With the first wave of export bans set to commence in July, Waste Management Review speaks with industry stakeholders about investment expectations and the globalised waste economy.
When the Federal Government announced it would ban waste exports in August 2019, China’s National Sword was old news for most in the resource recovery sector.
While its consequences were still being felt, many industry stakeholders had grown tired of government platitudes about the circular economy.
The Council of Australian Government’s announcement therefore functioned as a jolt – a suggestion to industry that government was finally listening to calls for state intervention.
Praise was quick, with both the Australian Council of Recycling (ACOR) and the Waste Management and Resource Recovery Association (WMRR) releasing statements highlighting the ban as a step towards a sustainable domestic recycling industry.
Despite widespread support for the ban as a concept, many, including ACOR and WMRR, cautioned that for it to be successful, it would need to be backed up by analogous infrastructure investment.
Rose Read, National Waste & Recycling Industry Council (NWRIC) CEO, for example, suggests the regulatory measure will fail if not supported by market investment for plastics and paper. Rose adds that while the export ban’s intent is noteworthy, its achievability is seriously constrained without parallel support.
Similar concerns have been expressed by multiple stakeholders, highlighting a schism between regulatory measures and industry viability.
Mike Ritchie, MRA Consulting, for instance, argued that the Federal Government should introduce recycled content rules for domestic manufacturing. Likewise, Gayle Sloan, WMRR CEO, said the ban should be supported with mandated government procurement.
Following the Meeting of Environment Ministers in November, the Federal Government announced a nationwide timeline agreement.
Ministers agreed on a phased approach, with glass banned by July 2020, mixed waste plastics by July 2021 and whole tyres, including baled tyres, by December 2021.
Additionally, remaining waste products, including mixed paper and cardboard, will be banned by no later than 30 June 2022.
Of the timeline, Rose says the plastics and paper enforcement dates are unrealistic, particularly given the packaging industry is only working to achieve 30 per cent recycled content by 2025.
“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,” she says.
“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 equitable.”
According to Rose, APCO’s packaging targets need to be brought forward to 2022 and mandated under the Product Stewardship Act – as proposed under senator Whish-Wilson’s Product Stewardship Amendment (Packaging and Plastics) Bill 2019.
“This is essential to ensure all packaging manufacturers, brands and retailers meet their producer responsibilities,” she says.
“It will create markets for locally recovered plastics, glass and paper and will remove problematic packaging, including plastics and composite materials, that can’t be recycled due to lack of technology or markets.”
Rose adds that given the ban’s intent, to prevent environmental and human harm, the Federal Government should consider banning whole crushed car bodies, white goods and waste motor oils exports.
“The NWRIC believes the current export of these materials is having substantial impacts on the environment and human health overseas, due to poor recycling and uncontrolled practices similar to that for whole baled tyres,” she says.
“These wastes are being harvested or burnt, with many of the by-products dumped or emitted, polluting the environment and putting human health at risk.”
Rose adds that Australia has the capacity to process these materials locally.
“Currently in NSW, steel mills are importing scrap from interstate and New Zealand to meet their feedstock needs, while whole car bodies are being exported to the Middle East and Asia,” she says.
Alternatively, the NWRIC does not support the banning of single resin/polymer plastics that have been processed, 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,” Rose says.
FREE TRADE?
While concerns over implementation are common, the ban as a concept has been largely well received.
John B Cook, from John B Cook & Associates, however, suggests a blanket ban on exports is counterproductive. He adds that much of the material domestic materials recovery facilities receive is packaging produced from overseas.
“We’re in a situation now where glass bottles are being imported from Singapore. If we are importing packaging from overseas, we shouldn’t say, well you can’t send the packaging back and complete the loop,” he explains.
John admits that while recovered resources are a credible commodity, waste is a difficult industry.
“The market has failed in relation to waste. It [was] thought landfill was an inexpensive, easy option, and we’ve been dealing with that ever since.
“That said, we’re now moving away from a disposal culture. People want a circular economy, they want recycling, plus they don’t want to live next to landfills. So the market failed, and the reality is government intervention is required.”
