09 Jun 2022

Venue: CICG | Room 14 & Online

Organization: International Pollutants Elimination Network, Geneva Environment Network

This side event to the 2022 meetings of the Conference of the Parties to the Basel, Rotterdam and Stockholm Conventions (BRS) focused on the international trade in refuse-derived fuel (RDF) and similar products which contain a high fraction of mixed plastic waste. This event is organized by the International Pollutants Elimination Network (IPEN) and the Geneva Environment Network, within the framework of the Geneva Beat Plastic Pollution Dialogues.

About this Event

This event focused on the international trade in refuse-derived fuel (RDF) and similar products which contain a high fraction of mixed plastic waste. Currently, RDF is not clearly regulated under the Basel Convention creating a loophole allowing continued low quality or hazardous plastic waste exports from wealthy countries to the global south for disposal.

The event is included in the programme of the Plastics Forum, taking place from 8 to 10 June 2022, as part of the 2022 meeting of the Parties to the Basel, Rotterdam and Stockholm Conventions.

The Geneva Beat Plastic Pollution Dialogues

The world is facing a plastic crisis, the status quo is not an option. Plastic pollution is a serious issue of global concern which requires an urgent and international response involving all relevant actors at different levels. Many initiatives, projects and governance responses and options have been developed to tackle this major environmental problem, but we are still unable to cope with the amount of plastic we generate. In addition, there is a lack of coordination which can better lead to a more effective and efficient response.

Various actors in Geneva are engaged in rethinking the way we manufacture, use, trade and manage plastics. The Geneva Beat Plastic Pollution Dialogues aim at outreaching and creating synergies among these actors, highlighting efforts made by intergovernmental organizations, governments, businesses, the scientific community, civil society and individuals in the hope of informing and creating synergies and coordinated actions. The dialogues highlight what the different stakeholders in Geneva and beyond have achieved at all levels, present the latest research and governance options.

Following the landmark resolution adopted at UNEA-5 to end plastic pollution and building on the outcomes of the first two series, the third series of dialogues will encourage increased engagement of the Geneva community with future negotiations on the matter. These include the meetings of the Intergovernmental Negotiating Committee (INC) from the second half of 2022 to 2024, as well as preparatory meetings within the ad-hoc open-ended working group during the first half of 2022. The series will also continue to foster stronger cooperation and coordinated actions ahead of other milestones in the environmental agenda, including the BRS COPs, SAICM ICCM5, the 2022 UN Ocean Conference, UNEA-6 and other processes in Geneva, such as at the WTO.



Mercury and POPs Policy Advisor, IPEN | Senior Researcher, National Toxics Network (Australia)


Senior Advisor and Co-Founder, Nexus for Health, Environment and Development Foundation (Nexus3)


Research Officer, Consumers’ Association of Penang


Executive Director and Founder, Basel Action Network


Programs and Policy Coordinator, IPEN | Moderator


In addition to the live WebEx and social media transmissions, the video of the event is available on this webpage.


Key messages from the event and quotes are available on our Twitter account.



Lia ESQUILLO | Programs and Policy Coordinator, IPEN

The International Pollutants Elimination Network (IPEN) is comprised of over 600 public interest NGOs in more than 120 countries. We work to strengthen global and national chemicals and waste policies, contribute to groundbreaking research, and build a movement for a toxics free future.

This side event will focus on the transboundary trade in refuse-derived fuel (RDF) and other similar fuels, like processed engineered fuels (PEF), which contain a high fraction of mixed plastic waste. Panelists will discuss the Australian government’s waste export ban being undermined by legislation allowing PEF exports to neighboring countries, and the lack of controls around this hazardous trade. Further insights will be provided into the trends around RDF imports, trade, and production affecting Indonesia and Malaysia. We conclude with the examination of recent plastic waste trade data relevant to the Asian region and the Basel Convention controls.

