#WeChooseReuse: Waste Trade and the importance of moving from single-use plastic to reuse

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:

Rethink Plastic Alliance Waste Shipment Regulation Recommendations (for Plastic Waste)  

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. 

[1] https://www.breakfreefromplastic.org/the-plastic-waste-trade-manifesto/

[2] https://eia-international.org/report/the-uks-trade-in-plastic-waste/

[3] https://www.greenpeace.org.uk/resources/trashed-plastic-report/

[4] https://www.greenpeace.de/zugemuellt

[5] https://www.greenpeace.org/international/press-release/47759/investigation-finds-plastic-from-the-uk-and-germany-illegally-dumped-in-turkey/

[6] https://www.oecd.org/env/country-reviews/Highlights-Turkey-2019-ENGLISH-WEB.pdf

[7] https://rethinkplasticalliance.eu/wp-content/uploads/2021/01/rpa_waste_shipment_regulation_recommendations.pdf

[8] https://wastetradestories.org/

[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

[10] https://www.europarl.europa.eu/news/en/headlines/society/20181212STO21610/plastic-waste-and-recycling-in-the-eu-facts-and-figures

[11] https://www.eca.europa.eu/Lists/ECADocuments/RW20_04/RW_Plastic_waste_EN.pdf

[12] https://www.eca.europa.eu/Lists/ECADocuments/RW20_04/RW_Plastic_waste_EN.pdf

[13] https://www.europarl.europa.eu/news/en/headlines/society/20181212STO21610/plastic-waste-and-recycling-in-the-eu-facts-and-figures

[14] https://www.eea.europa.eu/publications/the-plastic-waste-trade-in

[15] https://www.europarl.europa.eu/news/en/headlines/society/20181212STO21610/plastic-waste-and-recycling-in-the-eu-facts-and-figures

[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.

[19] https://www.plasticsoupfoundation.org/en/2020/10/high-risk-that-europe-will-fail-to-meet-its-recycling-targets/

[20] https://www.plasticsoupfoundation.org/en/2020/10/high-risk-that-europe-will-fail-to-meet-its-recycling-targets/

[21] Recent examples including transhipments via the Netherlands (source: https://www.endsreport.com/article/1687089/exclusive-ea-investigates-illegal-import-plastic-waste-netherlands-industry-questions-recycling-figures) or illegal shipments from Italy to Tunisia (source: https://zerowasteeurope.eu/2021/05/waste-trade-italy-tunisia/#:~:text=In%202020%2C%20Italian%20company%20Sviluppo,with%20little%20chance%20for%20recycling.)

[22] https://op.europa.eu/en/publication-detail/-/publication/ab3534a2-87a0-11eb-ac4c-01aa75ed71a1/language-en

[23] https://op.europa.eu/en/publication-detail/-/publication/ab3534a2-87a0-11eb-ac4c-01aa75ed71a1/language-en

[24] In addition to effective monitoring, enforcement and adequate penalty.

[25] https://resource.co/article/european-commission-warns-incineration-could-hamper-circular-economy-11632

[26] https://www.greenpeace.org/usa/wp-content/uploads/2019/11/Blog-3_the-path-towards-new-product-delivery-models.pdf

[27] https://www.eunomia.co.uk/reports-tools/final-report-chemical-recycling-state-of-play/

[28] https://unctad.org/system/files/non-official-document/suc2017d8_en.pdf

[29] https://www.businessinsider.com/environmental-rules-laws-protections-around-the-world-2019-4?r=US&IR=T#the-european-union-has-committed-to-banning-pesticides-that-are-dangerous-to-bees-4 and https://www.nationalgeographic.com/environment/article/ocean-plastic-pollution-solutions

[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)

[31] https://ec.europa.eu/environment/news/plastic-waste-shipments-new-eu-rules-importing-and-exporting-plastic-waste-2020-12-22_en

[32] Bangladesh, Malaysia, Vietnam, Hong Kong, South Korea for instance all have or are looking at restricting imports.

[33] https://advances.sciencemag.org/content/4/6/eaat0131

[34] Ban on HDPE, LDPE imports May 2021 (Source: https://www.resmigazete.gov.tr/eskiler/2021/05/20210518-10.htm) and change of import rules in March 2021 and December 2020 (Source: https://docs.google.com/document/d/1aBExN7txopbWeEQbt9KXz05yWaTkRnNIZwDTM1r5wj0/edit and https://docs.google.com/document/d/19_WM0XYORz_5qavLgdflomo8ZErnXn6yFCCVZITxcf4/edit)

The EU Climate Agenda’s major oversight: the link between the petrochemical industry and plastic production

By Natasha Naayem

In our series of virtual panels on Writing the New Story of Plastic, we spoke of the fact that solutions to our plastic crisis have focused for too long on managing end-of-life — where our plastics end up and how we dispose of them once they’re considered waste — and the importance of considering the entire lifecycle of plastic. A significant contributor to our climate crisis and plastic pollution crisis is the very beginning of this lifecycle: the upstream production of plastic. 

