During your 2019 to 2024 Presidency, the EU has made important progress on a variety of environmental priorities. We, the nine undersigned non-governmental organisations, now write to urge you to deliver on your vision to curb microplastic pollution in the European Union and cement your legacy as a global leader in tackling plastic pollution – and microplastic pollution, specifically – with decisive action in the next few months. This would firmly set the EU on the path to meeting its ambitious target of a 30% reduction in microplastic pollution by 2030, as set out in the Zero Pollution Action Plan.
Given the magnitude of microplastic pollution, we commend the Commission for making strides towards curbing the release of microplastics into the environment. The recent adoption of the European Commission’s proposal on the restriction of intentionally-added microplastics by the REACH Committee is a step in the right direction and aligns with the European Chemicals Agency’s findings that microplastics pose an inadequately controlled risk to the environment.
Nevertheless, microplastics unintentionally released from paints, tyres, pellets, and textiles still require urgent attention: these sources represent the vast majority of microplastic emissions to the environment. We are encouraged to see progress on legislative initiatives to curb emissions from tyres and textiles through Euro 7 and the EU strategy for sustainable and circular textiles, respectively, and see the potential for the Ecodesign for Sustainable Products Regulation to cover sources such as paint, tyres, geosynthetics and textiles. However, after years of delays, we are yet to see the release of a dedicated proposal to reduce microplastic emissions from the aforementioned sources and tackle the release of pellets – the third largest source of microplastic emissions in Europe.
Pellet loss occurs at every stage of the supply chain, yet loss and spills are preventable by implementing low-cost pellet handling best practices. Since 1991, the plastics industry has derived a set of best practice measures known as Operation Clean Sweep (OCS). However, OCS is a voluntary scheme with a lack of monitoring, compliance, and enforcement mechanisms. Further, only approximately 5% of the European plastics industry has committed to OCS.
Meanwhile, pellet pollution continues to plague Member States. A study funded by the European Commission estimates that 167,431 tonnes of pellets may be lost to the environment in Europe per year. Tackling pellet pollution is clearly high on the agenda for Member States. In 2021, the OSPAR contracting parties adopted Recommendation 2021/06, emphasising the need to develop and implement pellet loss prevention standards and certification schemes based on best practices, aiming to prevent or significantly reduce plastic pellet loss across the entire supply chain.In a call for ambitious measures, five Member States underscored the need for precautionary measures at the EU level as “national and voluntary measures alone are not sufficient” and that “measures should be taken early in the lifecycle.”
What is needed now is mandatory, EU-wide legislation that obligates all pellet-handling companies to provide independent verification that pellet loss prevention measures have been implemented, maintained, and monitored for effectiveness. EU-wide action would eliminate this preventable source of microplastic pollution, ensure a level playing field for businesses of all sizes, and demonstrate global leadership in enacting decisive measures to address pellet loss. EU legislation can also serve as a blueprint for action on microplastic and pellet pollution in the ongoing negotiations to develop a legally binding instrument on plastic pollution.
In conclusion, we urge the European Commission to prioritise the swift release of this crucial proposal, which is vital for delivering the 30% microplastic pollution reduction target, advancing the objectives of the Green Deal before the end of this legislative mandate in 2024, and strengthening Europe’s position as a global leader in addressing plastic pollution.
As Members of the European Parliament, your role is pivotal in delivering a 30% reduction in microplastics released into the environment by 2030 as per the EU target set in the Zero Pollution Action Plan. We, the undersigned non-governmental organizations (NGOs), are writing to urge you to take action to address the pressing issue of microplastic emissions from tyre abrasion. Owing to reductions in tailpipe emissions and the shift to zero-emission mobility, it is estimated that by 2050 up to 90% of particulate emissions from road transport in Europe will come from non-exhaust sources—namely tyres and brakes—representing the next frontier for regulatory efforts to improve air quality. Furthermore, non-exhaust vehicle emissions from tyres represent the second-largest quantified source of microplastic emissions in Europe, accounting for an estimated 450,000 to 500,000 tonnes per year, making tyre abrasion limits a priority for protecting both human health and the environment and critical to meeting the 30% reduction target.
