Waste : between illegal flows and local recycling, waste processing is undergoing radical change

Ophélie Cuvillard, Antoine Gillod, 2022

Association Climate Chance (Climate Chance)

China’s 2018 ban on plastic waste imports - followed by some neighbouring countries - has highlighted the weakness of local recycling capacity in industrialised waste-exporting countries. The urgent relocation of the recycling of millions of tonnes of plastics has also highlighted the precarious conditions of their recycling practices. In parallel with this process, and within the framework of the Basel Convention, the naming and control of waste is an important issue in preventing the circumvention of international rules and bilateral agreements. Illegal waste trafficking is one of the most organised networks of environmental crime, and while exports of plastic waste to South-East Asian countries have officially decreased, illegal shipments have sometimes replaced formerly legal shipments, leading to unofficial and more dangerous recycling practices. Europe has made some progress in recycling polymers, but faces the limits of this type of treatment if it is really to reduce the sector’s emissions and move towards a circular economy, which involves first and foremost preventing their production and reusing resources.

To download : bs2022_fr_dechets_tendance_flux.pdf (640 KiB)

Asian bans divert waste flows to new destinations

Plastic fibres are currently used for packaging, textiles, industrial machinery, electronic and electrical products, and in the transport and construction sectors. Between 1950 and 2015, only 9% of the world’s plastics were recycled each year, with 79% accumulating in landfill sites or being dumped in the environment, ending up in the oceans, and 12% being incinerated. A 2018 study by the OECD re-evaluated the global recycling rate at between 14% and 18%, the incineration rate at 24% and the rate of dumping in landfill sites or in the environment at between 58% and 62%. 72% of the world’s waste produced between 1992 and 2016 was exported to Hong Kong and China, much of it through illegal channels. Parts of Asia began introducing restrictive policies in the early 2000s, culminating in China’s National Sword Policy (NSP), which came into force on 1 January 2018. The NSP bans imports of 24 types of recyclable solid waste: non-industrial plastics, mixed paper, textiles and vanadium slag, a rare metal used in steel metallurgy.

As a result, plastic waste imports fell by 99% and paper imports by more than a third between 2017 and 2018. The main consequence of the Asian bans was the displacement of plastic waste importers, as exporting countries did not have the resources and industrial capacity in place to replace China.

From 2016 to 2018, the South-East Asian region saw an increase in plastic waste imports of 171%, according to a study carried out by the South-East Asian NGO Greenpeace, rising from 836,529 to 2,231,127 tonnes. In other words, in 2018, the region accounted for 27% of global plastic waste imports, compared with 11% in 2017 and 5.38% in 20168. The fact that Western countries (notably Europe and the United States) were unable to export to China led them to turn to South-East Asian countries such as Malaysia, the Philippines, Vietnam and Thailand, before the latter in turn introduced restrictive policies. As these countries have not ratified the Basel Convention, controlling the entry of hazardous waste is more difficult. Agreeing to process plastic waste from Northern countries was seen as an opportunity for non-OECD countries, which could then sell it on after processing. However, due to limited recycling facilities and infrastructure, hazardous or contaminated waste often ended up being thrown away or burnt.

Exports of plastic waste from European countries will fall from 1,583 Mkg in 2020 to 1,135 Mkg in 2021 (2,500 Mkg in 2017), while exports to non-OECD countries will fall by 45% between 2020 (887 Mkg) and 2021 (486 Mkg). The Asian bans have therefore led to a fall in exports to non-OECD countries and a fall in exports in general. With the exception of shipments to Vietnam, which increased, EU waste exports to South East Asian countries decreased in 2021, as did those to Turkey, which has become the main destination for plastic waste exports from EU countries. In general, total exports of plastic waste from the major exporting countries decreased each year between 2017 and 2021 (from 6.75 Mt to 3.75 Mt). The main exporters of waste to non-OECD countries in 2021 were Japan, the United States, the Netherlands, Germany, Australia, Belgium and the United Kingdom, while the main importers were Turkey, Malaysia, Vietnam, Indonesia, India and Thailand. India has changed its « ban » on plastic waste imports from 2019 to « restricted » imports in 2022. As a result of this closure of Asian borders, US exports to Latin America (Ecuador, Mexico, El Salvador, Guatemala and Honduras) almost doubled between 2019 and 2021.

Exports from Europe and North America to Africa are increasing, following the trade flows that already existed for waste electrical and electronic equipment (WEEE). Despite the drastic fall in the import of plastic waste into China, demand for recycled plastic particles is increasing as the world’s major chains step up their commitments to reduce the use of primary plastics. With the tightening of international trade rules, Asian import bans and the lucrative business that this market represents (expected to reach US$50.36 billion by 2022), illegal activities are on the increase.