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Plastics are petrol 

The creation of plastic begins with the extraction and processing of fossil fuels, practices responsible for significant greenhouse gas emissions including methane, whose global warming potential is at least 86 times that of CO2 over a 20-year period. While over 99% of plastics are produced from chemicals derived from fossil fuels, the association between fossil fuel extraction and plastic production has slipped from public attention, in large part because the climate impacts of greenhouse gas emissions are more difficult to grasp and less visceral than images of plastic litter flooding our oceans and killing marine wildlife. Yet not only does virtually all plastic come from fossil fuels, the petrochemical industry and the plastics industry are vertically integrated, meaning their prosperity relies on each other. This relationship describes a plastic industrial complex that has flown under the radar of EU policy for too long. 

Today, plastics account for 60% of oil demand. As the world relies less on oil and gas and prices for these materials plummet, the petrochemical industry—the largest consumer of oil and gas globally—is hedging its bets on plastics, with plans to double production capacity in the next 20 years. Yet public pressure on plastics is unlikely to yield the kind of demand to match the industry’s intended supply. In addition to the ecological problem of the upstream of plastic production, this gap has the potential to create an even greater economic problem than the one we already face—resulting from the crucial blind spot EU policy and legislation has on this sector, despite the EU’s plan to decarbonise its economy through policy like the European Green Deal.

An industry polluting with impunity 

As things stand, plastics impose a massive untaxed externality on society. “Externalities are a real cost, and people pay for them with their lives and with their livelihoods,” says panelist Kingsmill Bond, Energy Strategist at Carbon Tracker. The problem is that the ones paying these costs are not the ones pocketing the cash. Carbon Tracker’s recent report reveals that plastics cost taxpayers 1,000 USD per tonne produced, which amounts to 350 billion dollars of taxpayer money a year. While the principle that polluters should pay these externalities is present in European law, this principle is far from respected, particularly when it comes to industrial decarbonisation. Industries like the petrochemical industry have not reduced their emissions at all since 2012, despite the EU’s climate goals and our ongoing climate crisis.

Even with the EU Emissions Trading System (ETS) in place, the EU’s key tool for reducing greenhouse gas emissions, more than 90% of all the carbon pollution from these sectors has no price tag. The massive handout of free emissions allowances under the ETS—which represents 6.3 billion tons of CO2 over the next ten years—is “a hidden scandal of European climate policy making,” says panelist Sam Van Den Plas of Carbon Market Watch. It requires immediate attention. This “free” handout of carbon emissions represents 165 billion euros over the next ten years, a cost that will fall to European citizens instead of the industries who profit as a result of their production.

Solutions and EU policy

Internalising these externalities—making producers pay for the cost of their pollution—seems like a simple enough solution. Yet the reason the petrochemical industry has gotten away with such shocking impunity is because they’ve incorrectly convinced policy makers that putting a carbon price on their pollution will drive industry outside of Europe and only further pollute elsewhere. Another straight-forward seeming solution is to curtail the demand for plastics, which will curtail the demand for oil and phase out its extraction and processing. While our society is waking up to the negative effects of plastics, and industries across the board are turning away from them in their supply chain, the plastic industrial complex is wilfully blind to this trajectory. With plans to flood the market in oversupply, the discrepancy between their planned and likely growth is projected to create 400 billion dollars in stranded assets. If the EU doesn’t wake up to the flaws in their legislation and the hidden CO2 costs of plastics stemming from upstream production, there is a real risk that public funding will go towards saving this industry rather than towards implementing sound strategies. 

With the Green Deal, the goal of Carbon Neutrality and the increase of emissions target to at least 55% reduction by 2030, the European Commission is taking steps in the right direction, but these are nowhere near sufficient. Today, the EU has many good strategies in place, but these strategies have yet to be enacted through equally good legislation. For panelist Martin Hojsik, member of the European Parliament at Group Renew Europe, the solution is in a circular economy: “We need to create an environment that prohibits industries from going into linear systems and puts investments towards creating circular systems.” All plastics should be part of a closed loop system, which would avoid the production of virgin plastics and the creation of waste that ends up in landfill and incinerators. Creating these kinds of new capacities for plastic reduction relies on public money, which is why there is currently a big push to use COVID-19 recovery funds towards these kinds of initiatives. 

Carbon pricing and a system like the ETS are no silver bullets to our climate and pollution crisis. In addition to carving out a path towards a circular economy, the EU needs multiple instruments working in unison towards this goal. Instruments such as the Industrial Emissions Directive, the Circular Economy Agenda, the Methane Strategy, and the Carbon Border Adjustment have the potential to be harmonised towards the creation of a climate neutral economy, in which all free emission allowances are phased out, and pollution from plastics is tackled from both ends of the spectrum.

