The Basel Convention: NGOs advocate for the global efforts to address plastics pollutionBlog
In a joint letter NGOs urge Canada to advance its work on plastic pollution by supporting Norway’s proposal.
December 12, 2018
Waste Reduction and Management Division Industrial Sectors,Chemicals and Waste Directorate (ICW) Environment and Climate Change Canada
351 St. Joseph Blvd, 9th floor
Transmission by email: firstname.lastname@example.org
Dear Nathalie Perron:
Re: Norway Proposal to Amend Three Annexes under the Basel
Convention – input to Canadas position for next meeting of the Conference of the Parties
The undersigned non-governmental organizations thank you for the opportunity to provide additional input to the proposal made by Norway dated October 26, 2018 in which it recommends to amend three annexes of the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal(Convention).
We are pleased that Canada is seeking stakeholder input to Norway’s proposal to amend annexes under the Convention aimed to place a primary focus on plastics. This comes at a critical moment in time as the global community initiates steps to address the growing threats from plastic pollution to the environment and health. Canada’s leadership in the work to develop the Ocean Plastics Charter, initiated at the G-7 Summit held in Quebec in June, was a critical and laudable step forward.
The proposal, will seek to amend three annexes under the Convention:
1) Further clarifies the criteria for when solid plastic waste in entry B3010 of annex IX does not trigger the prior informed procedure, and
2) Establishes a new category Y48 to be included in AnnexII. This will trigger the prior informed consent procedure for that category, according to the Convention Article 1, paragraph 2 and Article 6, paragraph 1. Norway
proposes that the scope of this category is negatively defined to cover solid plastic waste not covered by B3010 in Annex IX.
3) Establishes a new entry AXXXX in Annex VIII for plastic wastes containing or contaminated with Annex I constituents to an extent that they exhibit an Annex III characteristic.
According to the Norway proposal:
The proposedamendments aim to clarify the distinction between hazardous plastic wastealready covered by the [prior informed consent] PIC procedure, problematicstreams of plastic waste that should be made subject to the prior informedprocedure (Annex II-waste), and uncontaminated, pre-sorted plastic materialsfor recycling, prepared to a specification and suitable for immediaterecycling. The latter group are less likely to pose environmental risks as aresult of transboundary movements and therefore may continue to proceed withoutapplying the convention prior informed consent procedures. The proposal promotes the trade for recovery of uncontaminated andsorted plastic waste streams and incentives the environmentally soundmanagement of plastic wastes limiting the plastic waste that ends up in themarine environment.
UNEP Position on the Norway Proposal
The Proposal from Norway is gaining support from countries and intergovernmental organizations. For example, in September 2018, at the Open-EndedWorking Group of the Basel Convention 21 countries supported the proposal as a significant move forward to reduce plastic pollution.
According to UNEP, “By explicitly including plastic waste in the cope of the Basel Convention, these waste streams can be controlled, and mismanagement of plastic waste avoided”  UNEDP also notes that the Norwegian proposal provides clarity on the regulation of plastic wastes that helps to avoid shipping of plastic waste as “green” waste.
We urge the government to support the Norwayproposal to amend 3 annexes of the Convention.
The Norway proposal complements and advances theglobal efforts to address plastics pollution set out in the Ocean PlasticsCharter led by Canada
and puts in place key provisions in the Convention that strengthens prior informed consent procedures for movement of hazardous materials including plastics and seeks to improve the capture and recycling of uncontaminated materials, particularly plastics.
Advancing Canada’s Strategy on Zero PlasticWaste
The timing of Norway’s proposal complements Canada’s Strategy on Zero Plastic Waste, announced by the Canadian Council of Ministers of the Environment (CCME), which seeks to keep all plastics in a circular economy system and out of the environment. The Strategy is consistent with commitments and objectives presented in the Ocean Plastics Charter, whichwas launched by Canada as part of its 2018 G7 presidency, under the theme of ocean health and marinelitter.
The vision of the Strategy isto keep all plastics in the economy and out of the environment using a circulareconomy approach. While waste management programs are established in Canada, more than 89% of plastics are still landfilled and incinerated. To improve thesituation, the Strategy recognizes the need for an integrated system thatconsists of three areas of activity: prevention, collection and clean-up, andvalue recovery. The system will be supported by enabling activities, includingawareness-raising, and education, research and innovations, regulations andmarket-based instruments. The design of plastic products must become one of thepriority actions that will contribute to the overall goal of 100% reusable and recyclable plastic products. Canada also plans to reduce the amount of e-waste plastic exported to other countries with the aim to recycle more domestically.
At the multi-stakeholder workshop organized in Ottawa by Environment and Climate Change Canada and Health Canada on Wednesday November 28, 2018, participating NGO groups raised concerns over recycling of plastic contaminated with toxic chemicals (as additives) into new products, which undermines recycling and the circular economy. Examples were presented by the NGOs of products created using materials from recycling of plastics containing toxics contain the same toxic additives as the original plastic products. In its response to the NGO concerns, the ECCC noted that the design of safe plastic, free from toxic chemicals will be part of the actions aimed at in the implementation of the Strategy on Zero Plastic Waste. Design of plastic products that could be recycled putting a specific ban on the mixing of different types of plastics – is one of the approaches that ECCC is considering. It was noted by some meeting participants that in many cases there is no need for single-use plastic products; therefore it would be better to phase out the use of these products instead of trying to recycle them.
NGOs further highlighted concerns over the impact of plastic-to-fuel technologies on climate change, as well as the increase in toxic emissions and toxic ash as a result of energy recovery from waste to energy technology. ECCC recognized the problem by saying that the country is not willing to increase the number of waste-to-energy facilities so far and that toxic ash and other residues are well regulated. Nevertheless, the possible options regarding energy recovery – incineration technology will be closely scrutinized as some provinces including Ontario
permit the use of alternative fuels relying on materials destined for final disposal.
Norway proposed amendments – global commitment and improvement to the scope of Basel Convention
While Canadahas made strides to elevate the challenges with global plastic pollution through its Ocean Plastic Charter, the amendments proposed by Norway further elevates the necessity for global actions. If supported, the Parties to the Convention will be given necessary tools and obligations that trigger change in the production, use and ultimately management of plastic products after their use. If adopted the amendments to the three Annexes will elevate certainty that recycling for sorted and uncontaminated materials destined for recycling is achieved while creating obligations for prior informed consent for hazardous plastic materials through PIC procedures.
Canada will benefit from these amendments as it aims to promote a zero plastic waste strategy. The global triggers established under the Convention will support necessary infrastructureand regulatory changes required for establishing appropriate waste managementframeworks with its provincial-territorial counterparts that seeks the sameobjective to reduce plastic pollution and achieve 100% recycling of plastics.The proposal could also seek to make important changes at the federal level bystrengthening the permitting and tracking to validate movement of plasticmaterials outside Canada In addition, the proposal will help Canada to implementits plans to increase the amount of recycling products domestically. Canada
’sexperience in plastic waste recycling, including its technological capacitywill make it the world leader for a safe recycling approach. As more plasticwill be recycled domestically, Canada will further facilitate technological transfer to developing countries to avoidenvironment and health exposure from artisanal dirty recycling faced by thesecountries.
We urge Canada to advance its work on plastic pollutionby supporting Norway’s proposal. We look forward to additional opportunities to provide input to Canada’ sposition on this matter.
Please do not hesitate tocontact us should you have questions.