NWRIC discusses export ban with Minister Ley

The National Waste and Recycling Industry Council (NWRIC) has asked Environment Minister Sussan Ley to bring the ban on whole bale tyre exports forward to July 2020, in parallel with glass.

According to an NWRIC statement, the potential harm to humans and the environment by exporting whole baled tyres is significant, with ample capacity to process the material into value added products domestically.

NWRIC members made the request at their quarterly meeting in Canberra this week, which Ms Ley attended to discuss export ban execution and the implications of the proposed timetable.

At the meeting, council members indicated their support for the intent of the ban, and welcomed the strong leadership of the Federal Government, according to an NWRIC statement.

In reference to mixed plastics, NWRIC advised Ms Ley that more time is required for industry to purchase equipment and scale processing capacity. The council also argued for the need to fast track local plastic demand through packaging.

Additionally, NWRIC called the export ban on baled paper and cardboard “illogical,” given local demand is limited and strong existing markets exist overseas.

“This also applies to the export of single resin polymer plastics, such as clean bales of PET and HDPE. The vast majority of this resource is going to legitimate licensed overseas manufacturers,” the statement reads.

How to build local demand for recovered materials for packaging, products and infrastructure was another topic of conversation.

“The minister emphasised the government’s commitment to increase the uptake of recovered materials by changing their procurement practices,” the statement reads.

“She also stressed that businesses must step up too, especially the packaging industry, manufacturers and retailers, by ramping up the use of recycled materials. This program is especially needed in plastic packaging and products.”

NWRIC also argued that for the ban to be successful, new obligations must extend beyond the waste and resource recovery sector, to include organisations importing products to Australia.

“A circular economy requires all parts of the supply chain participate. This also includes consumers who must buy recycled, along with households plus businesses sorting recycling better,” the statement reads.

“Importantly, the minister acknowledged that Australia is a net importer of plastics and paper, so this needs to be considered in implementing the export ban.”

NWRIC members also requested Ms Ley consider banning the export of whole crushed car bodies, white good and waste motor oils.

“All of these products, when exported unprocessed, are causing serious harm to human health and the environment in locations across Asia,” the statement reads.

In addition to the export ban, Ms Ley and NWRIC members discussed the challenges of diverting organics from landfill, and the need for nationally consistent landfill levies.

According to the statement, NWRIC told Ms Ley that there needs to be greater transparency and investment of levies back into developing recovered materials markets, community education, compliance activities, research and data collection. NWRIC members also highlighted the importance of state investment being matched by the Commonwealth.

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Waste export bans alone won’t drive resource recovery

Waste export bans won’t deliver the National Waste Policy Action Plan resource recovery targets unless recycled materials are used in packaging, products and infrastructure, writes Rose Read, CEO of the National Waste and Recycling Industry Council.

Led by the Federal Environment Minister Sussan Ley, state and territory environment ministers agreed at their recent meeting on a timeline for COAG’s waste export bans and signed off on the National Waste Policy Action Plan.

The proposed waste export bans in large are being introduced to reduce harm to human health and the environment overseas. But the likelihood of them delivering the 80 per cent resource recovery target by 2030, or the 70 per cent plastics recovery rate by 2025 on their own is low.

To achieve these resource recovery targets, the demand to use recovered materials locally needs to be fast tracked.

The environment ministers commitment on the 8th November to identify significant procurement opportunities such as major road projects that could use recycled material is a good start. As is prioritising work to develop specifications and standards for the use of recycled materials in building, construction and infrastructure development.

However, this will only increase demand for glass and crumbed tyres. It won’t increase the demand for recovered plastic, paper and cardboard locally.

What is needed to create markets for plastics, paper and cardboard is legally requiring packaging companies, manufacturers and retailers to increase the proportion of recovered materials in packaging put onto the Australian market, including imports, as most of these materials come from overseas.

Some may say that manufacturers have already committed to this. But evidence to date suggests this is limited to one or two global brands that cover less than 40 per cent of the packaging market.

Likewise, none of the major supermarkets have committed to increase the proportion of recycled content in the packaged products they sell. Nor is there any commitment to indicate the level of recycled content on packaging to give consumers the choice to buy recycled.

On the phased timings proposed to implement the export ban:

The NWRIC considers the timeline for mixed plastics is insufficient for industry to purchase and install equipment, especially as there are limited markets.

