More control desperately needed on plastic waste exports

In September 2010, the VROM Inspectorate published a report on the enforcement of the WSR rules for the export of plastic waste from the Netherlands in 2009. The report shows that in over 20% of the 350 investigated cross-border shipments of plastic waste, environmental regulations were violated administratively and/or also in a 'physical sense'. The investigated shipments are estimated to account for less than 1% of the total amount of plastic waste exported.

The fact that the administrative records for the remaining three-quarters of the containers were in order does not mean that there could be no 'physical' contamination present; this was simply not checked. What does seem to have become clear from the investigation is that of the consignments that did not comply administratively, a substantial proportion was also too contaminated in a physical sense to be recycled in a legal and acceptable manner. Of the containers whose administration was not in order, 8 containers were examined in more detail. All 8 containers were too heavily contaminated. According to the VROM Inspectorate (VI), these 8 containers did not constitute a random sample, but how representative these 8 containers actually were could not be indicated. An exact picture of the extent to which contaminated fractions are transported across all shipments cannot be derived from the VI report. Moreover, upon inquiry, the VI appeared unable to provide this either. However, the VI does share the view that the situation remains worrying; plastic waste will therefore continue to be treated as a priority waste stream by the inspectorate.

In 2008 and 2009, the VROM Inspectorate also detected violations in the export of heavily contaminated plastic packaging waste. In most cases, this concerned export to China, where relatively strict import requirements apply. A smaller part, however, enters China via Hong Kong. "The difference with the direct line, however, is that it may end up with unlicensed companies. Exporting low-quality batches of plastic bought relatively cheaply in this way can result in a portion not actually being recycled. There is also a risk that processing at these unlicensed companies may not be environmentally sound."

In our view, an intensification of supervision is therefore needed, in such a way that a complete picture can emerge of the extent to which contaminated plastics are exported. Moreover, this is not only a task for the government, but also for Nedvang (plastic packaging) and the NRK (other plastics). We therefore believe that the letter sent by the State Secretary for Infrastructure and the Environment to the House of Representatives on 10 November on this subject falls seriously short. The problematic situation needs to be investigated and tackled much more extensively and systematically. Recycling Netwerk has sent a letter about this to the members of the Standing Committee for Infrastructure and the Environment of the House of Representatives.

Read also Article in EVO Logistiek: Intended easing of WSR works out wrong