Microplastics – plastic particles less than 5mm in size – have been found in human lungs, blood and the placentas of pregnant women. They can cause adverse effects on the reproduction, growth and survival of aquatic organisms, as well as potential negative impacts on soil ecosystems and plant growth. Tyre particles also include a number of harmful chemicals that can leach into the environment and affect human health, including polyaromatic hydrocarbons (PAHs), 6PPD and heavy metals such as zinc and lead. Furthermore, studies have shown a significant association between exposure to airborne particle pollution and human health risks, such as cardiovascular effects and respiratory problems. For tyre wear particles specifically, laboratory studies indicate inflammatory effects on human cells.
Given how critical reducing microplastic emissions is for safeguarding human health and protecting natural ecosystems, the Commission’s proposal for new Euro 7 vehicle emission standards, released in November 2022, seeks to establish tyre abrasion limits for the first time. Under this legislative process, the European Parliament has a new opportunity to protect the well-being of European citizens and our environment.
However, we are concerned by the proposed amendments on Recital 12 and Article 15 put forward by the rapporteur in the Committee on the Environment, Public Health and Food Safety, which aims to bind the measurement methods and proposing tyre abrasion limits to the work being undertaken by the GRBP/GRPE Task Force on Tyre Abrasion, conducted under the UN World Forum for Harmonisation of Vehicle Regulations (WP29). We are supportive of the work underway in WP29 and understand that global alignment on regulation (in particular testing methodologies) reduces complexity for the auto industry. However, requiring full alignment on the timeline and ambition of limits – with a still-to-be developed UN regulation – could unnecessarily delay the work to establish tyre abrasion limits within the EU and result in weak and ineffective pollution limits hence jeopardizing the EU’s ability to meet the reduction target set out in the Zero Pollution Action Plan and infringing on the EU’s sovereignty to set regulation.
We, therefore, call on Members of the European Parliament to empower the European Commission to propose secondary legislation, including the test method and abrasion limits for tyres by December 2024, taking into account findings from the WP29 process where applicable but allowing for higher ambition if the limits set by the UN regulation are weak or faster progress within the EU if there is no agreement or delays at the UN level. This would ensure that the EU is able to establish tyre abrasion limits by the end of 2024, as currently foreseen in the Commission’s Euro 7 proposal.
In addition, we invite the European Parliament to consider amendments to:
Add a reference to the Zero Pollution Action Plan in order to, at a minimum, align future tyre abrasion limits to the targets set out in the plan.
Clarify that type approval of tyres – a process to certify that the product meets specified requirements – will apply to tyre manufacturers and to all new tyres placed on the market, and not just to tyres intended for new vehicles approved under the Regulation.
Request that the Commission prepare a report reviewing the chemical toxicity of tyre particle emissions and propose policy measures accordingly based on the findings of the report.
If adopted, such policy recommendations would mark a significant milestone in addressing microplastic pollution from tyre abrasion, setting a global precedent. Given the projected increase in microplastic emissions from tyres and their proven health and environmental impacts, urgent and binding action at the EU level is needed to address this problem at the source. With ambitious legislation on tyre abrasion, the EU can lead the way to tackle microplastic pollution globally, securing a cleaner and safer environment for all.
Plastic waste exports can have catastrophic impacts on the environment and human rights, especially the right to a clean, healthy and sustainable environment. Plastic waste ends up polluting water, contaminating air, and harming the health of people already facing poverty and marginalization. This is a terrible environmental injustice!
Dr David R. Boyd, UN Special Rapporteur on human rights and the environment.
On December 10, 1948, the Universal Declaration of Human Rights (UDHR) was passed – a milestone document which proclaims the inalienable rights that everyone is entitled to as a human being, irrespective of race, colour, religion, sex, language, political or other opinion, national or social origin, property, birth or other status.
In 2022, 75 years later, 161 countries at the United Nations General Assembly passed a resolution recognising the right to a clean, healthy, and sustainable environment as a human right. Yet, vulnerable communities globally continue to face injustice as a result of plastic waste mismanagement and pollution.
