The Hidden Plastic Waste Exports, the Case for Basel Convention Controls on RDF and Textiles | Road to 2025 BRS COPs

About this Event

As governments and stakeholders prepare for the Basel Convention Conference of the Parties in April May 2025, and for the resumed fifth session of the Intergovernmental Negotiating Committee to develop an international legally binding instrument on plastic pollution in August 2025, global attention is on transboundary controls on plastic waste exports and two important waste streams that have been overlooked: Refuse Derived Fuel (RDF) and textile waste.

RDF consists of 30-60% mixed plastic waste and is destined to be burned in cement kilns, thermal power plants and incinerators, yet few parties accurately classify it as plastic waste using Basel waste codes and its export goes largely unrecorded. Similarly, around 60% of all textiles are made of synthetic polymers but in their waste phase are rarely classified as plastic waste with appropriate Basel codes.

This event seeks to shine a light on these hidden plastic waste exports and how they can be brought into compliance with the Basel Convention.

Road to 2025 BRS COPs

In the lead up to the 2025 Meetings of the Conferences of the Parties to the Basel, Rotterdam and Stockholm Conventions, taking place from 28 April to 9 May 2025 in Geneva, the Geneva Environment Network is collaborating with various partners, including the BRS Secretariat, for a series of events providing information on preparations and facilitating dialogues on key issues to be discussed at the meetings.

Speakers

By order of intervention. 

Therese KARLSSON

Science and Technical Advisor, IPEN

Lee BELL

Technical and Policy Advisor, IPEN

Jane BREMMER

Chair, Toxics Free Australia

Leslie ADOGAME

Executive Director, Sustainable Research and Action for Environmental Development (SRADev), Nigeria

Ieva RUCEVSKA

Senior Expert, GRID-Arendal

Semia GHARBI

Chairperson, Association de l’Education Environnementale pour les Futures Générations

Highlights

Video

Summary

Setting the Stage: Making the hidden plastic waste exports visible

Therese KARLSSON | Science and Technical Advisor, IPEN

• The commonly reported statistics on plastic waste trade rely heavily on a single category from a large trade database, which significantly underrepresents the actual scale of global plastic waste movement. This narrow classification fails to include major plastic-containing waste streams such as textiles, plastic-contaminated paper bales, and electronics, thereby overlooking a large proportion of the plastics that are traded globally.
• Synthetic textiles, which make up around 70% of all textiles, are essentially plastics and thus carry a wide range of hazardous substances beyond just the polymer backbone. These substances include toxic chemicals such as flame retardants, bisphenols, arsenic, lead, mercury, and dioxins, making their trade particularly concerning for both health and environmental reasons.
• When a broader scope of plastic waste is considered—including synthetic textiles and plastics in paper bales—the landscape of exporters changes dramatically. Initial data may suggest Japan as the primary exporter to non-OECD countries, but more inclusive data reveal that the European Union or the United States might actually top the list, depending on how various waste categories are accounted for.
• Even with this broader approach, significant streams of plastic waste remain unaccounted for in trade data. One notable omission is refused derived fuels (RDF), which are known to spread hazardous chemicals and are a growing concern in plastic waste management. Addressing these hidden waste flows requires stronger recognition and classification under international frameworks like the Basel Convention.
• For the upcoming Conference of the Parties (COP), specific recommendations have been submitted to better regulate hidden plastic waste streams. These include proposals to define RDF and similar waste-derived fuels as hazardous waste and to ensure stricter control over synthetic textiles, which are often overlooked in current regulatory frameworks.
• Within the ongoing plastics treaty negotiations, it is critical to establish global controls that encompass the transboundary movement of plastics throughout their life cycle. This includes not only waste but also products containing plastics, reinforcing the need for stronger international coordination and oversight.
• The key to tackling these hidden flows is the implementation of robust transparency and disclosure requirements. Knowing what hazardous chemicals are present in plastics is vital for waste management, regulatory enforcement, and consumer awareness. Strengthening these provisions in the treaty would help close major regulatory gaps and ensure better protection for human health and the environment

What is RDF and why is it a problem?

