The deadline for comments to the World Trade Organization (WTO) on China’s amended proposed contamination standards passed on Friday and three major waste and recycling associations—the Institute of Scrap Recycling Industries, the National Waste & Recycling Association and the Solid Waste Association of North America—all submitted comments.

The groups pushed for more specificity in the guidelines, raised concerns at how the rules might roil global recycling markets and asked for a delay in implementation of any import regulations.

ISRI officials said they support the Chinese government’s strategy to improve the environment and encourage sustainable recycling. However,  they are concerned that the draft standards, if implemented, will lead to extensive disruptions in global supply chains because the proposed standards are not in line with the globally recognized ISRI Specifications and lack specific guidance for exporters.

 In the submission, ISRI President Robin Wiener requests specific, written guidance on the definition of “other carried waste,” suggests that the allowable percentages align with ISRI Specifications and requests more time to allow for global suppliers to understand the regulations for adequate compliance.

“ISRI understands that at the heart of China’s approach with the proposed GB standards is an effort to identify what is ‘garbage’ so that China can rightfully prevent such material from entering the country,” wrote Wiener in the submission. “We suggest the Chinese Government revise its GB standards to very specifically define what is intended to be minimized in terms of the percentages listed, giving particular attention to distinguishing between unusable trash that should have gone to a landfill and recyclable materials.” 

The full text of the comments can be read on ISRI’s website.

SWANA said its comments highlight the significant impact China’s waste import restrictions have already had on municipal solid waste recycling programs in parts of the U.S. and Canada, urging the Chinese government to suspend the implementation of the restrictions until no earlier than January 1, 2022. 

“With 2018 nearly upon us, recycling programs from coast to coast are being adversely affected by China’s actions,” SWANA Executive Director and CEO David Biderman said in a statement.“Plastic film is being warehoused, recyclables in Oregon are going to landfills, and the uncertainty created by China’s actions has created a significant disruption. While we call on China to postpone implementation, we also call on recycling companies and local governments to ensure they are generating high quality material that satisfies legitimate environmental concerns; this may require investment in additional equipment or personnel, slowing down the line, and increasing and improving education to residents and business.”

SWANA also pointed out that the proposed 0.5 percent contamination standard for waste imports was proposed without seeking input from any foreign stakeholders and is not based on any internationally accepted standard or specification. SWANA requests that MEP explain the basis for the carried-waste 0.5 percent contamination standard.

“The proposed contamination standard is not practical to achieve even at the most state of the art facilities in North America,” Jeff Murray, SWANA’s international president, said in a statement. “While modifications to the collection, sorting, and processing of mixed residential recyclable materials can improve the quality of the feedstock produced, it will be unable to achieve the levels the Chinese have proposed. The proposed implementation schedule is unfair, and we are seeking more time to assess potential changes and what standard can be achieved.”

SWANA’s comments express strong support for China’s efforts to protect and improve their environmental conditions and requests the Chinese government meet with industry stakeholders from the U.S., Canada, and other exporting countries to develop a mutually satisfactory carried-waste contamination standard and a timeline for implementation, in order to help China achieve its overall environmental health objectives.

To view SWANA’s full comments, click here.

NWRA, meanwhile, said the modifications to the standards would lead to a decline in recycling rates globally as well as an increase in green-house gas (GHG) emissions.

“NWRA supports high quality standards for recyclable materials and supports policies to achieve them. Our member companies’ processing facilities work to completely eliminate all materials that do not meet those specifications. We support the use of existing, internationally recognized specifications. The global recycling industry will face significant challenges should these standards move forward as written,” NWRA CEO and President Darrell Smith said in a statement.

Click here to access NWRA’s comments.