Millions of tonnes of plastic waste are traded globally every year. Several reports show that exported plastic waste often ends up in landfills, is burnt or incinerated as fuel, or is discarded into waterways. This has serious implications for the health and wellbeing of communities living at the fringes of dumpsites or factories, workers in unauthorised plastic waste recycling facilities, as well as the environment.
Here are personal stories of individuals and communities, the disproportionate costs they bear due to waste colonialism, and how their rights to health and a healthy environment have been violated.
Malaysia
In January 2018, China implemented its National Sword Policy to stop most plastic waste imports. Between January and July that year, Malaysia, a tiny country flanking the South China Sea, imported nearly half a million tonnes of plastic waste. What happened, and who is bearing the true costs of this reckless economic move?
Quote Source: The Recycling Myth report, Greenpeace Malaysia, 2018. Quote Source: Lay Peng Pua, Kuala Langat Environmental Action Association.
Indonesia
Rural communities in Indonesia who worked in lush-green maize and paddy fields not so long ago, have turned to waste work today. Places like Kragilan and Bangun village in East Java have become dumpsites, where plastic scraps shipped along with waste paper imports are discarded or incinerated.
Sifting through plastic scrap has become a community-level cottage industry. Waste pickers and communities living around recycling factories constantly breathe in toxic fumes generated by burning plastic. These images are from Bangun, East Java, Indonesia.
As awareness increases in some countries across Southeast Asia and restrictions on plastic waste imports are implemented, Turkey has become Europe’s plastic waste destination.
This resulted in a surge in illegal disposal methods: dumping and burning of imported garbage has been reported in İzmir and İstanbul, with much of the activity centred in Adana.
The recent influx of EU plastic waste imports also contributed to the growth of the plastic recycling sector, harming the health of workers and nearby communities.
In the past 16 years, there has been a 241-fold increase in plastic waste importation to Turkey – the soil, air and water around dumping sites bear testimony to the chemical poisoning caused by burning plastic waste.
Image credits: Caner Ozkan / Greenpeace (via Basel Action Network on Flickr – CC BY-SA-NC), Human Rights Watch. Quote source: “It’s as if they’re poisoning us”: the health impacts of plastic recycling in Turkey, Human Rights Watch.
The Philippines
In 2014, the Philippine Commission on Human Rights (CHR) issued a “Fifteen-Point Human Rights Agenda” to uphold “the people’s right to chemical safety” which “acknowledges that trade of toxic wastes, products and technologies, collectively toxic trade, also forms a disincentive towards attaining Zero Waste resource management.”
Human rights defenders have organised protest rallies to defend their right to a healthy environment, drawing attention to the fate of mixed plastic trash being dumped in the country, and even ensuring the repatriation of more than 100 shipping containers back to Canada in 2019 and South Korea in 2020.
Perpetrators of waste colonialism must be held accountable for these human rights abuses. The adverse impacts of waste trade on human rights is faced disproportionately by developing countries – to better protect these communities, PLASTIC WASTE TRADE MUST STOP!
We are in the midst of a worldwide plastics crisis. International waste trade creates an illusion of proper recycling, when there is actually a geographical shifting of the plastic waste problem, affecting the rights of the most vulnerable.
A human rights-based approach calls for a vision of plastics policy that aligns with scientific evidence, centres on principles of non-discrimination, accountability and informed participation and gives special attention to the needs of people in vulnerable situations.
Strict controls must be instituted to prevent further pollution and to hold plastics and chemical producers accountable for the damage already caused, including remediation and compensation.Safeguarding the human rights of present and future generations that are compromised by the growing toxification of the planet demands that the international community reverse the plastics crisis.
Dr Marcos A. Orellana, UN Special Rapporteur on toxics and human rights.
What can we do?
This World Human Rights Day, there are glimmers of hope.
On December 1, the Environment Committee of the European Parliament voted to set a ban on EU plastic waste exports to OECD and non-OECD countries, as part of the revision of the EU Waste Shipment Regulation. The European Parliament Plenary will have to confirm these measures in another vote, followed by the Council.
Keep up the pressure to ensure the export ban gets confirmed, and that the final decision includes stronger measures against waste dumping within the EU – send this letter to European embassies in your country!