Lee BELL | Technical and Policy Advisor, IPEN

• Refuse derived fuel (RDF) is a mixture of wastes leftover following recycling from material recovery facilities or for which there is no recycling available. RDF is the outcome often for a lot of waste materials that have no recycling options available for them in a local area. Typically, RDF consists of around 35% mixed plastic waste plus synthetic (plastic) textiles and rubber (usually a synthetic plastic mix), resulting in about 50% mixed plastic waste in the refuse derived fuel.
• Plastic waste is also combined with paper, cardboard and timber wastes, other types of textiles, and other sorts of combustible wastes including some sorts of plant, fibers and other materials. Together, the plastic and the other combustible waste are shredded and then converted either into bales or pellets, they can form a pelletized form or a material called fluff, which is the shredded form of RDF which has not been bailed and is simply transported and fed into the end processes where they’re burned as shredded RDF.
• Pellets can be of all sizes, from the size of a fingernail to larger than a hand palm.
• RDF is produced and burned for three key factors:
  • Waste diversion. Many local governments, state governments, regional governments, have issues with waste build up, landfills, reaching capacity and so on and they want to divert waste from landfill. In some cases, authorities can receive some form of credit for that waste diversion.
  • Cheap fuel. For the end users such as cement kilns, it’s a cheap fuel, costing less than traditional fossil fuels and in some cases, they’re even paid to take the material.
  • Obtaining carbon credits. End users can obtain carbon credits because a certain percentage of these bails has a biogenic origin (the paper, the cardboard, the shredded wood etc). The plastic is made from fossil fuels and doesn’t have a biogenic origin, but they can obtain some credits and claim for their advertising purposes that they’re reducing their carbon footprint.
  • Additionally, local governments are keen to supply waste for RDF as it’s a landfill diversion and it can look like recycling has occurred.
• Therefore, RDF is typically burned as a fuel in cement kilns, but also increasingly in waste incinerators, industrial boilers, pulp mills for paper production and thermal power plants as a substitute for coal. Smokestack industries claim that burning RDF reduces their carbon emissions by replacing a certain amount of fossil fuel like gas or coal.
• This system is based on a controversial accounting system, and in reality, burning plastic waste is burning fossil fuels as plastics are made from oils and petrochemicals.
• RDF is a problem for several reasons:
  • Generation of toxic emissions. Burning mixed plastics in the RDF generates many toxic emissions including dioxins, PFAS, and other unintentional POPs (UPOPs) due to the cocktail of chemical additives that are added to plastics in their manufacturing and use phase. The end users such as cement kilns, pulp mills, and power plants are not generally equipped to capture the emissions and were not designed to filter out these types of pollutants, which end up in the environment and in the food chain.
  • Exploitation of a loophole in plastic waste export bans. Exporting RDF under the guise of a low carbon fuel allows wealthy countries to exploit a loophole in plastic waste export bans and send mixed plastic waste to non-OECD countries without prior informed consent, and that’s one of the key problems with the Basel convention.
  • Rising dioxide emissions. On the issue of emissions, a series of stack tests were conducted at a cement kiln. With the increases and further substitution of RDF in place of traditional fuels, there will likely be rising dioxide emissions from these facilities.
• The Basel Convention is intended to regulate harmful waste exported for burning, yet it remains silent on the classification of RDF. Some suggest that RDF is a fuel product and not a waste, and therefore should not be regulated by the Basel convention. In reality, RDF is mixed plastic wastes with other non-plastic wastes and it should not be exported without hazardous waste permits and notification to the importing country with prior informed consent as the convention requires.
• Until the Basel Convention explicitly lists RDF as a mixed plastic waste with a specific waste code (Y48 or A3210 or a new dedicated code, which would be even better), countries will remain at risk of unknowingly importing hazardous plastic waste in disguise.
• If RDF was classified as Y48, it would still be difficult to track the volumes because it would still be under an umbrella of mixed plastic waste and you wouldn’t be able to discern which fraction of that was RDF, but it would allow for prior informed consent, bring the Basel Ban Amendment into effect, prevent waste dumping from wealthy countries onto developing countries and there would be stricter controls.
• The Basel Convention should consider the creation of a dedicated code at the upcoming COP, allocating a new code for RDF so that the total volumes and the countries of import, export and destinations can be tracked, starting to get a handle on the full scale of the problem.

Current known RDF exports and ways forward

• RDF movements between countries in South-East Asia are known, but the amounts aren’t quantified. The open-ended working group (OEWG) stated that the quantity of waste exported as RDF is very significant and that the United Kingdom alone was exporting over 1.5 million tons a year. The INF document 29 (UNEP.CHW.OEWG.14/INF/29) suggested reviewing whether there may be benefits in adding a new waste code for RDF.
• At a minimum in the short term, the convention must acknowledge that RDF and similar substances are a waste requiring regulation, and no product.
• RDF must be subject to prior informed consent in transboundary movement, and at a minimum coded Y48 or A3210 requiring permitting of volumes, origin and destination and subjecting it to the Basel Ban amendment.
• Ideally it should be given a specific waste code to allow direct tracking of exported volumes so that it’s not hidden under broader umbrella categories of other wastes such as Y46 (household waste), which disguises the true extent of the RDF trade.
• In the medium to long term, the trade in RDF should be prohibited as it is not environmentally sound management. Cement kilns and other processes are already moving in some locations to hydrogen, a much cleaner fuel while burning plastic waste and other waste for energy is a step backwards.