Will the EU Methane Regulation ignore the climate polluter role of the petrochemical industry?

Fossil gas has long been touted as being the cleanest of fossil fuels as well as a needed “bridge technology”. Plastics on the other hand have been hailed an integral part of modern society that might even deliver climate benefits due to their light weight. Andy Gheorghiu takes a closer look at the link between gas, climate and plastics and argues for an EU Methane Regulation that applies strict rules for both the fossil energy and the petrochemical sector.

Claims of gas as a “bridging technology” for its quality as the “cleanest fossil fuel” as well as “climate-friendly” plastics are far from being accurate or even factual.

The problem starts with the wording as such. Gas can’t be a “technology”. It is either a fossil fuel or a fossil feedstock, including for plastic production, and as such it is neither clean nor climate friendly. And there is also growing evidence and awareness that plastic production and consumption contributes significantly to global warming.

So, let us get some things clear here. Fossil gas consists primarily of methane. When fossil methane is released into the atmosphere, it is much more harmful to the climate than CO2 (up to 87 times more in the first 20 years, falling to 36 times more over 100 years). According to calculations, fracked shale-gas have been underestimated for a long time and may have contributed more than half of all of the increased emissions from fossil fuels globally and approximately one-third of the total increased emissions from all sources globally over the past decade. Satellite images show that methane emissions from other fossil fuel sources are also significant and relevant.

Fossil gas contributes significantly to global warming. At the same time, continued investments into gas infrastructure and petrochemicals are the main roadblocks for getting into full speed concerning the existential energy transition we need to accomplish rather sooner than later.

Two of the first scientists who addressed the problematic methane issue a decade ago were Robert Howarth and Anthony Ingraffea, Cornell University, Ithaca, NY. Calls for bans on fracking and proper measurements of methane leakages followed. However, it took almost ten years until the EU Commission was finally willing to address the problem. On October 14, 2020, the Commission adopted its Methane Strategy as part of the European Green Deal.

However, there is a key sector which the Strategy fails to identify or highlight: the petrochemical and plastic industry. According to the International Energy Agency, petrochemicals are about to rapidly becoming the largest driver of global oil (including so-called “wet gas” or ethane) consumption – ahead of trucks, aviation and shipping. Today, the chemical sector is already the largest industrial consumer of fossil fuels, accounting for 14% of global oil and 8% of gas primary demand.

In 2019, the Center for International Environmental Law (CIEL), published a report that outlined the full plastic lifecycle emissions (including the extraction of fossil fuels, production, transport, consumption and disposal) of global plastic production. The results – based on conservative approaches – are striking: we are on a pathway where plastics alone will generate 56 gigatons of CO2 by 2050 which corresponds to 10 – 13 percent of the global carbon budget we have left to stay within a 1.5 ° global warming scenario.

Given that oil and gas extraction, transport, production and processing, including production of petrochemicals and plastic) contribute significantly to methane emissions, the EU Methane Regulation must address methane in the petrochemical and plastic production sector along the full supply chain. Covering the full supply chain is in particular important with regard to the increasing imports of US fracked gas for plastic production in Europe and the fact that most of the fossil fuels consumed in the EU are imported – with 75-90% of the methane emissions being emitted before reaching the EU’s borders.

The following policy options are ways to reduce methane emissions – an imperative from both a climate change and plastic pollution point of view: 

  • constant independent monitoring and measuring to a) measure methane leakages and b) repair the leaks;
  • a ban on routine venting and flaring of methane during oil and gas extraction but also within the production of petrochemicals and plastics;
  • cover the full supply chain of fossil fuels entering the EU market (including as an energy source or feedstock for petrochemicals and plastic production) and extend obligations to companies importing fossil energy into the EU/companies exporting fossil energy to the EU
  • fine non-compliance significantly;
  • ban imports of hydrocarbons (as an energy source or feedstock) which for which compliance with the overall requirements of the EU Methane Regulation cannot be credibly demonstrated.

A public consultation was just held about new rules on methane and the European Commission is expected to propose its EU Methane Regulation at the end of 2021. You can find Rethink Plastic’s submission to the public consultation here.

The inherent problem with the global plastic waste trade

Four thousand kilometres away from the UK, panelist Dr. Sedat Gündoğdu, a microplastics researcher at Çukurova University in Turkey, splays out shiny crinkled packaging he picked up in an illegal dumping site and holds it up to his computer’s camera. For those attending our virtual Global Plastic Waste Trade panel on the other side of their screens, the provenance of this packaging isn’t hard to decode: a large British flag is boldly printed at the top of what was once a bag of crisps. Gündoğdu pulls up item after item, all from different parts of Europe. Most of what Gündoğdu pulls up are items that would have been diligently placed in recycling bins back home, and yet they are part of the 11.4 million tons of waste EU countries exported to Turkey in 2019 alone.