For over a decade, the town of Ecaussines in Belgium has been facing the destructive impacts of pollution from Plastic Pellets also known as nurdles, spilled by the petrochemical complex present in the area.
160,000 tons of pellets are dumped into the environment every year in Europe Last March, Surfrider Foundation Europe and the Rethink Plastic alliance decided to invite decision makers to witness this pollution with their own eyes.
Once again, the industries are proving that the voluntary Operation Clean Sweep initiative is not working to reduce plastic pellet pollution – as shown in other cases such as Tarragona.
Overall production of packaging and packaging waste has steadily grown over the past 20 years. In 2018 a record high of 174 kg of packaging waste per person was reached in Europe. Between 2009 and 2019, paper & cardboard were the main type of packaging waste per weight (32.2 million tons in 2019), ahead of plastic and glass (15.4 and 15.2 million tonnes, respectively, in 2019).
Currently, most packaging in Europe is:
Single-use: with enormous environmental impacts from production down to waste, including resource extraction; use of raw materials; land, energy, and water use; and CO2 emissions. As levels for single-use packaging continue to rise, current waste management systems cannot cope.
Warming our planet: Research shows that across their lifespan, plastics account for 3.8% of global greenhouse gas emissions. That’s almost double the emissions of the aviation sector. In order to manufacture just one kilogram of plastic, 3.5 kg of CO2 are emitted into the atmosphere. And incineration of one particular type of plastic packaging (40% of plastic demand) waste amounted to 16 million metric tons of CO2 in 2015. In 2019, the global production and incineration of plastic (including plastic packaging) emitted more than 850 million metric tons of greenhouse gases — equal to the emissions from 189 five-hundred megawatt coal power plants.
Putting our health at risk: In Europe alone, over 8,000 chemicals can potentially be used in food packaging, tableware, and other food contact materials, with many of these chemicals linked to cancer, harm reproduction, and hormone disruption. More about chemicals in food contact materials can be found in these infographics.
Wasting our food: 37% of all food sold in the EU is wrapped in plastic packaging. Packaging, which should protect food and increase its shelf life, is often found to be a driver of food waste. Recent researchhas shown that wrapping fresh products in plastic packaging does not make them last longer, but rather adds to pollution and food waste. The research concluded that when food products were sold loose, and the best-before dates removed, it could save more than 10,300 tonnes of plastic and about 100,000 tonnes of food from being wasted each year – the equivalent of 14 million shopping baskets of food. Packaging often forces people to buy more than they need, while oversized packaging and packaging items that are difficult to empty also lead to the waste of perfectly edible food.
Non-recyclable and not recycled: the overwhelming majority of packaging doesn’t get recycled. Most statistics available on the recyclability of packaging are inaccurate, as the current waste management scenarios do not reflect the real conditions of the sector. Just because a product is recyclable does not mean it will be collected, recycled and turned into new materials and products. Most often, waste management infrastructures lack the functionality to deal with different formats of packaging . The greater the mix of materials within the packaging, the lower the overall quality the recycled material becomes. Currently, most single-use packaging placed in the EU market is made out of complex materials; involving different materials or layers, as well as many different types that should not be recycled together. The presence of many chemicals in packaging along with food leftovers also hampers recycling. Furthermore, current recycling statistics do not take into account the inappropriate disposal.
Traded as waste sent to countries outside Europe: where it is usually burnt, landfilled, or leaked in the environment. The European Union relies heavily on international trade for its overgeneration of plastic and packaging waste. In 2019, the EU exported a monthly average of 150,000 tonnes of plastic waste beyond its borders. In 2017, plastic packaging accounted for 75% of the plastic waste exported (by weight). Since most single-use packaging are not recyclable, they are exported “for recycling” to third countries – mainly to countries in the Global South with significantly more limited waste management infrastructures. In fact, a third of the plastic packaging destined for recycling is shipped outside of EU territory, where control over whether the recycling process actually happens (or happens under the right conditions) cannot be monitored.