Waste Export Bans and RDF Trade

Lee BELL | Mercury and POPs Policy Advisor, IPEN | Senior Researcher, National Toxics Network (Australia)

Context and timeline. To discuss the Australian Waste Export Ban and how that’s being undermined by exporting waste plastic as fuel into the region, it is important to describe the context:

  • 2017: China implemented a National Sword Policy to reduce environmental damage from imported waste into China, forcing waste exporters like Australia to redirect waste exports to countries in Southeast Asia.
  • Post-2017: Australia’s plastic waste exports destined for recycling often ended up dumped, open, burned, or used as fuels with minimal recycling. Persistent organic pollutants (POPs) food chain contamination from burning plastic were identified and import countries began to reject and return Australian shipments of plastic waste.
  • 2019: Basel Ban Amendment enters into force preventing OECD countries from exporting hazardous waste.
  • 2020-2021: Neighboring countries begin rejecting or tighten controls over plastic waste exports. Australia invests in a domestic recycling program and announced a Waste Export Ban, one of the first globally.

Changes in policies. China’s National Sword Policy, a strict regulation on imports of solid waste and raw materials, in 2017 prompted countries like Australia to review their recycling infrastructure and plastic waste export options.

Considering Australia’s historical dependence on waste exports to a country with low labor costs and environmental standards, the country has minimal recycling options and infrastructure available. As such, other export destinations, such as Indonesia, Malaysia, and the Philippines, were targeted. When the Basel Ban Amendment entered into force in 2019, controls tightened further (See IPEN, “The Entry into Force of the Basel Ban Amendment: a Guide to Implications and Next Steps).

When neighboring countries started rejecting Australian plastic waste shipments to counter the surge in imports, waste exports became a political issue in Australia. The Australian government announced a waste export ban and heavy investments in domestic recycling, including a billion-dollar waste and recycling plan.

The loophole. This huge investment, however, included RFDs and PEFs: shredded plastics, paper, timber, fabric, and other combustible waste compressed into solid fuel pellets or bales for burning in cement kilns and incinerators. These are exported from Australia as a fuel product and not waste, even though they are made of waste. In such a form, they may avoid the restrictions of the Basel Convention, where they should be classified at least as Y48 (under Annex II).

The problems. However, the Basel Plastics guidance fails to address the implications of such a waste trade. Little information is available about this trade or on the contents of RDF. Moreover, Australia produces more than a quarter of a million tons annually for use in Australia and plans to significantly expand production on exports into Southeast Asia.

After announcements were made, problems associated with the trade were made evident:

  • Reuters conducted an exclusive investigation and Australia came under fire for shipping their plastic waste as fuel to these countries.
  • Australian waste companies had significant plans for RDF/PEF expansion in the region, which includes establishing factories in other countries to produce waste for distribution as a way to overcome export issues.
  • An International Energy Association report in 2022 mapped out transboundary movements in RDF and solid recovered fuel (often made of tires), and found that while China and India are currently major final customers, Australia intends to export more to other countries in the region, like the Philippines.
  • An outlook on Plastic Waste Trade from Australia in 2021 shows that the reality of Australia’s waste management is different from what was claimed: main destinations remain to be India, Vietnam and Malaysia despite the National Ban in 2021.

The unilateral determination by Australia to consider RDF and PEF as a non-waste — and thus not subject to this kind of waste export bans or controls — is another concerning development. However, federal regulators have informed licensed applicants who wish to export the material that an application for a hazardous waste export license may be needed. This results into a contradiction.

RDF and PEF export volumes are also difficult to track since they do not have a specific Harmonized System Code (HS) and fall under much broader plastic waste HS codes, which tend to obscure the actual volumes that are involved.

Recommendations. According to IPEN, Australian exports of plastic waste to be burned in neighboring countries must come to an end. They recommend that such exports are classified as waste shipment rather than product exports to clarify the status of these materials, and to subject them to the Basel Transboundary Controls. RDF, PEF and associated wastes used as fuel should be assigned a specific HS code to ensure trade transparency and the ability to track.