Turkey itself is the third largest producer of waste in Europe (after France and Germany) but can only officially manage 10% of its municipal waste, according to Gündoğdu. Over the last couple of years, however, the amount of waste Turkey has imported has increased ten- to twentyfold. This surge is a result of the National Sword policy that China enacted in 2018, closing its borders to foreign plastic waste imports in order to safeguard its territory from foreign plastic pollution. The fallout threw the global recycling industry into chaos, with the burden of waste and its associated health and environmental impacts diverted to other countries, many of them in Southeast Asia. Alarming photos of these nations awash in plastic – trash originating from much wealthier countries – perpetuated a narrative that these nations were irresponsibly handling this waste, dumping plastic and leaking microplastics into our oceans. When we consider that only nine percent of all plastic produced since 1950 has ever been recycled, this narrative quickly falls apart. In 2017 alone, the EU exported 2.55 million tonnes of plastic waste outside of its territory, under the pretext of recycling. Rather than operating as a keystone element to a circular economy, the global plastic waste trade has acted as a means for countries in the Global North to externalise the true costs of proper waste management to weaker economies, with huge social justice and environmental implications.

Gündoğdu jokes that an unintended ‘upside’ of the international waste trade is increased brand awareness of popular European consumer goods. The trash Gündoğdu picked up wasn’t difficult to find: illegal dumping and burning sites are found in abundance near people’s homes in the residential suburbs of Turkey. The downsides, however, are many and dire. The smoke caused by burning plastic is carried by the wind and felt even in the city. The toxic smell is so bad that residents are forced to keep their windows closed. Importers of plastic waste also use the irrigation canals that pass through the industrial recycling zone as dumping sites. These canals lead to one of the most important lagoon systems in the mediterranean sea, the Akyatan Lagoon, home to flamingoes and a breeding site for endangered green sea turtles. In addition to illegal dumping and burning, hundreds of waste treatment facilities have cropped up in the last three years, most of them employing refugees, asylum seekers and other members of disadvantaged communities under terrible working conditions. There is no proper monitoring of the health conditions of these facilities, no regulations in place. As plastic waste importing has boomed, so have the number of fires within these facilities, with over 100 reported in the last year.

In May 2019, about a year after China’s National Sword policy, amendments were made to the Basel Convention (the international treaty designed to control the movement and disposal of transboundary hazardous waste) to better control plastic waste. Unanimous agreement among the 180 member countries in record time affirmed the international plastic waste trade as a pressing concern. The amendments came into effect in January 2021: plastic waste that is difficult-to-recycle will now need to be clearly consented before being imported into receiving countries. This consent mechanism, however, evades an outright ban of plastic waste flows from countries in Europe to those in the Global South and does not apply to countries like Turkey within the OECD. Nor does it address the uneven economic playing field that leaves certain countries that lack the proper infrastructure and capacity to appropriately manage waste vulnerable to exploitation. A bilateral consent mechanism is a step in the right direction, but is far from providing the kind of oversight this crisis requires, and still leaves room for what has largely underpinned the global plastic waste trade: illegal trafficking

Characterised by a lack of transparency, traceability and accountability, the plastic waste trade in particular is notoriously opaque,” says Tim Grabiel of the Environmental Investigation Agency. He describes it as a “black box” that has been historically under-regulated, in large part because the waste traders and brokers involved in moving waste from one place to another are thought of as part of the logistical supply chain as opposed to critical actors in the fate of plastic waste. This fate, however, is well documented: plastic waste is often dumped, burned, or stockpiled in warehouses secured by brokers themselves and abandoned. What remains obscure are the many processes that organised criminals, corrupt officials and unscrupulous traders engage in up until the waste lands in a non-EU country. One government official estimates that 30% of organised crime in their member state is involved in the waste trade.

With the European Waste Shipment Regulation coming under review over the next few months, the European Union is presented with the opportunity to address the regulatory oversight that has allowed for a thriving black market of plastic waste in a multibillion-dollar global recycling industry that perpetuates disastrous  environmental racism. As the wealthiest group of nations in the world, the EU has a responsibility to shoulder the costs of its own waste and become self-sufficient in order to limit plastic waste’s transboundary movement. An outright ban of plastic waste exportation to countries where the EU doesn’t have the means or jurisdiction to implement sound and frequent monitoring is a necessary measure. As is a rigorous standardised and streamlined electronic reporting system in order to ensure accessibility and transparency along the plastic waste supply chain. 