Packaging at the core of the solution
As a principle, packaging that cannot be safely used, reused and recycled at the end of its life should not be produced or placed in the market in the first place. The solution to stop this packaging pollution chain is logical: the less packaging we produce, use, and discard, and the less materials we extract, the better for our environment and society. This is why it is crucial to think upstream: rethinking and redesigning packaging so that these products are toxic-free, circular by design, and contribute to regenerating ecosystems instead of polluting them.
Reducing and redesigning packaging is key to solving most of the problems above. By eliminating packaging that we don’t need, we can save resources, reduce emissions, and minimise waste. A good example is the French Circular Economy Law which seeks to reduce single-use plastic packaging and to develop alternatives such as bulk or reusable packaging. As of 1 January 2022, plastic packaging is banned for most fruits and vegetables in France.
Rethinking the purpose of packaging itself helps to not only prevent packaging waste, but also to prevent food waste as consumers can buy exactly what they actually want to consume – not more, not less! Promoting local and short supply chains, such as farmers’ markets, community supported agriculture schemes, and basket delivery systems have great potential to connect consumers to the production of food in ways that can help to reduce food and packaging waste.
Reusable packaging systems are a crucial element to this equation. The more times a product can be used, the lower its negative environmental impact, regardless of its material. A reusable glass bottle has 85% less emissions than its single-use counterpart; 70% less emissions than a single-use PET bottle; and also 57% less emissions than a single-use aluminium can. Setting up well-managedpool systems for washing and redistribution of reusable packaging, is a key instrument to make efficient and effective reuse systems work.
Specifically on safe, toxic-free packaging, EU legislation is required to phase out the most hazardous chemicals and ensure packaging is safe for use, reuse and recycling. Manufacturers can already introduce innovative solutions and/or by scaling up existing safer solutions for packaging (e.g. avoiding toxic glues and inks, using glass or metal containers for reusable options).
Sustainable packaging systems and take-back systems such as deposit return schemes (DRS) enable the return of packaging to the system to be preferably reused, or recycled; and it should be among the high-priority solutions and measures to achieve true circularity for packaging.
By redesigning packaging with circularity in mind, it is possible to reduce uses of hazardous chemicals; reduce food waste; and get rid of 75% of the waste that is currently being exported, thus mitigating climate change impact through the reduction of carbon footprints. It will also allow us to ensure that this packaging is primarily reused and effectively recycled in Europe at the end of its life.
With the right support and conditions, reuse can thrive in Europe, and lead to a much needed effective reduction in plastic use and pollution while supporting a healthy environment and society.
Reuse is a system in which products and packaging accomplish multiple trips or rotations within their life span, by being returned to a producer and re-used for the same purpose in which they were originally conceived, as opposed to single-use products and packaging designed to be disposed of after one use. Successful reuse systems require infrastructures like refill stations, collection points, storage, cleaning facilities and transport to ensure the packaging or product can go back to the producer for reuse or refill. Systems like this have existed before, and they can exist again. Remember the milk man?
That’s why the Rethink Plastic alliance and #breakfreefromplastic movement are calling on EU decision makers to tackle the significant human health and environmental impacts caused bysingle-use plastics production and waste by supportingreuse and signing the We Choose Reuse commitment!
We need everyone on board for the reuse revolution ! The support of EU decision-makers is particularly critical and timely. The EU is currently designing policies that have the potential to make reuse the new normal in the EU, notably the Ecodesign for Sustainable Products Regulation, the Packaging and Packaging Waste Directive and the EU Taxonomy on sustainable finance.
For inspiration on how to engage decision-makers, our #breakfreefromplastic Slovenian member Ekologi brez meja offers their effective engagement process, which gained support from three Slovenian MEPs for reuse – Irena Joveva, Milan Brglez and Franc Bogovič.
“Gaining support for #WeChooseReuse from almost half of the Slovenian representation in the European Parliament, who represent from different political backgrounds, is a great forecast for reuse in the EU.” shares Public Relations President at Ekologi brez meja Katja Sreš. “We have used the prepared materialsby the #WeChooseReuse campaign team and distributed them among all our MEPs with a given deadline for response. “The teams of Irena Joveva, Milan Brglez and Franc Bogovič responded within minutes and once again lent their voice to one of our causes. I am positive if we would be even more persistent and would send out reminders to the others, we would also get on board with the other five members. Nevertheless, this will be our mission in the next decision-makers call to action.”
