ISRI supports the Chinese Government’s strategy to improve the environment and encourage sustainable recycling. However, ISRI is concerned that the draft standards, if implemented, will lead to extensive disruptions in global supply chains because the proposed standards are not in line with the globally recognized ISRI Specifications and lack specific guidance for exporters.
In the submission, ISRI President Robin Wiener requests specific, written guidance on the definition of “other carried waste,” suggests that the allowable percentages align with ISRI Specifications and requests more time to allow for global suppliers to understand the regulations for adequate compliance.
“ISRI understands that at the heart of China’s approach with the proposed GB standards is an effort to identify what is “garbage” so that China can rightfully prevent such material from entering the country,” wrote Wiener in the submission. “We suggest the Chinese Government revise its GB standards to very specifically define what is intended to be minimized in terms of the percentages listed, giving particular attention to distinguishing between unusable trash that should have gone to a landfill and recyclable materials.”
Wiener notes, “Each proposed GB standard also contains a catch-all restriction for “other carried-wastes” with a set threshold for the allowable percentage by weight. It is this last restriction that has raised concerns within ISRI and the global recycling industry as the percentages proposed are in many cases (but not all) out of line with global norms and established manufacturing tolerances.”
“We anticipate additional questions about China’s scrap import regulations to arise as our industry tries to adapt to the regulatory changes and therefore we respectfully suggest an opportunity to meet with MEP, SAC, AQSIQ and other relevant authorities for a walk-through of the regulations, enforcement measures and other potential scenarios that could occur in the normal course of trade.”
“ISRI respectfully suggests that the Chinese Government delay its implementation of the proposed GB standards for a time period consistent with WTO guidelines. Extra time is required for recyclers to fully understand China’s changing scrap import regulations and to make the necessary changes to comply with these new rules.”