RDF in Australia and the Asia-Pacific region

Jane Bremmer | Chair, Toxics Free Australia

• Toxics Free Australia monitors plastics, chemicals, and waste in relation to their impacts on human health and the environment, ensuring that Australia complies with key international conventions like the Basel, Rotterdam, and Stockholm Conventions. The organization collaborates with colleagues in the Asia Pacific region, particularly on the plastic waste trade, and has produced reports examining Australia’s waste management policies, exports, and the regional impacts of its plastic waste ban.
• Historically, Australia—similar to many OECD countries—exported the majority of its plastic waste to the Asia Pacific region. Due to close geographical and economic ties, Australia’s waste management practices have a direct impact on this region. Domestic policies have increasingly led to waste-to-energy outcomes such as chemical recycling, incineration, and the production of refuse derived fuel, particularly as a response to the 2019 waste export ban.
• The 2019 waste export ban, introduced after China’s move to expose plastic dumping, led to stricter regulations allowing only single polymer plastics or processed engineered fuel (PEF) to be exported. These measures institutionalized the conversion of waste into fuel as a primary waste management approach in Australia. The policy shift significantly reduced plastic waste exports.
• ResourceCo, a major player in Australia’s RDF production, has had large operations in Malaysia and was previously active across the Asia Pacific region. Following the ban, Australia ramped up research, policy reform, and industry efforts to promote RDF markets and incineration projects in the region. The intention was to foster a demand for RDF as a fuel source, especially in Asia.
• With the Basel Ban Amendment in place, ResourceCo began shifting toward converting textiles into RDF for combustion in Malaysia. This move reflects broader efforts to continue waste trade with Asia despite tighter export restrictions. The processed engineered fuel classification as a hazardous waste under Australian law was a positive development, aligning with Basel obligations and requiring a Y48 hazardous waste code for export permits.
• While the new hazardous waste classification halted some of the industry’s RDF export projects, it also disrupted the growing push—particularly by the cement industry—to use RDF as an alternative fuel. The use of RDF in cement kilns is problematic, given that these facilities are not designed to burn such heterogeneous materials, leading to unpredictable and potentially harmful emissions.
• In Western Australia, concerns are especially high due to the lack of transparency and weak regulatory oversight in the cement industry, which includes the largest cement operation in the southern hemisphere. There is limited public access to information about fuels used or emissions produced, making the expansion of RDF use in this sector a major public health and environmental concern.
• Following the PEF hazardous classification, domestic RDF production in Australia has surged, with many new facilities now turning waste into fuel. Australia’s weak waste management system, historically shaped by the waste disposal industry, is now driving a significant expansion in incineration and chemical recycling infrastructure. This rapid buildout suggests much of the RDF previously meant for export may now be diverted to local burning facilities.
• Another emerging concern is the export of recycled plastic pellets, which currently operate without any regulatory oversight in Australia. Unlike RDF, these exports require no permits, monitoring, or impact assessments. This lack of regulation presents a loophole, raising fears that recycled plastic pellets may become a covert channel for continuing plastic waste exports to the Asia Pacific, despite their potential toxicity.
• Australia’s overarching waste policy includes an 80% resource recovery target by 2030, which is contributing to the aggressive promotion of waste-burning infrastructure. As communities around the country begin pushing back against this pollution threat, there’s an opportunity to shift toward a more sustainable, zero-waste system and to support the Global Plastics Treaty in capping plastic production and detoxifying material supply chains.
• Recommendations emphasize the need for a ban on waste imports into the Asia Pacific region to protect vulnerable communities from corruption and environmental harm associated with the waste trade. National-level bans on plastic fuel and RDF exports are called for, along with broader classification of RDF and similar fuels as hazardous under the Basel Convention. Australia’s decision to apply the Y48 code to PEF is seen as a positive model for others to follow.
• There is a push for the complete suspension of RDF use due to its toxic nature, and a call for cement kilns to transition directly to clean, renewable energy rather than relying on RDF. Additionally, a specific Harmonized System (HS) code for RDF is needed to ensure proper tracking, regulation, and restriction of its trade across borders.