These kinds of waste should be rapidly phased out as an environmentally unsound management practice of plastic waste, due to toxic emissions when burned, food chain contamination and a high carbon footprint. It is impossible to ensure that they are burned and consumed in facilities that meet the highest regulatory standards. The newly elected Australian government will now review this practice, and we’ll be talking to them on this use and the export with a view to implementing a real waste export ban.

[For more information on this topic you may read IPEN’s publications: Plastic Waste Fuels and Australian’s Refuse-Derived Fuels.]

Refuse-Derived Fuel in Indonesia

Yuyun ISMAWATI | Senior Advisor and Co-Founder, Nexus for Health, Environment and Development Foundation (Nexus3)

Indonesian context. In 2020, the composition of Indonesian waste mainly comes from households and traditional markets, thus being dominated by organic waste. Alongside food waste, woods, branches, and leaves are an important part, while plastics amount to about 17% of the total.

The Indonesian government has in place several policies and regulations related to RDF and waste management:

  • At the local level, the government and subregional regulations already banned several types of plastic packaging.
  • At the national level, regulations and strategies to reduce and manage plastic waste included the requirement for FMCGs and retailers to submit the roadmap to reduce plastic waste about 30% by 2030.
  • This is also linked to the energy strategy, which aims to have mixed sources of energy by 2025. The current reliance on oil and coal is not excessively high, but the government would like to increase the use of renewable energies, which consist of biomass in form of pellets and briquettes.
  • Plastic is also considered a new source of energy and mixed waste due to the problems of the Indonesian waste management system.

Plastic sources. Despite being a producer of virgin materials, about 50% of the virgin materials to make plastics in Indonesia are imported since locally produced ones are considered low capacity. As such, imported plastic products are the result of plastic waste mixed with virgin materials. When waste arrives, however, containers are at times mixed: thus, those from paper companies are likely to contain lots of plastic packaging, especially flexible ones.

Plastic as fuel? Indonesia follows the references about the type or grade of RDF. RDF-5 is widely used for coal-fired power plants and cement kilns. Based on this reference, various projects are now being pushed to create or produce RDF pellets and briquettes. The Indonesian Ministry of Energy and Mineral Resources also tried to identify new sources of renewable energy from biomass among waste. Biomass sources from agriculture are deemed better than municipal waste.

RDF plants. To support the strategy on waste management from 2025 to 2030, the government also set the target to have about 40 RDF plants and about 23 waste energy plants by 2030.

  • Several national standards have been issued, especially standards related to RDF bio pellets and briquettes, or SNIs (Indonesian National Standards). These SNI are voluntary, thus it is unimportant whether the producer respects them or not.
  • More than twenty coal-fired power plants are now scheduled to have RDF as a co-firing mechanism, especially those run by the Indonesian power companies, or alternative fuels deriving from biomass.
  • This causes a problem in terms of CO2 emissions as it simply replaces coal with another fossil fuel. Moreover, biomass emissions will be more toxic because they will be a mix of plastics in the RDF.

Cement kilns. This process is referred to as co-processing rather than co-firing, because mixed waste will be burned together with other materials to produce cement. Despite dioxins monitoring being challenging in developing countries, including Indonesia, this is also included in the target thermal substitution rate for which many state-owned companies are being pushed to replace coal 15-23% with RDF from biomass or other sources by 2025.

  • Cement companies and coal-fired power plants must increase their capital investment to accommodate different materials being burned and collaborate with suppliers to fulfill the capacity to replace from 1% to 5% of coal.
  • To support this, the government relies on the Ministry of Environment Regulations on emission standards. Due to the lack of capacity of local laboratories to analyze dioxins, the government set standards to analyze and monitor polychlorinated dibenzodioxins (PCDDs), dioxins and furans only every four years.
  • Cement kilns that use coal-firing hazardous waste must be measured at least once a year, depending on the permit. Cement kilns also release heavy metals issues for which standards need to be tightened.