The timeframe should be extended to match the 2025 APCO recycle content target. If the government wants this to progress more quickly, manufacturers should be required to meet specific plastic recycled content targets sooner.

The NWRIC also does not support the banning of single resin/polymer plastics that have not been processed (e.g. cleaned and baled PET), nor the banning of baled paper and cardboard. Both these recyclates have legitimate overseas markets, clearly demonstrating they are value added products that will not have a negative impact on human health or the environment.

To give government confidence that there will be no harm to human health and the environment overseas, exporters should be able to verify their downstream pathways and material recovery rates with the aid of third-party audits.

Submissions in response to the government’s discussion paper on implementing the banning exports of waste plastic, paper, glass and tyres discussion paper are due by 3 December 2019.

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Tyrecycle questions export ban delay

While Tyrecycle welcomes the Australian Environment Minister’s agreement to ban the export of whole baled tyres, the recycler has called the two-year implementation delay disappointing.

According to a Tyrecycle statement, the decision to delay implementation also represents a missed opportunity to grow local markets.

“To learn the ban specific to whole-baled tyres won’t be implemented until December 2021, six months after plastics which are far more challenging, seems nonsensical,” the statement reads.

“Not only is there already sufficient processing capacity in Australia for end-of-life tyres, but there are also existing local and overseas markets for recycled tyre products.”

A new report commissioned by the Australian Tyre Recyclers Association (ATRA) shows that present Australian capacity is capable of recycling all the material currently exported as bales.

“We already have the capability to recycle tyres for use in asphalt for road surfacing, in tile adhesive, in soft fall and sporting surfaces and as tyre-derived fuels to replace fossil fuel use,” the statement reads.

“All we need is a commitment to increased levels of domestic procurement for tyre-derived products.”

The statement suggests that delayed timeframes will lead to the continued exportation of roughly 70,000 tonnes of whole bales tyres per year.

“Indian authorities are presently seeking to clamp down on imports of used tyres and a recent decision by India’s Green Tribunal leans toward banning any imports of whole tyres that would be used in batch pyrolysis reactors. Surely, it’s a far more ethical and environmentally responsible approach for Australia to act first,” the statement reads.

“A ban, implemented sooner rather than later stands to create local jobs, attract investment in domestic infrastructure and technology, and position Australia as a global leader in the circular economy.”

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NWRIC raises concerns over export ban viability

The National Waste Recycling Industry Council (NWRIC) has raised concern’s over COAG’s proposed export ban, suggesting the regulatory measure will fail if not supported by markets for recovered plastics and paper.

NWRIC CEO Rose Read said the Meeting of Environment Minister’s (MEM) announcement is in urgent need of adjustment to ensure the timelines are realistic.

“Its intent is noteworthy, however its achievability is seriously constrained unless markets and infrastructure are established in parallel,” Ms Read said.

“Perverse impacts from the ban must be avoided as Australia seeks to address its waste and recycling challenges.”

According to Ms Read, NWRIC members are keen to work with all agencies and the packaging and manufacturing industry to support developing markets and regulatory shifts. 

“However, we are very concerned that the regulatory focus is being crudely placed at the end-of-pipe and not at the source of the issue i.e. brands and producers,” Ms Read added. 

“The proposed export bans have the potential to address Australia’s packaging waste and recycling challenges, but only if supported by appropriately targeted product stewardship regulation and effective government procurement policies that create new home markets for used packaging.” 

Ms Read said it was also unrealistic to enforce export bans for plastics by July 2021 and paper by June 2022, when the packaging industry and manufacturers are only working to achieve 30 per cent recycled content and 100 per cent recyclable, reusable or compostable by 2025. 

“Currently, there is no regulation requiring manufacturers or the packaging industry to achieve these targets or penalties if they don’t.  This is far from being equitable,” Ms Read said.

Despite concerns, Ms Read said NWRIC welcomes the environment ministers commitment to further test the proposed export ban timetable with industry and local government prior to finalisation in early 2020.

“The NWRIC is calling on the federal environment minister to bring together a round table of industry leaders from the manufacturing, packaging, waste and resource recovery sectors, to commit to both minimum recycled content levels in plastic and paper packaging and scaling up reprocessing capacity within mutually agreed and realistic timeframes,” Ms Read said.

