - ESDO (Bangladesh)
Environmental Investigation Agency (UK)
European Environmental Bureau (Belgium)
Fauna & Flora International (UK)
France Nature Environnement (France)
GAIA
GAIA Africa (South Africa)
Greeners Action (Hong Kong)
Greenpeace International
Work (South Africa)
Institute for Local Self-Reliance (USA)
International POPs Elimination Network
Island Sustainability Alliance CIS Inc - ISACI (Cook Islands)
It's Not Garbage Coalition (Canada)
Korea Zero Waste Movement Network (South Korea)
Mother Earth Foundation (Philippines)
Oceana
Pesticide Action Network - PANeM (Mauritius)
Plastic Change (Denmark)
Plastic Free Seas (Hong Kong)
Plastic Soup Foundation (Netherlands)
Sahabat Alam Malaysia - Friends' of the Earth Malaysia (Malaysia)
Society for Earth (Poland)
Sound Resource Management Group, Inc. (USA)
Story of Stuff Project (USA)
Surfrider Foundation (USA)
Taller Ecologista (Argentina)
The Story of Stuff Project (USA)
United Kingdom Without Incineration Network - UKWIN (UK)
"Volgograd-Ecopress" Information Center (Russia)
"Ziedine ekonomika" (Lithuania)
Wellington Association Against the Incinerator - WAAI (South Africa)
YPBB (Indonesia)
ZERO - Association for the Sustainability of the Earth System (Portugal)
Zero Waste International Trust (Australia)
Zero Waste OZ (Australia)
Zero Waste Villages (China)
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