Small-scale RDF. Plenty of small-scale RDF to process mixed waste and waste residues from communities and residential areas are available. Some of these are supported by FMCGs, but, as in the case of Bali, the processing of household waste to produce RDF is acidic, raising complaints from the community surrounding that area.

  • When an FMCG asked a certifications-issuing company for plastic credit for the waste they processed, we have tried to discuss the standard for certifications of plastic credit. This is because if plastic is burned in boilers or small-scale facilities, no emission controls in these small units are available. We try to communicate with companies.
  • Since the small-scale RDF was launched last year, it represented a source of concern, because it is uncontrolled but widely supported.

Addressing the issue. The issue of plastic waste importation is both caused by plastic and paper companies. Despite a decrease in plastic waste imported by Indonesia in 2021, this number is not final yet. Additionally, this decrease might result from the switch to different types of plastics imported.

We tried to use the HS code as entry points for PEF to Indonesia, namely 3825, municipal waste, which is being used in many other countries to send plastic waste or RDF. Other countries have also used different codes to transfer or trade RDF like 400400 or 700700, where in 2020 the highest one was from Australia.

Recommendations for the Indonesian government.

  1. Allocate funds to improve the waste management system as a whole and Zero Waste approach.
  2. Prohibit importations of waste for alternative fuel, under the code HS code 3825 or 360690.
  3. Implement effectively the Basel Amendment and strengthen the border check.
  4. Strengthen emission standards for thermal treatment facilities.
  5. Prohibit RDF productions and use for small scale in residential areas.
  6. Increase the capacity of laboratories especially to analyze dioxins and POPs.
  7. Publish the roadmap of the circular economy for paper and plastic industries.
  8. Turn voluntary SNI into mandatory ones.
  9. No subsidies are given to RDF or WTE projects.

Refuse-Derived Fuel in Malaysia

Mageswari SANGARALINGAM | Research Officer, Consumers’ Association of Penang

Introduction. The Consumers Association of Penang has been working for consumer rights and environmental issues since 1969. Working with IPEN to study process engineered fuel coming into Malaysia, they discovered a 2006 RDF plant, whose scientists and engineers claimed that it could solve the municipal solid waste problem by diverting the waste from going to landfills.

A pilot project, it had a capacity of processing 1,000 pounds/day and 8.9 MW of electricity. After a year from construction, people from surrounding areas complained, claiming that waste was being sent out again because the plant could not fully operate. The capacity for the operation was only 70% and was finally shut down in 2015, with the company going bankrupt.

Malaysia’s waste context. Following China’s decision to ban all waste imports, we studied why Malaysia was a top dumpsite in 2018, showing HS 3915 for plastic waste coming in, 3825 for RDF of municipal waste, 3825.10 for RTF and 3606.90.10 for processed engineered fuel. It also showed Indonesia exporting waste to Malaysia (spent bleaching earth, a byproduct of oil pump processing from palm oil processing industries).

After launching an official complaint to the Malaysian government, the inspection of the Department of Environment revealed the presence of electronic waste, a hazardous waste. The government repatriated the waste back to Australia and decided to ban imports of this kind of material. Demonstrations were held in front of the ResourceCo Asia factory.

The pressure on Australia to ban waste exports was high, but the new plastic rules were only partial relief for neighboring countries like Malaysia. The ban did not include export materials treated as PEF – considered not plastics despite containing 30-50% of it.

Tyres, if processed into crumbs or shreds, are considered as tyre-derived fuel, and enter both Malaysia and Indonesia and perhaps the Philippines. An investigation by the Malaysian government revealed that base tyre exported from Australia was meant to go into cement kilns.

Loopholes? The ResourceCo company after being banned from importing waste started locally sourcing it. The imported plastic mist was burned, as not all plastic can be recycled, and they convinced the Malaysian government to allow them to clean the waste, which they did because they needed waste.