“If the environment ministers do not prioritise minimum recycled content levels in plastic and paper packaging, there will be no markets for recovered plastic and paper, stockpiles will grow increasing fire risk, resources will be sent to landfill, people may lose their jobs and currently viable businesses will cease.”

To read further industry responses to the export ban timeline click here.

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Waste export bans are one part of the solution

The Prime Minister’s August announcement to ban the export several waste types is a welcomed development. It has the potential to reboot local reprocessing and markets for recovered materials, writes Rose Read, CEO of the National Waste and Recycling Industry Council. 

First, just the facts. As part of the Council of Australian Governments communique on 9 August 2019, the Prime Minister, along with the states and territories announced:

“Leaders agreed Australia should establish a timetable to ban the export of waste plastic, paper, glass and tyres – while building Australia’s capacity to generate high value recycled commodities and associated demand.”

Further, the communique also said:

— “Leaders agreed the strategy must seek to reduce waste, especially plastics,”

— The government will work to; “decrease the amount of waste going to landfill and maximise the capability of our waste management and recycling sector to collect, recycle, reuse, convert and recover waste,”

— “The strategy should draw on the best science, research and commercial experience, including that of agencies like the CSIRO and the work of Cooperative Research Centres.”

These developments are a decisive push in the right direction. However, there are two key elements that need to be addressed to achieve its intention of stopping waste being dumped in developing countries, and stimulating Australia’s resource recovery industry.

These two elements are: building markets at home and clearly specifying how waste paper, plastic, tyres or glass must be processed to become a resource suitable for manufacturing.

Building markets at home

In regard to building markets, two key priority materials stand out. The first is plastics. In order to use the plastics we currently export at home, we will need to increase domestic reuse of plastics by more than 180,000 tonnes per year. To use those plastics here, every Australian would need to purchase products that contain an additional seven kilograms of recycled plastic per year. This still only represents seven per cent of the total plastic waste produced by Australians annually.

Using plastics in civil infrastructure will help. Examples include street furniture, decking by local councils and railway sleepers such as the recent project by Sustainability Victoria, Integrated Recycling and Metro Trains. Integrated Recycling say more than one million railway sleepers in Australia need to be replaced, so just creating railways sleepers from mixed plastics could create a market for up to one quarter the plastics we previously sent overseas.

However, clearly higher end markets for plastics are also desirable, especially putting PET and HDPE back into packaging. These higher end markets will create the necessary pull to stimulate development of Australia’s reprocessing capacity and the collection systems to ensure quality material.

The second market is tyres. According to the Federal Department of the Environment and Energy, Australians generate in excess of 400,000 tonnes of end of life tyres per year. Plenty of scope remains for creating local markets for tyre derived products. Key products produced from tyres include rubber crumb, or explosives and adhesives. Likewise, waste tyres can become high quality engineered fuels for local or export markets.

Positive procurement by local and state governments as well as businesses including the waste and recycling industry is also urgently needed. As consumers of products and materials we must match our rhetoric with action by preferentially purchasing products with recycled content.

Clear specifications and definitions necessary

Clearly, the intention of these bans is to stop the export of unprocessed waste to countries that do not have the ability to process it responsibly. So to untangle this problem, the first step is to have a clear definition of waste.

State and Territory EPAs have done preliminary work in this area as part of their domestic landfill bans, which identify certain goods and materials that should be processed and not buried. Examples include whole baled tyres, whole cars and white goods, all of which are banned from landfill in South Australia.

The next step is to define and agree nationally what minimum material specifications must be met before each waste material type becomes a resource suitable for manufacture locally or overseas.

To some this may seem simple, but in reality it is quite difficult as currently each state and territory have a different approach to this problem. For example in NSW, ‘Resource Recovery Exemptions and Orders’ are used. In Queensland, there is an ‘end of waste (EOW) framework’ of the Waste Reduction and Recycling Act 2011.

This divergence in approaches will need to be resolved urgently, as national agreement on ‘waste’ and ‘resource’ definitions will be key for the COAG’s national ban on the export of waste paper, glass, plastics and tyres is to be successful.

In closing, this approach should also be harmonised with the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes, which has recently expanded its scope to include various plastics. It should be noted that the Australian Government has yet to ratify these latest changes to the Basel Convention.

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