An informal in-person meeting of INC Heads of Delegation (HODs) will take place in Nairobi, Kenya, from 30 June to 3 July 2026. Its purpose is to continue the discussion on the most significant topics for the upcoming round of negotiations, which will take place in 2027.
In preparation for the meeting in Nairobi, HEJSupport, the Swedish Society for Nature Conservation (SSNC), and groundWork South Africa have prepared information for the Heads of the INC delegations. In the letter, we highlight several issues that are essential to achieving an ambitious and effective agreement capable of addressing plastic pollution throughout its full lifecycle.
Meaningful Observer Participation
While states hold decision-making authority within the INC process, observers – including CSOs, Indigenous Peoples, frontline communities, scientists, youth, and other stakeholders – provide essential scientific, technical, legal, and implementation expertise that strengthens negotiations and supports informed decision-making. They also play an important role in highlighting on-the-ground realities, documenting impacts on affected communities, amplifying underrepresented perspectives, and increasing transparency and public accountability throughout negotiation processes.
Meaningful participation, transparency, and regular engagement with observers are long-standing practices within UNEP and UNEA processes and are essential for the legitimacy, effectiveness, and accountability of the Plastics Treaty negotiations.
We therefore encourage delegations and the INC Chair to ensure that observers can meaningfully participate in the remaining intersessional consultations and future INC meetings.
Chemicals and the effectiveness of the Treaty
A strong and effective Plastics Treaty requires robust control measures addressing chemicals throughout the full plastics lifecycle.
Plastics are complex chemical materials. According to the PlastChem Project and subsequent peer-reviewed research, more than 16,000 chemicals are associated with plastics, including thousands of chemicals of concern and many others, with inadequate safety data.
Scientific evidence linking plastic chemicals to human health and environmental harms continues to grow. Addressing plastic pollution across the full lifecycle, as mandated by UNEA Resolution 5/14, is therefore impossible without addressing chemicals in plastics.
The Treaty should include:
- upstream measures on hazardous chemicals,
- harmonized and binding chemical transparency and disclosure requirements,
- traceability of chemical information across value chains,
- and measures supporting safe and toxic-free circularity.
Circular economy and recycling limitations
While recycling plays an important role, it cannot alone solve plastic pollution.
Recent OECD findings confirm that recycled plastics may contain hazardous additives, contaminants, and non-intentionally added substances, while transparency and traceability of chemical composition remain limited.
Mechanical recycling — currently the dominant method for plastic recycling — often leads to polymer degradation and accumulation of chemicals of concern, resulting in downcycling and the materials leave the loop only after a few cycles. In addition, many plastics remain difficult or economically unfeasible to recycle in practice.
Emerging chemical recycling methods use catalysts or solvents to break polymers into constituent monomers, but produce chemical waste streams. Pyrolysis, often marketed as recycling, is better described as thermal conversion into fuels (oil, gas, wax), offering no material circularity or climate impact improvements since virgin plastics are still required.
The Treaty should therefore prioritize waste prevention, reduction, reuse systems, safer product design, and toxic-free material cycles, in line with the waste hierarchy.
Transparency and traceability
Chemical transparency and traceability are essential for a safe circular economy.
Information on chemical composition is needed throughout the plastics lifecycle to support safer design, substitution, reuse, recycling, waste management, regulatory compliance, and informed decision-making.
The Treaty should establish globally harmonized requirements for disclosure and traceability of chemicals in plastics, supported by interoperable digital systems and international standards initiatives already under development. Central to this are digital product passports (DPPs), which are digital records of individual materials and products accessible via centralized or decentralized databases throughout their life cycles.
Harmonization, interoperability, and standardization initiatives include, but are not limited to, the United Nations Economic Commission for Europe Transparency Protocol (UNECE TP), which defines technical protocols and data exchange rules for trusted, interoperable sustainability data across value chains; the United Nations Environment Programme (UNEP) Digital Product Information Systems (DPIS) that provides a global conceptual and governance framework for digital product information systems; the Digital for Circular Economy (D4CE) multi-stakeholder platform promoting convergence across DPIS-related efforts; the UNECE/ISO Digital Product Passport (DPP) standardization work; and the EU Ecodesign for Sustainable Products Regulation (ESPR), which introduces mandatory digital product passports in the EU and is expected to be the first large-scale regional implementation of its kind.
Pacific Small Island Developing States (PSIDS)
Pacific Small Island Developing States (PSIDS) are among the most vulnerable regions to the impacts of plastic pollution, despite contributing only a negligible share of global plastic production and consumption. Their geographic isolation, limited land availability, small domestic markets, and constrained waste management infrastructure make it particularly difficult to manage rising volumes of imported plastic products and packaging. As a result, many PSIDS face disproportionate environmental, economic, and public health burdens associated with plastic pollution and hazardous chemicals in plastics.
For PSIDS, effective upstream measures are therefore especially important. Reducing problematic plastic products, eliminating hazardous chemicals, improving transparency regarding chemical content, and supporting reuse and refill systems can help prevent pollution before it reaches island communities and marine ecosystems. Chemical transparency and traceability are also essential to enable informed decisions on imports, waste management, recycling, and the protection of human health and biodiversity. A strong Global Plastics Treaty should therefore reflect the particular needs and circumstances of PSIDS and provide the financial, technical, and institutional support necessary for effective implementation.
Recommendations
- Ensure meaningful observer participation in intersessional and INC consultations.
- Support ambitious upstream measures addressing chemicals in plastics.
- Include mandatory transparency and traceability requirements for chemicals in plastics.
- Prioritize prevention and reuse over recycling.
- Recognize that recycling alone cannot solve plastic pollution.
- Avoid promoting false solutions such as plastic-to-fuel approaches.
Health and Environment Justice Support (HEJSupport), Swedish Society for Nature Conservation (SSNC) and groundWork South Africa (groundWork SA) thank the delegates for their continued efforts throughout the negotiation process and look forward to continuing the discussion on effective implementation measures in support of an ambitious Global Plastics Treaty that addresses plastic pollution across its lifecycle.
Contacts
HEJSupport | Olga Speranskaya, Alexandra Caterbow | info@hej-support.org |
www.hej-support.org
SSNC | Andreas Prevodnik | andreas.prevodnik@naturskyddsforeningen.se | www.ssnc.se
groundWork SA | Rico Euripidou | rico@groundwork.org | www.groundwork.org.za