At the same time, recycling and circular economy initiatives have no choice but to develop in waste-producing countries.

Faced with inadequate recycling and illegal shipments, circularity focuses on the reuse of plastic waste

Recognised as hazardous waste, plastics fuel illegal trafficking Illegal activities involving waste cover a range of activities: transporting waste on black markets, contamination, false declarations of hazardous waste or declaring waste as reusable products. In the latter case, the products are no longer subject to international regulations on trade in waste and can be traded with developing countries. While developing countries depend on reusable products such as certain electronic waste or cars, the majority of these are not functional and may also hide other types of waste.

According to the World Customs Organisation (WCO), this type of action complicates the distinction between legal and illegal waste, creating a vast grey area where it is difficult to enforce international rules.

As waste accumulates, illegal trafficking increases through an underground economy of trade in recycled plastic. One study assessed the extent of this economy by observing the differences between what was reported by the two parties involved in the same trade. On average, exporters of waste declared a value 18.47% higher than importers (the opposite trend to that observed for other types of economic exchange). According to the WCO, illegal flows are particularly high for trade in waste. The WCO launched Operation Demeter IV against illegal waste flows in 2018: of the 199 seizures made, plastic and electronic waste were among the most numerous. Illegal waste flows are reported from Western Europe, in particular from the Adriatic Sea to Turkey and Bulgaria. In December 2021, the ship Cosco Pride, travelling with 37 containers of plastic waste from Germany to Turkey before being exported again to Vietnam, was stopped on its way to Asia, reported by the Greek authorities, following a warning from the Basel Action Network. Flows rarely go from point A to point B, particularly when importing countries receive illegal shipments and then transfer them to other neighbouring countries.

In a report published in August 2020, Interpol analysed emerging criminal trends in the global plastic waste market since the Chinese policy began to be implemented in January 2018. Drawing on data and intelligence from 40 countries, Interpol identifies an increase in practices outside the boundaries of the law: transfers of illegal waste shipments to other destinations, unauthorised dumping, illegal incineration and administrative fraud are all alternative routes opened up in the absence of domestic recycling capacity in countries hitherto dependent on China. In 2020, port and air cargo control units intercepted 630 tonnes of waste. Thirteen of the 24 countries affected by illegal exports were located on the Asian continent. Interpol’s analysis shows that illegal waste routes follow legal routes and, in fact, they also follow their change of destination induced by the rise in restrictive legislation. However, as some South-East Asian countries increase claims against these illegal shipments and put bans in place, the trend is for these illegal shipments to move to non-importing countries, redirecting hazardous waste to more vulnerable countries with less infrastructure to deal with the waste. While this trend has already been observed in South-East Asian countries, we will have to wait a few more years for data on Africa and Latin America, where shipments appear to be heading according to Interpol. In particular, the routes used for the transfer of WEEE in Africa could be used for the transfer of plastic waste.

Some WEEE to Africa is exported under false names. The new French report by the General Council for the Environment and Sustainable Development (CGEDD) concludes that France knows the future of only 20% of its exported waste, due to gaps in existing data. In particular, it points out that a large proportion of WEEE is exported as « second-hand products » rather than « waste », and that the same code covers both products and waste, making it impossible to analyse precise data at a later date. Until October 2021, electronic and electrical waste was not part of the European Union’s customs nomenclature. A two-year survey (2015-2016) by the UN, published in 2018, shows that 77% of imports of electrical and electronic equipment (EEE) came from EU ports, with Germany and the UK each accounting for 20%. Imports are mainly directed towards West Africa.

The investigation concluded that there had been a major failure to comply with the Basel Convention rules on controlling the nature of waste, resulting in the shipment of hazardous and therefore illegal waste, without transparency or prior agreement. Of the 30,000 tonnes of EEE that arrived in Nigeria in 2018, at least 25% were non-functional and non-repairable, and around 70% arrived concealed in second-hand vehicles. In a podcast for the French-language media RFI, Samuel Turpin points out, following a report he conducted in Cotonou in Benin, that the countries concerned could refuse the waste at the time of receipt in accordance with the convention, but that such controls would require resources and political will that are lacking most of the time. In May 2021, the city of Dakar (Senegal) refused to accept 25 containers of plastic waste weighing 581 tonnes from the German carrier Hapag-Lloyd, which had to re-export the cargo to Spain and pay a fine of 2 billion CFA francs (€3 million). Senegal has banned the import of a number of single-use plastic waste products since April 2020.