There is an appetite for reuse within and beyond the European Union. By actively engaging with MEPs and using the #WeChooseReuse campaign to illustrate the benefits of reusable systems, EBM have set an inspiring example of what can be achieved through effective engagement.
European Parliament, 11 May 12:00 – 14:00 (hybrid event)
What’s the impact of EU plastic waste trade and how can the EU end its damaging practices and achieve a circular economy?
As all eyes are on the revision of the Waste Shipment Regulation, the Rethink Plastic alliance invites you to the European Parliament to this crucial hybrid event calling on the EU to implement a full ban on EU plastic waste exports.
Agenda
12.00- 12.30: Light lunch provided 12.30 – 12.35: Welcome, introductory remarks from MEP Cyrus Engerer 12.35 – 12.45: Screening extract of documentary The Recycling Myth on illegal exports to Turkey 12.45 – 13.30: Speeches from:
Krista Shennum, Fellow, Human Rights Watch
Yuyun Ismawati, Founder of the Indonesian NGO Nexus 3 Foundation, Goldman Environmental Prize Winner 2009
Sedat Gündoğdu, Associate Professor, Cukurova University
Emmanuel Katrakis, Secretary General, EuRIC
Lauren Weir, Ocean Campaigner, Environmental Investigation Agency and the Rethink Plastic alliance
13:30 – 13:50: Q&A with the participants, moderated by the Rethink Plastic alliance 13:50 – 14:00 Closing remarks by MEP Cyrus Engerer
You can register here by 5 May. You can join the event online here.
The following text is courtesy of the Center for International Environmental Law. For more information, see their policy briefing.
Plastic is a growing crisis for the environment, human health, human rights, biodiversity, and the climate — actions to address it are needed NOW at the global level.
Momentum is rising. Civil society groups, scientists & academics, a majority of UN Member States, and a wide variety of business and industry voices are now calling for the negotiation of a strong new international agreement to address the plastics crisis.
The fifth session of the United Nations Environment Assembly (UNEA5.2) — happening from February 28th to March 4th, 2022 in Nairobi, Kenya — is the time to build on this momentum. Governments must agree to mandate an ambitious new global agreement, with specific legally-binding provisions and obligations to prevent and remediate pollution from plastic and its toxic impacts.
Civil society groups are joining forces to demand such an instrument and call for the inclusion of measures along the entire life cycle of plastics, from the extraction of feedstocks and production to transport, use, disposal, and remediation. This process must be predicated on a just and robust system for ensuring stakeholder participation and meaningful implementation at all levels under a human rights-based approach.
Levels of plastic production, consumption and use are hugely damaging. Reuse measures will enable their reduction, writes Lauren Weir, Ocean Campaigner at the Environmental Investigation Agency.
The #WeChooseReuse campaign, the objective being to replace single-use plastic with reusable systems and products, has many different facets. Whether that be consumer choice at the individual level, different business refill systems and deposit return schemes to policy facilitating this transition at scale. But all amount to one objective: the clear reason for this campaign being that levels of plastic production, consumption and use are hugely damaging, and these measures will enable their reduction.
In tandem we are also calling on Europe to responsibly manage the treatment of its plastic waste, including through banning shipment of extra-EU plastic waste exports[1] – an irresponsible practice under the guise of recycling that in fact creates immeasurable harm to society, health and the environment[2]. This is felt particularly in countries in the Global South, who are the major recipients of this EU waste destined for “recycling”, despite having infrastructure that is overwhelmed resulting in European plastic waste that should be recycled being incinerated, landfilled or illegally dumped.
“Waste colonialism is an environmental justice issue, Europe is dumping its plastic waste onto others whilst touting itself as an environmental leader.”
A recent Greenpeace investigation helped document this occurring at scale in Turkey, finding UK plastic waste[3] and German plastic waste[4] destined for recycling illegally dumped. In 2020 alone they legally exported 210,000 and 136,000 tonnes of plastic waste to Turkey respectively. To better comprehend the scale of the issue, in combination, Europe sends approximately 241 truckloads of plastic waste to Turkey per day[5]. A country where an OECD Environmental Performance Review has reported it sends 90% of its waste to landfill[6].