The waste they had did not satisfy their capacity of a hundred thousand pounds in a year, causing ResourceCo to outsource waste. The government trusted this company to provide a free cleaning service that exporters are not paying for, but the plastic waste processed contained electronic waste with shredded plastic components and textile waste, which are then mixed. This reveals that these sorts of materials are being mixed into PEF and then burnt in cement plants.

Malaysia also has the guidelines on co-processing in terms of emissions monitoring since cement plants produce hazardous toxic gas emissions. The emissions from all these heavy metals, HCL, and toxics substances must be monitored a minimum once per year or in some cases twice a year. This leaves the rest of the days of the year uncontrolled. This offers the possibility to control the mix of waste and the number of emissions to be adequate on the day these are tested. A continuous emission monitoring system is in place, but it does not work.

Requests to the Malaysian Government: 

  1. Prevent dumping by ending waste colonialism.
  2. Stop waste trade and ban the trade of waste-based fuels.
  3. Ensure full traceability and transparency of waste treatments. Currently checking is complicated by the use of different HS codes and fraudulent reporting.
  4. Reinforce monitoring and enforcement measures to stop the illegal waste trade. Malaysia’s customs department cannot currently check all the containers coming in. To solve these problems, wasting export needs to just stop and all countries need to manage their waste.
  5. Prioritize reduction and avoid false solutions like using qualified power plants. A memorandum to the Malaysian government to stop co-opting plastic-based imports which are repackaged as feedstock has been recently sent and we are waiting for a response.

Is RDF Regulated under the Basel Convention?

Jim PUCKETT | Executive Director and Founder, Basel Action Network

The law to regulate RDF is under discussion now at the Basel Convention, which does not mention refuse-derived fuel anywhere. It is important then to ask if RDF escapes the Convention controls or whether it is controlled.

The Basel Convention does not control all trade nor all waste trading. What it does control is hazardous waste which is listed in Annex VII, Annex I, and Annex III or as “other waste” in Annex II. The differences between these are that hazardous waste is impacted by the Basel Ban Amendment, while “other waste” is not. The way to fall outside of the Basel Convention controls is not to declare material as a non-waste, getting out of the Convention’s scope. It is possible then to declare something as waste, which is neither hazardous nor wastes falling under Annex II or other waste.

Annex IV. First, RDF must be categorized as one of the wastes under the Basel Ban Amendment to assess whether it escapes its control. According to the text of the Basel Convention, “wastes” are defined as substances or objects that are disposed of or required to be disposed of; while “disposal” is defined as materials or objects going to any of the operations on Annex IV. Annex IV of the Convention includes R1 “Use as a Fuel”, which would make RDF a waste. In the EU, RDF is under the waste catalogue as 19 12 10 “combustible waste (refuse drive-fuel)”. Various countries and the EU itself are starting to adopt a criterion called “when waste ceases to be a waste”. This is a reason for concern because countries trust this listing as an indicator that the waste is no longer such, despite it might be listed in the Basel Convention. This leaves countries free to decide whether how they process RDF makes it cease to be a waste. Therefore, it must be a hazardous waste because waste is not enough.

Annex VIII. Annex VIII contains a list of waste presumed to be hazardous based on the real fundamental test of Article 1.1.A, defining materials contain a hazardous constituent (Annex I) and at the same time hazardous characteristic (Annex III). RDF is not listed on Annex VIII and neither falls under the definition of Article 1.1.A. It is complex to establish whether it has either a hazardous constituent or characteristic because the content of waste collected from municipalities or commercial waste is hard to guess. At any given point in time, RDF could be very hazardous. To assess if RDF contains heavy metals, or pesticides and so constant testing would be necessary.

Annex II. When the Basel Convention was formed, Annex II was created to control but not fully hazardous waste that maybe be coming from household waste and residues. Annex II is now achieving new importance because new items will be added for RDF, including waste collected from households (Y46). The collection from households can be an item for disputes since RDF can originate from production waste, commercial sources, or be manipulated so that proportions of waste change. If it does not classify as Y46, it could be the new Annex II listing for Plastics, Y48, which is mixed and contaminated plastics. As this is composed mostly of plastic, it is valuable for it can be burned as a form of fossil fuel. This fact can also be contested.  RDF is clearly a waste at the global level, but countries at a national level can arbitrarily say it no longer is. Unless it can be proved, RDF will not be considered hazardous waste. RDF is not fully on Annex II and the current ambiguity is ripe for exploitation.

