The Institute of Scrap Recycling Industries (ISRI), Washington, issued an alert to its members dated Dec. 11, 2017, updating them about its recent meetings in Beijing with Chinese and U.S. government officials and its industry association counterparts. The association also offers guidance to its members regarding implementation of China’s new import rules.
The alert, which is signed by ISRI President Robin Wiener and Chair Mark Lewon of Utah Metal Works, Salt Lake City, explains that China is facing “a serious environmental crisis,” and the country’s central government has prioritized cleaning up the country’s environment. “Their focus is not on any one industry but across all sectors of the country's economy regardless of the impact on jobs and production,” the alert states. “A wide-ranging series of actions—including closures, aggressive enforcement and the tightening of environmental controls—are being implemented in industries as far ranging as agriculture coal, oil and recycling.”
The association says the actions are coming from the highest level of the Chinese government and little time and few resources are being given to the country’s government agencies charged with developing and implementing these rules to ensure they “get it right.”
The alert reads, “The Chinese are struggling to distinguish between what is waste (that they do not want in their country at any cost) and valuable resources, i.e., scrap (that they understand is needed as feedstock for Chinese manufacturing). And in their rush to meet President Xi Jinping's directive to develop rules to prevent ‘foreign waste’ from entering their country, they have created terms and standards inconsistent with the global trade.” ISRI adds, “During our meetings it was clear that there is little understanding within the Chinese government of the chaos they have created.”
The association says AQSIQ (General Administration of Quality Supervision, Inspection and Quarantine) is unprepared to implement the bans on mixed paper and postconsumer plastics Jan. 1, 2018, adding that representatives from the agency “could not answer questions as to the meaning of the terms. Thus,” ISRI concludes, “the likelihood of individual inspectors at the ports understanding what they are inspecting—and what they are looking for—is very low.”
While ISRI says the Chinese government is listening to what it has to say on the matter, “they have limited time and ability to take in all the comments.”
ISRI notes that a working group comprised of officials from the U.S., Canadian, U.K., E.U., Australian, New Zealand and Japanese embassies in Beijing are coordinating strategy and speaking to the Chinese government on behalf of the recycling industry. “We briefed this group last week and were very pleased with the concerns expressed by each and their joint commitment to provide support,” the association says.
According to the alert, ISRI “attempted during our meetings to get clarifications to the Chinese government’s definition of ‘carried waste,’ the specific scope of paper and plastics to be banned and the specific timing that these actions will come into force. For ‘carried waste,’ it is very clear they do not want imported trash but are confused as to how to define what is trash and what is not. Beyond that, the government does not know the answers to our questions, which included very specific examples of grades that are typically exported to China. Furthermore, they have not fully prepared for the implementation of the regulations, and we believe even more confusion and inconsistency is yet to come.”
ISRI suggests that its members be vigilant when loading to avoid including dirt, wood, concrete or other materials or even recyclables that do not belong in that particular load. The association also advises including more photos and thoroughly documenting the condition and contents of shipments before export. It also tells its members to expect rejections. “We anticipate a greater number of rejections of material before and after shipping, and it will not necessarily be related to scrap quality but unfortunately on misunderstandings by inspection officials as to what they are looking for.”
ISRI encourages its members to keep records of their experiences, including reasons given for rejections, and to share this data with the association.
“As to next steps, comments to the World Trade Organization are due this week,” ISRI notes in the alert. “Based on what we now know, we are rewriting our comments to include very specific information about the industry, including specifics on the various grades of scrap traded globally, suggestions on quality standards and detailed questions to try to get as much clarity and guidance as possible.”
ISRI adds that members are welcome to submit comments by the Dec. 15 deadline, adding, “There is a specific process to do this, so please feel free to reach out to Adina Renee Adler for guidance if you are interested in doing so.”
Adler can be contacted at firstname.lastname@example.org.