We have identified a solution in the form of 5 key recommendations:
– Ban on plastic waste exports outside of the European Union – Fully implement the Basel Convention within Europe to increase transparency and allow for prior informed consent – Establish a clear distinction between mechanical recycling and any other kind of recovery for treatment operations, like chemical recycling, to in turn apply the waste hierarchy – Set a European-wide threshold for waste contamination of 0.5% to improve the quality of the recyclate – Ensure publicly accessible access to waste trade data to facilitate monitoring, enforcement and accountability
But how are our #WeChooseReuse campaign and our plastic waste recommendations[7] interlinked? And how will eliminating plastic waste exports facilitate reuse systems and lead to plastic reduction?
If Europe were to take full responsibility of its plastic waste treatment it will reduce the risk of plastic waste leakage[8], enhance circularity, and operate within Europe’s finite recycling sector[9] – facilitating reduction and subsequently paving the way for reuse.
Figure 1 – Exports and shipments, like waste to energy recovery, landfill and incineration, are an externality to a circular economy. Source: https://www.eca.europa.eu/Lists/ECADocuments/RW20_04/RW_Plastic_waste_EN.pdf
Simply put, the export of extra-EU plastic waste is a result of Europe’s overconsumption of plastic and single-use economy. Therefore, Europe needs to export its plastic waste as it fails to handle the majority of it in an environmentally sound manner. For instance:
Energy recovery is the most common method of treating European plastic waste, followed by landfill. Only approximately 30% of all the generated plastic waste is collected for recycling and recycling rates by country vary a lot[10].
In 2018 the EU exported 6.5% of all plastic waste collected, the equivalent of 20.2% of all plastic waste sent to recycling facilities[11].
Between 2012 – 2017 approximately 30% of all plastic packaging waste destined for recycling was exported[12]., the largest volume of plastic product put on the European market that is also principally single-use[13].
For context, in 2019 this amounted to the EU exporting a monthly average of 150,000 tonnes of plastic waste[14] and not all of this waste is actually being recycled.
The European Parliament states that the production and incineration of plastic emits about 400 million tonnes of CO2 globally per annum, a part of which could be avoided through better recycling but principally reduction[15].
Dumping European plastic waste in the form of exports is convenient[16], cheaper and a form of greenwashing[17], as this practice is externalising many costs that Europe is responsible for[18]. Europe uses these exports to then state it’s achieving its often over-estimated recycling objectives[19]. Despite this, it seems the EU target of 50% of all plastic packaging should be recycled by 2025 will still not be met[20].
This is further facilitated by the illegal shipments of plastic waste[21]. The illegal EU waste trade annual revenue ranges between 4 and 15 billion euros (midpoint figure of 9.5 billion)[22]. The illegal shipment of plastic waste, end-of-life vehicles and e-waste are expected to increase[23]. Least transboundary movement of waste facilitates transparency and reduces the risk of illegal shipments[24].
Europe has been able to continue consuming high levels of (principally single use) plastic because it knows it can export the problem of its treatment elsewhere, either through currently legal channels or unaccounted illegal shipments. By stopping exports, and accounting for European recycling targets, current recycling capacity and the Commission’s acknowledgement of the need of incineration moratoriums[25], Europe is in turn acknowledging the need for and would need to enact a further absolute reduction in plastic consumption. Consequently, by maintaining waste produced, linearity of production to disposal would be somewhat halted, facilitating circularity.
Operations and consumption of products that currently rely on plastic, including in the form of single-use packaging, would continue. In turn providing the opportunity and demand for reuse and refill to be adopted at scale – the only viable replacement to our current throwaway culture. The subsequent necessity to find an alternative to single use reduces the risk of investing in new reuse/ refill systems which is not without lucrative market opportunities[26].
Like many policy areas, methods and measures are dependent and overlapping. Concurring measures on limiting incineration, reducing the contamination of plastic waste so intra-EU waste trade has better quality recyclate, ensuring eco-design and being wary of the widespread uptake of chemical recycling[27] and biodegradable/ compostable plastics would facilitate success.