Turkey, Malaysia, Thailand and other countries that became ‘destinations’ for plastic waste once the National Sword policy came into effect have since enacted bans and restrictions of their own, but enforcing these bans remains a challenge. Turkey, for example, imposed a regulation in 2019 stating that licensed recyclers can only import 80% of their facility’s recycling capacity, a regulation rendered meaningless as companies’ reported capacities are largely misrepresented. Exports in the European Union have since gone down from 2.55 million tonnes in 2017 to 1.72 million tonnes in 2019. Where exactly the surplus of waste went is unclear, but intra-EU flows of waste have naturally increased, and unsustainable management of plastic waste has already been documented in certain Eastern European countries. This suggests a similar pattern of wealthier Western European countries externalising true costs to poorer nations. In order to prevent the consequences of mismanaged plastic waste within EU borders, full implementation of the Basel Convention within the EU is necessary, along with tighter restrictions that should be laid out in amendments to the Waste Shipment Regulation. These restrictions include establishing a clear preference for  mechanical recycling over other forms of recovery operations that have higher environmental impacts, and a European-wide threshold for plastic waste contamination of 0.5%.

Gaël De Rotalier, team leader of the European Commission, sees the EU’s shared rules for the management of plastic waste all across its member states as a good foundation for the creation of a circular economy in Europe. Along with addressing how tighter enforcement, inspections, and coordinated regulatory oversight can be implemented through the Waste Shipment Regulation, the European Commission will be looking at how these regulations work in concert with the EU Green Deal and the Circular Economy Action Plan. Important aspects of packaging – one of the most significant sources of plastic waste – such as its design and prevalence will be addressed, for example.  

As Sirine Rached, moderator of our panel and global policy advocate at GAIA, points out: our problems with handling plastic waste are necessarily tied to our volumes of plastic production. As these volumes are expected to explode in the coming years, so are the societal and environmental consequences that come with the challenges of managing plastic waste. With the ongoing fight against a potential new plastic production facility in Antwerp, it is clear that many challenges still lie ahead and that the need for amendments to the Waste Shipment Regulation is as pressing as ever. 

By Natasha Naayem for the Rethink Plastic alliance 

Read our recommendations for the Revision of the Waste Shipment Regulation.

It’s time for EU decision-makers to severely restrict the intentional use of microplastics

A proportion of these microplastics are escaping into our environment after having been intentionally produced, supplied and used in products like cosmetics, detergents, paints, pesticides and even sports fields

These tiny synthetic polymers are harmful to biodiversity as they resist biodegradation – breaking down in nature – and block the digestive tracts of aquatic creatures, turtles and birds. Many scientists believe them to be harmful to human health.

An EU-wide action putting an end to this rising pollution is needed now! 

So what is being done to tackle intentionally-added microplastics?

In line with the EU Plastics Strategy (2018), the European Chemicals Agency (ECHA) was asked to make a proposal for restricting the use of intentionally-added microplastics under the Regulation on the Registration, Evaluation and Authorisation of Chemicals (REACH). This proposal is to be given to the European Commission and Member States which is why it needs to be as ambitious as possible. This legislation to restrict intentionally-added microplastics will need to stand up to strong industry pressure and lobbying which will attempt to delay and weaken its effectiveness. 

In November 2020, in advance of ECHA sending their final proposal to the European Commission and Member States we outlined key recommendations requited to fix their draft as we urged them to strengthen microplastics ban. You can read our Position Paper or Summary Paper (please note the more up-to-date version is below).

Since then, on February 23rd, ECHA handed over their proposals to the European Commission. The final draft has major loopholes remaining that could favour unproven biodegradable plastics and give some sectors up to 8 years to take action. We shared our thoughts in a press release alongside a letter to the European Commission, and updated versions of our position paper and summary paper:


You can also find translations of our position paper in the following languages:







Relevant News Stories: 

The following organisations support the position taken in our position paper:

Calls to tackle intentionally-added microplastics on twitter:

The Movement Towards a Global Treaty on Plastic

The complexity of our plastic crisis stems from the fact that plastic is part of a globally connected value chain that has often been approached through regional waste management programs, which only tackle plastic at the end-of-life, when what is needed is a sweeping transboundary approach that tackles plastic at every stage of its lifecycle.

When the United Nations Environment Assembly (UNEA) first came together in 2014 in defense of nature, it recognised marine plastic debris and microplastics as an issue that demanded comprehensive action. This week, UNEA gathers virtually for the first installment of its 5th session (UNEA-5.1), gearing up to UNEA-5.2 this time next year, when Member States will gather in Nairobi, Kenya, to open discussions for a coordinated global response with a potential binding mechanism towards plastic pollution—which could lead to a much needed global treaty. In anticipation of UNEA-5.1, the Break Free From Plastic movement and the Rethink Plastic alliance invited speakers Giulia Carlini (Center for International Environmental Law), Hugo-Maria Schally (European Commission) and Christian Sekomo (University of Rwanda), to discuss at a virtual conference the need for this global treaty, the challenges it poses, and key aspects of the four pillars of action that would provide its proposed structural and conceptual framework. The conference was moderated by Christina Dixon of the Environmental Investigation Agency, and the insights gathered from our speakers have formed the basis for this article. 