Tougher international legislation on waste flows

Informal networks are being targeted by restrictions on plastic pollution. In June 2022, India’s Ministry of Environment, Forests and Climate Change announced that the production, import, storage, distribution and sale of single-use plastic products with low utility and a high probability of being quickly discarded will be banned. Failure to comply with this new measure carries a penalty of up to five years’ imprisonment and 100,000 rupees (€1,220). The measure is due to be extended to more products by 31 December 2022. In New Delhi, around 150,000 ragpickers and informal waste collectors depend on the mountains of rubbish in the city. These people (around 5 million in India) are not officially recognised as workers, but they recycle around a fifth of the city’s waste through what they collect, exposing themselves to the potentially dangerous chemicals and methane present in the waste. These informal collectors are the first victims of the dangerous nature of plastic products and their dependence on them. The Indian government’s announcement marks a positive turning point for the reduction of plastic waste, but threatens the livelihoods of the collectors. After three months, studies are highlighting the disproportionate impact on the most vulnerable and the negligible impact on multinationals.

Other Indian local authorities had tried in previous years to ban plastic bags - but to no avail, given the many obstacles encountered. In 2018, the state of Maharashtra attempted to strengthen and enrich its restrictive policy, leading to the closure of more than 300 plastic bag producers in the first few weeks and considerable confusion among the population about their use. Faced with widespread confusion and the support of major groups, the government eventually relaxed the measure. The Maharashtra government subsequently developed other complementary measures, such as charging large industries 0.25 rupees per « tetrapak » to contribute to a fund for waste collection and recycling. Having become the leading destination for European exports since the Chinese bans, Turkey imported 50% of the EU’s plastic waste in 2020-2021.

Nevertheless, the Human Rights Watch (HRW) report published in September 2022 highlights the harmful local effects of plastic recycling in Turkey. The lack of standards and controls is having a major impact on health and the environment. The process of recycling plastic waste endangers health (and drastically reduces life expectancy) through the toxins released when it is recycled if people are not properly equipped. The employees surveyed in the HRW study are on the lowest incomes and cannot afford to lose their jobs. In a report on the illegal trade in plastic waste, Global Initiative observes that around two suspicious incinerations take place at recycling plants in Turkey every week.

On 17 November 2021, the European Commission adopted new rules on waste shipments out of the European Union. The aim of the proposed European measures would be to authorise exports only if the importing countries « are in a position to manage them sustainably » and to oblige European companies to subject the infrastructures that manage their waste abroad to environmental audits. NGOs have nevertheless called for a stricter ban on waste exports, highlighting the exemptions granted and the insufficient distinction between recycling and other less ambitious forms of treatment, such as incineration. According to the NGOs, the revised text could temporarily allow waste to be transferred to OECD countries, but would not make it more difficult to export waste. In a report published in September 2021, the Environmental Investigation Agency called on the European Union to amend the regulations on the transfer of waste because of the environmental and social consequences of these flows.

At local, regional and national level, initiatives are nevertheless shedding light on the future of waste treatment

175 countries have agreed to negotiate a legally binding UN treaty on plastics in March 2022. This treaty could represent a major step forward in the fight against plastic pollution, and has even been highlighted as a potential counterweight to the plan B of oil companies, which are banking on petrochemical production to secure their future. At international level, while many international organisations already exist, CMA CGM - at the One Ocean Summit in February 2022 - reiterated the weight that carriers and all players in the sector have by announcing a ban on the transport of plastic waste on their ships from 1 June 2022. While companies such as Hapag-Lloyd, Maersk, Hamburg Sud and MSC have already done so in Chinese waters - and in Hong Kong for the last three - CMA CGM is taking its ban global.

In the European Green Deal to achieve climate neutrality by 2050, the European Union has devoted a plan to the circular economy, which aims to reduce waste production. In the European plastics strategy adopted in 2018, the measures adopted by Europe concerning plastic waste and its production have resulted in a recycling level of 41.5% (less than 10% in the United States and 14% to 18% worldwide). While the production of primary plastics has decreased in Europe since 2017 (from 64 Mt to 55 Mt in 2019), the average consumption of plastic products is increasing.

From 2009 to 2019, the quantity of plastic waste packaging has increased, as has recycling in quantity but not in relative value. The treatment of plastic packaging by incineration to convert it into energy has increased from 34.4% in 2016 to 36.5% in 2019. Using waste to produce energy has emerged as a solution to be encouraged to promote energy independence at local level, against the backdrop of an energy crisis in 2022. For example, Fnade - a federation of waste sector companies in France - has proposed doubling the production of heat from waste, but the combustion of waste required for this energy conversion still emits greenhouse gases.

The revision of the Waste Framework Directive is scheduled for the first half of 2023, and the revision of the Packaging and Packaging Waste Directive is intended to take greater account of waste prevention rather than just recycling. Ten plastic products have been withdrawn from the European market since 3 July 2021 - in line with a European directive from 2019 - but some NGOs qualify the impact of the measure, estimating that they only concern 1% of European plastic production.