John says however that the devil is in the detail. He adds that while there should be a ban on exporting “garbage”, completely closing the borders is unsustainable.
“Contracts need to be developed that ensure we are adding value and recovering resources instead of exporting dirty plastics, which we seem to have been doing,” he says.
“We should be washing and processing the material here and exporting bales or pallets at low contamination levels.”
The Federal Government also needs to facilitate market development, John says. He adds that while those markets are developing, exports need to occur to a specification that is adhered to.
The idea of sustainable exports, John says, works in tandem with developing domestic recycling markets. He suggests investment in the infrastructure and technology required to produce high-grade pure materials for exports has a flow-on effect.
That said, lack of federal investment is a central industry complaint surrounding the ban.
While it’s too soon to tell, the Federal Government’s recently opened $100 million Australian Recycling Investment Fund might alleviate these concerns.
Speaking with Waste Management Review in June last year, Assistant Waste Reduction Minister Trevor Evans said the fund was designed to support recycled content product manufacturing.
Administered by the Clean Energy Finance Corporation, Minister Evans said the government will provide guidance about the mandate and how to best invest in new industry.
While the fund was announced in May 2019, applications didn’t open until December. This followed criticism from Labor Assistant Environment Spokesperson Josh Wilson, who said the Federal Government was not doing enough to support the export ban or build the National Waste Strategy.
“We know the so-called recycling investment plan is predominantly bulked out with prepackaged or repackaged funds,” Mr Wilson said.
“The hundred million dollars in the Australian Recycling Investment Fund consists of nothing more than a fresh label on existing clean energy finance moneys.”
Rose says while the NWRIC welcomes the Australian Recycling Investment Fund, its investment criteria means it will only be capable of supporting a few major infrastructure projects.
“Smaller projects, for example those less than $10 million, won’t have access to the fund directly, but will have to seek loans through the Clean Energy Finance Corporation’s aggregate programs,” she says.
A GLOBAL PROBLEM
Despite ban conversations understandably centring on Australian markets, Michele Acuto, Melbourne University Global Urban Politics Professor, says industry and government need a global perspective.
Drawing on research from the World Economic Forum, Michele says retreating into an export ban is paradoxical to the notion of a circular economy.
“The problem with the ban is that it’s similar to immediate conversations after China’s restrictions. The rhetoric is quite nationalist, and more explicitly, about domestic solutions to an international problem,” he says.
“I want to be very clear that I’m not saying Australia doesn’t require strong infrastructure investment – but we do need to be thinking in terms of a global circular economy.”
The ban, he says, is diametrically opposed to this approach, and a recognition of waste as a global series of networks and industries.
The World Economic Forum suggests to create a global circular economy, system change needs to enable blended financing models, particularly in developing countries, policy framework adjustments and public-private collaboration.
For instance, Michele suggests a more collegial and strategic relationship between Australia and its neighbours could move global networks in the right direction.
He adds that while there is little agreement on waste definitions between Australian states, let alone sovereign bodies, the Federal Government should attempt to work in tandem with Malaysia, Thailand and Vietnam.
“We’ve turned another opportunity for leadership into a statement of inward policy. It’s very tit for tat and smells like 1980s Cold War policy. There’s an ocean of difference between the ban and a strategically based national plan,” he says.
The World Economic Forum suggests similar, albeit more controversial, solutions. Recycling is linear, the NGO argues, and out of touch with the extended lifecycle goals of a circular economy.
Reusing, redistributing and/or remanufacturing strategies are the preferred approach, it argues.
Additional points include moving away from activities that devalue materials, relocalising and resizing activities closer to consumers, and developing strategic partnerships with service providers.
While it’s hard to argue against future-focused attempts to restructure our approach to waste and consumption, the challenges of today still require action.
At a recent meeting with Federal Environment Minister Sussan Ley, the NWRIC members discussed how to build local demand for recovered materials for packaging, products and infrastructure.
According to Rose, 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,” she says.
This article was published in the February edition of Waste Management Review.
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