Why a global treaty on plastic is important 

With so much existing legislation on plastic today, we might wonder why a global treaty is important and what it can accomplish that existing legislation hasn’t been able to. In looking to understand the source of the problem, member states of UNEA asked the United Nations Environmental Programme (UNEP) to take measure of existing legal instruments at the regional and international level, and assess whether they were effective in tackling marine plastic pollution and microplastics. Their conclusion, which corroborates other studies done on the subject, was that they are fragmented and inadequate. 

The issue is that current instruments only cover bits and pieces of the lifecycle plastic. We have agreements in place that look at marine plastics, for example, or that look at chemical waste, but there is no legislation that is holistic and tackles the full lifecycle, which includes production and consumption – the source of the problem. Dealing at the level of waste management will never be an effective solution to an issue that is created through the design of products and materials, and the way they are distributed and consumed – before we even get to the problematic way they are discarded at the end-of-life. The case for international governance becomes evident simply by looking at the level of the EU, where we have 27 different nation markets operating within one single internal market. When the European Commission looked into what a European plastic strategy would look like, it was clear that this would require solutions that apply both along the value chain and the supply chain, in addition to a supportive environmental regulatory system that involves governments at all levels. And still, this would never be enough: what became equally evident was that government instruments in Europe alone would never suffice to combat our plastic crisis, as partners outside of the EU would always be subject to some kind of pressure due to international trade in materials and substances. 

What can a global treaty on plastic look like? 

While global governance with binding legislation for plastic may seem like a tall order, it is certainly not out of the ordinary. There is precedent: we have some degree of global governance when it comes to dealing with toxic waste, for example, and ship-born plastic pollution. What’s needed today is legislation with considerable focus on the upstream elements of the plastic lifecycle – with the conception, design and production of materials – which is conspicuously lacking in our fight against plastic pollution. Member States of UNEA have identified four broad categories of necessary action, key pillars that seek to address our current legislative gaps and that can lead to effective change: 

  • 1 Monitoring and reporting 

As the market for plastic is transboundary, countries all over the world would benefit, for example, from knowing the material composition of the plastic they receive in order to make better decisions about what to do with it. This touches a key component of this pillar: standardising monitoring and reporting of elements that pertain to a circular economy – not just the material composition of plastic, but how its designed, used, consumed, etc. We can look to Rwanda for a prime example of the limitations posed by a lack of global reporting standards in this regard. The mosquito nets Rwanda imports from the US come in plastic packaging, the chemical composition of which are not disclosed. Even though the recycling plant in Rwanda has attempted to contact the manufacturers in the US, they have been unsuccessful in getting full transparency. Without this knowledge, Rwanda is unable to recycle this plastic packaging, which hinders the development of a circular economy. The other key component is standardising the monitoring and reporting on the presence of plastic pollution and its environmental impact

  • 2 Plastic pollution prevention  

Preventing discharge and creating a safe circular economy for plastics is the primary focus of this pillar. In order to prevent plastic discharge, this pillar proposes plans that touch on infrastructure investments, market restrictions, and remediation of legacy plastic pollution, amongst others. 

Beyond plastic waste and microplastics, we must also remember that there are often additives in plastics – to make them hard, or soft, or colourful – that can be hazardous and come at a cost to our health. In addition to interfering with the development of a safe circular economy, additives are endocrine disrupting chemicals linked to cancers, chronic diseases, and weakened immune systems. There is very little now that addresses this issue at international level. We have the Stockholm Convention on persistent organic pollutants, which covers some of the world’s worst chemicals, but this is just a very small part of all existing additives. When it comes to plastic pollution prevention in terms of a global treaty, there is discussion of having voluntary industry standards, but an ideal approach would be to not let substances that aren’t proven safe enter the market in the first place. It’s important that this happen in the design phase of products, and especially with consumer products. “No data, no market,” is the ideal philosophy in the EU.

Another key element of this pillar is putting measures in place that cap and reduce plastic production. It’s common to get a lot of pushback from companies when they hear about this kind of regulation, because there’s a myth that regulation is an obstacle that hampers production. But when the EU put in place chemical regulation, for example, what ensued was an increase in the number of patents for safer alternatives/inventions. 

