The draft proposes tightening the thresholds for “carried waste” (i.e. contaminants and prohibitives) to 0.3% for all materials which is of particular concern to the recycling industry. If implemented, these standards could effectively prohibit scrap imports to China.
“ISRI is extremely concerned with the reduction of the control requirement for “carried waste” to 0.3% for all commodities,” wrote ISRI President Robin Wiener in the letter. “The application of this standard will effectively result in a ban on the importation of all these commodities. It is simply not possible to achieve such a control level, nor is it possible to even measure it with such accuracy.”
“The current standards followed globally by the recycling community and our industrial consumers are found in ISRI’s Scrap Specifications Circular and vary depending upon the specific commodity. For example, for paper, “outthrows” (the equivalent term for “carried waste”) generally varies between 1% and 5%, depending upon the grade of paper. Similar levels are found in the plastic specs. These numbers were determined through an open and deliberative process within the global recycling community, and reflect manufacturing standards and needs. The same open process is utilized for all the other commodities as well.”
In the letter, ISRI also commented on the proposed 80% weight requirement for “metal and electrical appliance scraps.”
“In the United States, a 50% threshold is used when defining what is considered legitimate scrap metal for recycling. For consistency in the global trade, we would respectfully request that a uniform standard of 50% be used within China as well,” Wiener wrote.
Given the short time frame to provide comments after translations, ISRI also requested more time to evaluate proposed threshold values related to allowable radiation levels. ISRI does however support the need for added controls.
The letter to the Chinese government is part of an ongoing, comprehensive effort by ISRI to protect the interests of the recycling industry as China seeks to impose significant restrictions on the movement of scrap into China. As the Voice of the Recycling Industry TM, ISRI has engaged the U.S. Government on the issue and is in constant communication with Chinese officials, and its recycling counterparts throughout the world. ISRI has also filed comments with the World Trade Organization related to China’s intent to revise its Identification Standards for Solid Wastes General Rules and ban certain scrap imports.