The circular economy is defined as an alternative economic organisation to the linear « produce-consume-dispose » model, and one of the levers for waste management and recovery is the extended producer responsibility (EPR) system. These enable responsibility for plastic waste to be shifted onto the production side, in order to reconnect the different phases of a product’s life cycle. These schemes are designed to get producers involved in the collection, sorting, pre-treatment, rehabilitation - recycling or energy recovery - or incineration of waste.

In a report, GIZ (the German development bank) looks at the results of five programmes of this type set up near coastal areas: in Australia, Canada (British Columbia), the European Union, South Korea and Tunisia. The GIZ study concludes that EPR programmes are effective in preventing marine pollution, provided they are precisely designed, genuinely implemented, monitored and developed on an ongoing basis. In the United States, programmes are beginning to be put in place, following the first in Maine in 2021. In France, an EPR for buildings will come into force on 1 January 2023. In 2021, the EU definitively adopted a tax on non-recycled plastic waste (thus becoming a new source of revenue for the EU). Each kilo of non-recycled plastic packaging waste costs the country 80 euro cents, or €800 per metric tonne. States can pay the cost of the tax directly via their national budgets or by financing it through taxes on the private sector. For the time being, France, Germany, Ireland, Luxembourg and Slovakia have opted for the first option, although they intend to shift the cost onto businesses in the long term to encourage recycling.

In 2021, France has paid €1.2 billion to the EU. Spain and Italy have opted to introduce a new tax on single-use plastic packaging collected but not recycled (€0.45 per kilo), which will come into force on 1 January 2023. The tax introduced by the United Kingdom on 1 April 2022 is different and applies to plastic packaging containing less than 30% recycled plastic and to imported plastic packaging. Belgium plans to integrate the cost of the tax via the extended producer responsibility mechanism. In the United States, according to a report by the American branch of Greenpeace, the recycling rate for polyethylene terephthalate (PET) bottles and jars is just 21%, and 10% for high-density polyethylene (HDPE). However, PET and HDPE jars and bottles, bearing the numbers 1 and 2, are the only ones that meet the government’s recyclability specifications in the United States. The majority of recycling plants refuse plastics numbered 3 to 7, which are more difficult to process or contain too many toxic products. The report therefore notes the limits to recycling plastic products, while highlighting the low recycling rate for those products for which it is possible. The difficulty of recycling plastic waste because of the toxic products it contains and the high probability of it being mixed with toxic waste mean that the cost of recycling is higher than the cost of buying new plastics. The NGO is therefore calling on companies to reduce their plastic packaging by 50% by 2030, rather than doubling their recycling rate. However, the fight against plastic production remains tough in the United States: the General Services Administration has submitted a bill to ban single-use plastics in July 2022, but since then the giants of the plastics industry have launched massive campaigns to counter the proposal. In the Balkans, the policies envisaged focus mainly on the installation of infrastructures to use the combustion of waste to produce energy: an incineration plant for this purpose is due to start up at the end of 2022 in Serbia. In this region, the little that is recycled is thanks to informal collectors, who sell it to recycling companies on site or ready for export. Before recycling, the political challenge is above all to stop the dumping of waste in illegal dumps. Investment in other types of treatment plant has nevertheless been launched in several countries. In Kosovo, a pilot project to treat organic waste was launched in the town of Priština in 2020 as part of a municipal action plan to direct investment towards recycling and composting plants.

In Asia, programmes are being set up to manage and recycle waste, in particular to counter marine plastic pollution. Plastic waste accounts for almost 80% of debris in the oceans. The South-East Asian region is responsible for almost 70% of the plastic waste emitted into the oceans.

As the first victims of this pollution, the countries of Southeast Asia have set up regional plans to prevent and treat it. Two years after the Bangkok declaration to combat marine plastics in 2019, the regional action plan setting out fourteen priority policies to be implemented by ASEAN member countries has been launched and is financed with $20 million in loans from the World Bank. In addition, the Indian Ocean Commission has been running a programme called EXPLOI (Expedition Plastique Océan Indien) since last year. With a budget of €6.5m, the aim of this programme is to analyse this pollution over a five-year period and make recommendations.

In developing countries, local citizens and entrepreneurs are developing their own initiatives to reuse or recycle plastic waste, particularly for infrastructure and construction. In Nairobi, an entrepreneur has launched an industry turning plastic waste into bricks to replace concrete for construction projects: « Made from a combination of plastic and sand, the paving stones have a melting point above 350°C and are more durable than their concrete counterparts ». Gjenge Makers has recycled more than 20 tonnes of discarded plastic, producing between 1,000 and 1,500 bricks a day and creating 150 local jobs. Several plastic waste road projects have been launched in India, where around 60,000 miles of « plastic roads » have been built since 2018. For example, a 703 km motorway will be built in New Delhi using this waste in 2021. Other African and Western countries have followed suit since 2018.