The Washington-based Institute of Scrap Recycling Industries (ISRI) has sent a letter to China’s Ministry of Environmental Protection (MEP) urging it to reconsider newly drafted limits on prohibitive materials mixed into scrap shipments.
The MEP draft proposes tightening the thresholds for “carried waste” (contaminants and prohibitives) to 0.3 percent for all scrap materials. If implemented, these standards could effectively prohibit scrap imports to China, according to ISRI.
“The application of this standard will effectively result in a ban on the importation of all these commodities,” writes ISRI President Robin Wiener in the letter to the MEP. “It is simply not possible to achieve such a control level, nor is it possible to even measure it with such accuracy.”
“The current standards followed globally by the recycling community and our industrial consumers are found in ISRI’s Scrap Specifications Circular and vary depending upon the specific commodity,” adds Wiener. “For example, for paper, ‘outthrows’ generally varies between 1 and 5 percent, depending upon the grade of paper. Similar levels are found in the plastic specs. These numbers were determined through an open and deliberative process within the global recycling community, and reflect manufacturing standards and needs. The same open process is utilized for all the other commodities as well.”
In the letter, ISRI also commented on the proposed 80 percent weight requirement for “metal and electrical appliance scraps.” Writes Wiener, “In the United States, a 50 percent threshold is used when defining what is considered legitimate scrap metal for recycling. For consistency in the global trade, we would respectfully request that a uniform standard of 50 percent be used within China as well,” Wiener writes.
Given what ISRI calls a short time frame to provide comments, ISRI also has requested more time to evaluate proposed changes related to allowable radiation levels. ISRI says it supports the need for added radioactive material controls, but needs “more time to evaluate the proposed threshold values.”
ISRI says the letter to the MEP “is part of an ongoing, comprehensive effort by ISRI to protect the interests of the recycling industry as China seeks to impose significant restrictions on the movement of scrap into China.” ISRI says it also has filed comments with the World Trade Organization related to China’s intent to revise its Identification Standards for Solid Wastes General Rules and ban certain scrap imports.