Crucially, it is important to note, that neither the methods nor logic outlined above is novel. Bans are common policy measures to heighten the development of a commodity[28] or used to ensure environmental protection[29]. Europe is fully aware of its waste problem and currently has the opportunity to heighten responsible management.[30] In fact, it has already enacted a partial plastic waste trade ban exceeding current international regulations – having banned the export of unsorted plastic waste to non-OECD countries at the beginning of 2021[31].
It must also be noted that a European plastic waste ban would not be occurring in isolation. A number of countries who have historically been receiving this plastic waste have in turn placed import bans themselves as they acknowledge the damage these shipments bring[32]. This was kick-started in 2018 when China[33], as the principle importer of other countries’ plastic waste, put in place an importing ban leaving Europe scrambling to find other destinations for these shipments. The most recent country to place restrictions being Turkey[34].
The ban of extra-EU plastic waste is simply Europe taking an additional step, getting us closer to the tipping point from single-use plastic to reuse existence.
[9] Recycling is necessary but should not be the primary objective, and subsequently drastically enhancing Europe’s recycling ability is a false solution. Plastic can only be recycled a very few number of times (sometimes only once or twice – recyclability rate/ downgrading ultimately depends on plastic type, level of contamination, the nature of the product it is recycled into). Regardless. Polymer breakdown is countered by mixing with virgin plastics. Source: https://www.foodpackagingforum.org/fpf-2016/wp-content/uploads/2015/11/FPF_Dossier08_Plastic-recycling.pdf.
[16] “Half of the plastic collected for recycling is exported to be treated in countries outside the EU. Reasons for the exportation include the lack of capacity, technology or financial resources to treat the waste locally. Previously, a significant share of the exported plastic waste was shipped to China, but with the country’s recent ban on plastic waste imports, it is increasingly urgent to find other solutions.” – European Parliament. Source: https://www.europarl.europa.eu/news/en/headlines/society/20181212STO21610/plastic-waste-and-recycling-in-the-eu-facts-and-figures
[17] “EU operators must receive documentation attesting that the treatment (including recycling) of plastic packaging waste in a third country is done under broadly equivalent standards to those in the EU. Nevertheless, the European Environment Agency notes that treatment in non-EU countries often causes higher environmental pressure in terms of pollution, CO2 emissions and plastic leakage into the environment, than treatment or recycling in the EU. Verification of compliance with EU plastic waste treatment standards in third countries is often insufficient to ensure respect of EU standards. Member State national authorities have no control powers in third countries and extended producer responsibility organisations, which are responsible for plastic packaging waste management, rarely perform on-the-spot checks. This translates into a low assurance relating to recycling outside the EU and significant risk of illegal activities”. Source: https://www.eca.europa.eu/Lists/ECADocuments/RW20_04/RW_Plastic_waste_EN.pdf
[18] Labour rights, poor working conditions, toxicity and leaching through recycling, leakage, residuals, burning dumping and landfill, chemical and microplastic pollution, exacerbating social inequalities to name a few.
[30] Currently Europe is revising a host of waste legislation, including the Batteries Regulation, Waste Framework Directive, RoHS Directive, WEEE Directive, ELV Directive, Packaging and Packaging Waste Directive, Waste Shipment Regulation, POPs Regulation (waste annexes)
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The technical storage or access is necessary for the legitimate purpose of storing preferences that are not requested by the subscriber or user.
Statistics
The technical storage or access that is used exclusively for statistical purposes.The technical storage or access that is used exclusively for anonymous statistical purposes. Without a subpoena, voluntary compliance on the part of your Internet Service Provider, or additional records from a third party, information stored or retrieved for this purpose alone cannot usually be used to identify you.
Marketing
The technical storage or access is required to create user profiles to send advertising, or to track the user on a website or across several websites for similar marketing purposes.
Plastic waste exports can have catastrophic impacts on the environment and human rights, especially the right to a clean, healthy and sustainable environment. Plastic waste ends up polluting water, contaminating air, and harming the health of people already facing poverty and marginalization. This is a terrible environmental injustice!
Last March, 