Recommendations to fix this ambiguity: 

  • RDF should be nominated by a Party for entry into Annex VIII or at the very least – Annex II and then a Guidance Doc.
  • People should cease the “caveman” mentality of Burning Wastes – it is killing the planet with C02 and other emissions.
  • Countries and local governments should begin to pass measures to forbid the production of RDF and other waste burning operations.
  • It is not environmentally sound management.


Q: There is no specific guideline on RDF and specified HS code for transportation from one country to another country. Plastic comes in the form of RDF and is being exported to various countries.

What are regulatory measures being adopted in Malaysia and Indonesia to control this waste that has no HS code? How can national measures prevent the entry of RDF from a developed country to a developing one?

Lee BELL: What would be very beneficial is for the Basel Convention to cover this issue so that parties are compelled to implement it. An initial strategy would be to extend the Basel Ban Amendment to Annex II and to clearly distinguish between Y48 and Y46. The European Union, Switzerland and Liechtenstein have already done so. This requires therefore for countries to ratify the Basel Ban Amendment.

Testing is also a key component of this strategy. Customs importers can perform some analysis of the incoming material, although it can be complicated for some household waste. Determinations can be made at the national level through sampling and then determine whether a specific import has the characteristics or constituents of hazardous waste. This will allow countries to control their own borders for these types of waste and unilaterally declare a hazardous material and subject it to some testing. Another option is to require laboratory certificates from exporters as a demonstration that there is no hazardous material before it ever leaves the country of export. This also places the cost of the analysis on the exporting country.

Q: Nigeria has been inundated by requests to allow imports of RDF into the country. Not knowing the composition of these materials, we are facing a dilemma as we are aware of the risk to allow plastic waste into the country under the guise of RDF.

Lacking the capacity to test and analyze these products, the material data safety sheets we request are not enough to make us comfortable. Likely, exporters do not tell the truth. How can we deal with this problem?

Lee BELL: This problem is real as waste exporters conducting their own testing and telling importing countries what is contained in that material cannot be fully trusted. Independent audits could be provided by third parties, like national auditing agencies, to analyze it for the country of export. Following the precautionary principle, the material would be prohibited from entering the country under any circumstances.

The best way to do that would be to have clear, definitive statements through the Basel Convention about what this material is, what it constitutes and what its potential for being hazardous is. It is difficult to define refuse-derived fuel or process engineered fuel through the Convention and currently, there is much freedom allowing many actors, even companies, to develop their own names around certain types of fuel.

Given that not many international standards apply to these, the Intra-EU Trade for instance employs some standards to limit the chloride and mercury contents in the materials. This measure is taken mainly because these can damage the cement film rather than being taken as a measure to prevent hazardous waste for human health. The best solution would be to have a transparently negotiated agreement at the Basel Convention level establishing what the material is and how it should be handled.

Q: Nigeria is also challenged by private sector operators claiming to have received some sort of incentive from developed countries to establish facilities to produce RDF in the country. This would mean that Nigeria allows in an unknown waste that will be handled by these facilities.

We are opposing this because Nigeria is already struggling to manage the waste it generates internally. For us, it is puzzling why developed countries cannot use and produce RDF in their countries. Addressing the issue under the auspices of the Basel Convention is thus necessary and urgent.

Yuyun ISMAWATI: The Basel Convention must clarify what is the HS code considered for PEF and RDF because HS codes currently represent an entry point for waste as RDF. Parties will then have a clear idea of what HS codes should be prohibited. In Indonesia, at the moment there are no prohibitions to import 3825 although the Indonesian law already prohibits the importation of waste. Importations under the name of HS 3915 for plastics and 4704 for paper craps are regulated under the so-called “importing waste as raw material for industrial processes” measure, which allows them to enter the country.