  • 3 Technical and financial support

While rules and regulations must be put in place, it is imperative that technical support be available to policy makers and financial support be available to developing countries. Technical assistance, capacity building, policy development, and scientific and socio-economic assessments are elements that this pillar defines as necessary in order to help define and drive the financial activities for developing countries. For example, in order to reduce microplastic pollution from textiles, countries might commit to requiring new washing machines to contain filters that collect fibers during the washing cycle. This would, in turn, compel washing-machine manufacturers to redesign their washing machines to include new components and upgrade manufacturing facilities. This redesign and upgrade could be considered an incremental cost of compliance for developing countries. 

  • 4 Coordination 

This pillar ensures the coherence and coordination of existing international and regional agreements in order to avoid redundancies and maximise efficiency. While coordination with international and regional instruments is paramount, the challenge is also recognising that separate bodies have their own mandates and competencies. In the context of Africa, for example, certain countries are jumping on plastic bans while others are reluctant to do so because they have sectors of their economy that rely more heavily on plastic. 

How can we get corporations on board?

Today, approximately 275 million tonnes of plastic waste is produced annually and virgin plastic production is only projected to increase in the coming years. What’s important to consider in this light is a global treaty that provides a win-win scenario, in which binding rules help everybody profit: we need to look for an agreement that will preserve a circular and sustainable use of plastic for decades to come and not make a whole industry go bankrupt. In the fight against plastic, we sometimes forget that plastic can be incredibly useful when it’s designed and conceived in the right way. 

Ultimately, the market is the master, and policy needs to work on the side of demand in order to curb supply. What we call unsustainable plastic today (such as any single-use plastic) needs to be deemed unnecessary plastic. Rather than telling industries that they can not produce plastic (which in a market economy never works), we need to be saying that there is no market for certain plastics, such as those that can not be safely reused. There are many producers today who understand this and are willing to jump on board

Where do we stand today?

With UNEA-5.1 underway, we have an opportunity to send an important and clear political message, to push for a global treaty on plastic that will enable consumers, economic decision makers and policy makers to make the right choices. With access to the right technology and capacities, a global treaty on plastic should be an enabling, empowering instrument that allows countries and jurisdictions to make their choices and implement them in an effective way. Due to the current COVID-19 pandemic, the second installment of UNEA’s 5th session (UNEA-5.2) is happening a year later than expected so as to allow the conference to be held in person. Rather than seeing this delay as an impediment to momentum, we have a unique opportunity to have more interaction between regions and countries than previously envisaged, mature the ideas we want to bring forward, build progressive partnerships, and present a strong unified message when the assembly reconvenes in 2022. What we are aiming to reach at UNEA-5.2 is the mandate to form an Intergovernmental Negotiating Committee for a new global agreement. Given the speed at which interested parties are mobilising and moving discussions along, we can feel confident about making a global treaty on plastic a reality in the not too distant future.

By Natasha Naayem for the Rethink Plastic alliance

Precautionary approach needed on biodegradable plastics, says Rethink Plastic alliance

In the past two decades, “bioplastics” have increasingly been promoted as a solution to many of the challenges caused by conventional plastics. In this context, the 2018 EU Plastics Strategy itself had set out a cautious approach, applauded by the Rethink Plastic alliance, for the use of biodegradable plastics as it identified a number of concerning challenges associated with their uptake: “It is important to ensure that consumers are provided with clear and correct information, and to make sure that biodegradable plastics are not put forward as a solution to littering”. An approach that was confirmed in the Directive on single use plastics and fishing gear which makes no distinction between conventional, non-biodegradable plastics and biodegradable plastics, capturing them all in its ambition to phase out the most polluting single-use plastics.

Reacting to the release of this new report, Gaëlle Haut, EU Affairs Project Manager at Surfrider Foundation Europe said  “Biodegradable plastics are single use and still plastics. Far from being the ‘silver bullet’, they bring with them a series of issues, misrepresentations, greenwashing and hidden impacts, notably on marine life and habitats. We are very pleased to see this recognised in the SAPEA report in addition to the recommendation that biodegradable plastics should be limited to specific uses for which reduction, reuse and recycling are not possible. Yet, we’re strongly concerned the report outlines bioplastics as being possibly a solution to plastic pollution and states these plastics do not harm the environment, a statement we clearly object to”.

The market pull effect of openly supporting the wide development of biodegradability testing and standards should not be underestimated. This can lead to the dramatic increase in products designed for biodegradation in the open environment at the global level.” added Ioana Popescu, Senior Programme Manager at ECOS. “This not only sends the message that it is ok to throw a plastic product into the natural environment, it also bears considerable risk of impacting natural habitats as biodegradation times in the open environment vary and can take up to 2 years in ideal laboratory conditions.”

“It is currently too easy for bioplastic manufacturers to push their products towards consumers through the use of misleading labels on single-use products such as “compostable” cutlery, beverage cups and food containers. This is against the spirit of the recent single-use plastic Directive and should stop for greener alternatives to be promoted, such as durable and reusable products.” added Frédérique Mongodin, Senior Marine Litter Policy Officer at Seas At Risk.

