China’s announcement last month to cease acceptance of various waste paper and plastic grades
and a decrease of allowable contamination on imported bales resulted in widespread shock and
condemnation of their approach to protect their environment and public health. Various
associations have even called on their governments to intervene and to ‘make’ China continue to
accept these wastes and maintain acceptance of existing contamination levels. The UK’s Recycling
Association for example, has called the proposals to reduce contamination levels from 1.5% to 0.3%
Old Corrugated Containers (OCC) in EN643 (European standard for paper for recycling) unrealistic.
They have also formally requested that the Chinese Government reconsider the ban on post-
consumer plastics.
In its submission, the UK’s Recycling Association took the opportunity to even warn the Chinese
Government of possible increases in shipping costs of East-West routes as shipping companies seek
to compensate for the loss of revenue. Yes – really!
China’s approach to addressing environmental pollution and public health should be commended –
not touted as unfair by countries and organisations wishing to maintain the status quo of exporting
waste which they themselves do not want to process. Instead, we should be focusing our efforts on
building local (national) capacity and innovation to reuse these resources and build sustainable
markets.
China’s solid waste recyclers have been facing increasing environmental regulatory scrutiny. Last
week, environmental officials in China announced further inspections of companies which recycle
imported wastes. These inspections form part of a five-month joint campaign between customs and
the environmental authorities, targeting Chinese firms which import e-wastes (including larger
appliances), tyres, plastics, and textiles. These inspections are seeking to close-down polluting
enterprises, regulate processing zones, and guide the green growth of domestic recycling
companies. The inspections may also inform further import bans of materials for recycling.
In July 2017, inspectors audited 1,792 imported waste processors of which 60% has serious
breaches, such as excessive pollutant releases. As a result, fines for environmental breaches are to
be increased, particularly targeting companies which smuggle solid waste into China. This is in
addition to more frequent random inspections on companies involved in the importation of wastes.
These audits were critical in informing the recently announced bans on various paper and plastic
categories into China, and the development of the action plan to ban the importing of ‘polluting
garbage’ which will be completed by 2019.
These efforts have been as a result of ongoing and increasing levels of contamination (some
hazardous) in imports of recyclate labelled as ‘raw materials’. It also forms part of a larger, targeted
plan to address pollution levels (specifically air) and other pollutants which cause environmental
damage and pose risks to public health.
The Ministry of Environment has developed a series of plans for regional campaigns to address
pollution and provide more powers to regulators to manage polluting companies. One specific plan
looks at the Beijing-Tianjin- Hebei region and neighbouring provinces to control air pollution and may

result in companies installing new pollution control technologies, potential relocation, through to
closure.
There are increasing challenges in many of the material streams. Not least the progress towards the
‘limits of circularity’ for some materials (packaging) as we push resource use to maximise
‘minimisation’. For example, technological developments aimed at making PET bottles thinner and
lighter have resulted in higher moisture content in bales and thinner flakes which are more likely to
be discarded during the recycling process. We are also seeing more diversity in product offerings
and materials resulting in our waste and recycling streams becoming increasingly complex and our
labelling, collection schemes and sorting technologies have yet to catch up with these changes. For
example, opaque PET bottles and PET trays are now increasingly being mixed with coloured PET
bales. It is time we start to look at products in their entirety, with product designers and product
manufacturers working more closely with the waste and recycling industry to develop a truly circular
approach.