The RDF policy in every country should be restricted and no regulatory support given to RDF. Introducing RDF as an alternative fuel will be very dangerous as many developing countries cannot monitor POPs and cannot anticipate waste entering countries as a form of mixed waste. Developing countries should follow the example of Nigeria and say no to these materials. It is in the interest of exporters to falsify declarations and unless declarations are honestly written, it is impossible to know what is inside containers. Stricter shipping requirements and strengthened checks at the ports and at customs must be coupled with government regulations to forbid unwanted materials from other countries.

Q: The USA is a major exporter of plastic waste. What are the challenges and consequences for the Basel Member countries receiving waste from the USA as non-party of the Basel Convention?

Jim PUCKETT: The Basel Convention forbids parties to trade with non-parties. The only exception to that, under Article 11, is to establish an agreement in a bilateral or multilateral way. That agreement has to be the environmental equivalent of the Basel Agreement, which in most cases is the OECD Agreement. The USA can thus trade plastics with other OECD countries. After the Basel Plastic Amendments were adopted, the USA objected to the OECD, which forbade them to be traded in the OECD regime. The USA is then not allowed to trade Y48 plastic mix, except Canada, and Basel still applies.

Recently it has been discovered that PVC, which has an HS code, is entering Mexico from the USA. Mexico has been asked by BAN to explain bringing the issue in front of the Basel COP. The USA is moving Y48 and PVC all over the world because air exporters have no liability in the country since it is not a Basel Convention Member. Since the most wasteful country on the planet is not part of this treaty, it is up to receiving countries to just say no to incoming materials.

Q: In Africa, most of the countries that are targeted for exports are those that are not a party to the Bamako Convention. A solution could then be to access the Bamako Convention because then traders will have to pay huge compensation to countries.

Q: How can countries prevent illegal traffic and trade without having POPs Laboratories to identify the contents of POPs in the waste?

Jim PUCKETT: The Chinese National Sword policy was put in place because China, after several years as the world’s first importer of waste, realized the value they extracted from waste was lower than its costs. Costs are economic, but also ecological, as the loss of our groundwaters, and related to health. Every country should be reflecting on this decision and learn its lessons. Laboratory analysis should not even be a concern if solid waste or hazardous waste is prevented from entering countries.

Lee BELL: Prevention is better than cure. The precautionary principle should be applied and block anything from being imported and then becoming household waste is better so. The Basel Convention needs to clarify in the technical guidelines and in the related annexes, but governments should also take action before the outcomes of the Convention are operational. Governments can act unilaterally and protect their own borders as China did.

Q: For Cameroon, even as Party to the Bamako Convention, the main challenge is illegal to trade. This shows that enforcement at the national level is important.

Jim PUCKETT: Ratifying Convention must be coupled with enforcement in national legislation, which allows for prosecution of perpetrators. The Basel Convention helps identify what constitutes illegal traffic but then it is a national law that allows acting upon it through judicial punishments. If illegal exports of these materials represent a jailing risk, people will quickly refrain from doing it. Prosecuting the crimes is what makes a difference in the force of the Conventions.

Closing Remarks

Lee BELL: We need to move away from these cynical waste exports schemes and start dealing with our own waste domestically.

Yuyun ISMAWATI: Refuse-derived fuels are a different form of pollution, but they are even worse because it converts visible pollution into invisible pollution. Following the precautionary principle in that regard is best.

Mageswari SANGARALINGAM: RDFs are also coming into paper waste imports because of residual waste. We need to reduce the waste we are generating.

Jim PUCKETT: We have been producing way too many plastics, and they are inherently not circular. The industry wants to triple the amount of plastic in the next ten years, the only way out is to saying that burning them is the green thing to do. It is not. This logic needs to be looked at with great skepticism.




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