Drastic drop in exports outside the EU expected following adoption of Norway proposal, says FEAD


Following the Conference of Parties meeting where 180 governments adopted the Norway proposal to move mixed plastic waste to the ‘amber list’, FEAD has said that there will be a “drastic drop” in exports outside the EU. 

The proposal means that outside or within the EU, exports of mixed plastic waste that are not perfectly sorted, recyclable and contaminated will be subject to prior consent from exporting and importing countries as of January 1, 2021.  


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FEAD believes that the adoption of this amendment will end in a drastic drop in exports outside the EU, and that it will become more difficult and more expensive due to additional red tape and long delays, required by consent.  

It stated that it might become “impossible” to export, not only in the case of delayed or missing consent, but also due to the legal uncertainty on how customs authorities will determine if plastic waste shipments meet the conditions of exports for recycling.  

There also needs to be a clear definition of “contamination” or the legal criteria for meeting the conditions will be subject to a wide difference in interpretation, said the Federation.  

FEAD president Jean-Marc Boursier said: “This international decision, of which we understand the motives but question the effectiveness regarding marine pollution, ignores that recycled wastes are traded on a global commodity market. Such a major drop in the exports of EU collected and sorted plastic waste will effect, in the short and in the long term, the existing separate collection and sorting systems and, finally, downgrade the EU’s recycling performances. 

“In the absence of new markets compensating the lost exports, it will prevent new investments and jobs from being created. The private waste management industry is ready to invest in improving the quality of plastic recyclates only if there is a market for recycled plastics. Pull measures such as mandatory recycled content in products, reduced VAT, mandatory green public procurement, can create a demand shock. Imported products should also be covered by these rules. The EU has to urgently adapt its own intra-EU shipment rules so that shipments of non-hazardous plastic waste for recycling or for recovery remain under the current regime.” 

FEAD said that plastic waste should be reclassified and assimilated to hazardous waste in the ‘amber list’, but as no appropriate code exists, it will make some plastic exports impossible. If the demand for recycled plastic remains weak, the loss of flows of exports outside the EU means less recycling within the EU. 

To prepare for the new rules in 2021, the Federation believes it is vital that public authorities responsible for shipments implement strengthened controls against illegal trade.  

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