“ISRI fully supports the efforts of the Chinese Government to improve environmental protection and standards within its domestic recycling infrastructure. However, we disagree that a ban on the import of specification‐grade scrap materials will help with those efforts. …

“For recycled commodities such as recovered paper and fiber, plastic scrap, and copper scrap, China accounts for more than half of the world’s total imports. Thus, any change in Chinese policy concerning the import of these commodities will be quickly felt around the world. …

“There is a need to distinguish scrap from waste within the Notification, as well as in the underlying regulations and related notices issued by the Chinese, in order to properly identify those materials for which the Chinese Government intends to truly impose a ban, while at the same time providing clarity for the exporting community as to what products are permissible for import. …

“The U.S. recycling industry stands ready to help China to prevent deficient practices that harm the physical environment in China. The U.S. recycling industry also supports the Government of China’s efforts to improve domestic collection, processing and distribution of scrap materials and welcomes the opportunity to provide information and training on operational best practices, including RIOS^™. U.S. industry can share information and analysis of market conditions and how to develop supply chains to ensure the efficient use of scrap materials, especially with environmental sustainability in mind. We also recommend that the Chinese Government officially recognize industry‐wide standards as outlined in the ISRI Specifications Circular.”