In its letter, BIR supports once again all efforts to protect human health and the environment. Whilst China has stated that for environmental and health protection purposes its intention is to prohibit imports of “foreign garbage”, BIR points out the necessity to differentiate “foreign garbage” from inclusions in processed scrap. Inclusions are generally controlled in commercial specifications so they do not harm human health or the environment and do not hinder the use of the recycled raw materials by manufacturing industries. Hence, the main concern of BIR is the extremely high thresholds for inclusion or ‘carried waste’ in the GB Standards. BIR also points out the difficulty in processing very large tonnages to such very high qualities and the resultant cost increase in the processed secondary raw materials. Lastly, BIR requests equal treatment, i.e. that domestic Standards for the same purpose have the same thresholds.
In its conclusions, BIR requests that the Chinese Government re-defines “carried wastes” in each of these GB Standards so as not to include materials that may be separated and recycled. ‘Carried wastes’ should be defined as wastes which are only fit for landfill or incineration. BIR suggests against using quality thresholds in these GB Standards as pass/fail trade controls specifically where there is no significant human health or environmental impact from ‘carried waste’ and the ‘carried waste’ does not affect the onward recycling processes or utilisation of secondary raw material in manufacturing. While BIR supports the efforts China has taken to protect its Environment it points out that the Chinese GB Standards threshold for inclusion or ‘carried waste’ in their 2005 version were already extremely high when compared to generally adopted Commercial Specifications (with thresholds of 2 – 5% more common). BIR proposes to first strictly enforce the GB Standards from 2005 to gain experience of using such Standards.