On biodegradable and bio-based plastics, the Rethink Plastic alliance believes upcoming initiatives on sustainable products, green claims, on the use of bio-based plastics, and biodegradable or compostable plastics and the revision of the packaging and packaging waste directive provide an opportunity to:

1. Prioritise material reduction and reuse over substitution of one single-use item with another, for example by setting sectoral reuse targets.

2. Set strong criteria and conditions for the sourcing and use of bio-based and biodegradable plastics fully acknowledging and taking into account all their externalities.

3. Harmonise the definitions and strengthen consumer protection against greenwashing on plastics: set clear definitions of bio-based, biodegradable and compostable plastics, and regulate the use of marketing green claims such as “bioplastics”, “biodegradable”, “compostable” and any qualitative claims linked to the environment, including on feedstock source, biodegradability and compostability through a pre-approval process.

4. Introduce clear and ambitious requirements into EU standards on industrial compostability, home compostability and biodegradability for example that reflect real-life conditions and do not adversely impact natural ecosystems.

For more information, please read our full infographic on bioplastics.


[1] Science Advice for Policy by European Academies (SAPEA). (2020). Evidence Review Report. Biodegradability of plastics in the open environment. Berlin: SAPEA. doi:10.26356/biodegradabilityplastics

[2] Group of Chief Scientific Advisors. Scientific Advice Mechanism (2020). Scientific Opinion. Biodegradability of plastics in the open environment. 

[3] Rethink Plastic (November 2020). Plastic Fake Out: Falling into the trap of Bioplastics.

[4] Rethink Plastic (July 2018). Why bioplastics won’t solve the plastic crisis.

The EU must take action on plastic pellet pollution

Up to 160 000 tonnes of pellets are lost every year in Europe alone. Plastic pellets, also called nurdles or mermaid tears, are a raw material used in the manufacturing of plastic items. They are the virgin plastic that is melted and molded into plastic items. Pellets end up in nature when handled irresponsibly by plastic producers, transporters, recyclers or converters.

As part of the EU’s commitments under the new Circular Economy Action Plan, and the Commissions commitments to come up with a zero-pollution strategy next year, we are calling on the European Commission to adopt ambitious legal measures to tackle pellet pollution once and for all.

To date, pellet pollution has not been regulated by EU decision makers, and the voluntary industry initiative (Operation Clean Sweep) has proven to be unable to stop the pollution despite nearly 30 years of volunteer action.

For more information, you can read the full report by Surfrider Foundation Europe or check the Summary Paper. you can also view the Press Release.

Get more information on pellets:

Current discussions on European Commission guidelines could jeopardise EU single-use plastic bans!

In 2019, the European Union (EU) adopted landmark legislation on single-use plastics, requiring EU countries to ban certain single-use plastics, reduce the consumption of others and put in place extended producer responsibility schemes. This was a major step in moving away from single-use plastics and reducing plastic pollution.


The European Commission is now developing guidelines to support the implementation of the new rules by EU countries, notably by specifying in greater detail which single-use plastic products are covered by the Directive. While technical, these guidelines are very important, as they will partly determine how much change the Directive will yield.


However, the current discussions, underway in Brussels, are not going well. The current draft of the  European Commission guidelines on single-use products, (that has been leaked to the press), allows for dangerous exemptions, which would undermine the very objective of the Directive.


Firstly, the current draft of the guidelines defines plastic in such a way that certain single-use plastic products, made of materials such as viscose and cellophane would no longer fall under the Directive. Certain types of wipes and menstrual products would be excluded, even though they have similar impacts on the environment as other types of wipes and menstrual products that are covered by the legislation. Single-use plastic straws made of cellophane would still be allowed on the market, even though the Directive clearly bans single-use plastic straws. With the current wording in the draft, the ban would be rendered completely ineffective.


Secondly, the draft guidelines use “single-serve vs multi-serve” criteria in order to exclude certain types of packaging and food containers. For example, this distinction would lead to the exclusion of all crisp packets that are not considered to be “single-portion” or “single-serve.” However, most of the crisp formats currently sold on the shelves are not considered “single-serve,” which would therefore  lead to the exclusion of most crisp packets from being covered by the legislation. Using the “multiserve” criteria to exclude certain single-use plastic products opens the door to wide exemptions, with companies simply changing the labelling of their product to 2 portions or 2 servings in order to bypass the Directive.


The current draft of the guidelines would completely undermine the Directive and risk making some of the new rules completely useless. The European Commission and EU countries need to change the course of these discussions in order to uphold the ambitious objectives of the Directive and answer the public’s demand to move away from single-use plastics and end plastic pollution.


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