Experiences from Nigeria with RDF and Other Plastic Waste Imports

Leslie ADOGAME | Executive Director of Sustainable Research and Action for Environmental Development (SRADev) Nigeria

The Nigerian Situation

• The population of Nigeria consists of about twenty million people, with a rapid urban growth. Between 30 and 60% of municipal waste remains uncollected in major cities. Less than 10% of plastic waste generated is recycled. Nigeria faces a severe plastic waste problem in both urban and coastal areas. Currently, there is no national regulation for the plastic waste sector, and in Africa, Nigeria ranks 2nd highest for import and use of plastic. Additionally, there is inconsistent data tracking and classification, with chronic underfunding of waste management systems.
• Nigeria is among the top ten countries producing the largest amounts of mismanaged plastic waste, which mostly comes from the EU countries.
• Since 1989, Nigeria has ratified the Basel Convention, the Basel Ban Amendment and the New Plastics Amendments. Nigeria has signed, but not ratified, the Bamako Convention. The regulatory framework is not yet up to date in terms of plastics risk management.
• The exports of plastic waste to African countries from the top 7 exporters (Japan, USA, Netherlands, Germany, UK, Belgium and Australia) reached 9,476,060 kgs in 2021, particularly in the form of Y48 waste. Nigeria was one of the 6 top receiving countries in Africa.

Illegal traffic of waste into Africa: Plastic waste export (PVC) from USA into Nigeria in 2021

• The Basel Action Network (BAN) has been tracking plastic wastes exports from the US to Parties. It found that a substantial volume of Y48 plastic waste (PVC) is exported to Nigeria without prior informed consent controls or in defiance of existing trade prohibitions.
• In Africa, Nigeria followed by Ghana top the list of countries that continued to receive illegal traffic on plastic waste export from the USA. Since 2021, huge volumes continue to come.
• Illegal waste comes from the US as well as some other OECD countries.

Refuse derived fuels (RDFs) and prior informed consent

• The case of Nigeria is worrisome as it comes to RDFs. Recently the SRADev got to know that the government of Nigeria will be receiving some non-hazardous waste from the EU. It found out that RDFs, textile waste and racks would be part of the new waste received.
• RDFs have a huge energy potential. Two major cement facilities need it, so the potential is quite high in terms of demand by those facilities.
• This conversation about the status of importation of RDFs into the country had been ongoing locally.  When the DRADev learnt about it, civil societies were immediately interrogated. A coalition of NGOs came together and immediately did a press conference, released the media because of the risk in accepting RDF imports.
• Looking at it from the point of view of Waste colonialism, it is as if the burden was shifting from the EU to Nigeria, although Nigeria lacks infrastructure to handle, process and monitor RDFs.
• The emissions and ash from RDFs bring a lot of toxic pollution. This contradicts Nigerian Nationally Determined Contributions (NDCs) commitments and climate goals, particularly knowing its public health and environmental justice implications.
• The SRADev releases a lot of media outcry and this case drew quite a lot of attention on the subject matter of RDF.
• Governments sometimes have different views on the nature of these wastes than NGOs, civil society or communities. After the media release, the government justification was that they were not importing plastics: “We’re not importing plastics. We are importing RDFs, textile and rags because we need them for cement production, blankets, baby shawls, sweaters, knitting wool production and others.”, and “Nigeria is following due process in applying for it, and we need the wastes because we need to produce cement, blankets, shawls because people are still having babies, and it’s not everybody that can afford to buy shawls from abroad”. It’s a different perception issue often amongst governments and regulators as to how they perceive these types of materials.
• Civil society in Nigeria urgently demands that the African governments individually interact with the regional Bamako convention, the regional convention on hazardous waste:
  • to prevent plastic waste being dumped in the region,
  • to protect the existing and new legislation upholding their right to a safe, clean and healthy environment that is toxics free,
  • to exercise their right to refuse shipments of plastic waste of all kinds and to modify the annexes of the Bamako Convention accordingly as was called foreign decision CB 3/8,
  • to stringently enforce existing legislation like the Basel and Bamako conventions, which restrict and at times prohibits waste imports, and undertake swift prosecutions and return-to-sender legal actions for illegal shipments,
  • to adopt national systems that allow waste pickers to be a part of all decision-making processes with a view to improving waste collection and management in Africa rather than importing waste from overseas,
  • to engage in ongoing discussions around a legally binding game-changing global plastics treaty, to ensure that it reflects the local plastic pollution realities within the region and that attempts are made to address the problems of plastic across its entire value chain, especially through a strict cap on the production of new plastic, and to forbid the use of single-use plastic.
• The call for action entails the following items:
  • Nigeria must align its waste policies with its developmental and climate goals.
  • The EU must ensure waste export policies uphold environmental justice.
  • The EU is urged to act responsibly by ensuring that its waste export policies (according to Article 41 of the regulation 2024/1157) did not place an undue burden on developing nations.
  • Waste trade controls applicable to RDFs and other plastic waste-based fuels need to be clearly communicated and applied.
  • It is needed to protect over 200 million Nigerians from worsening waste burdens. This is a much bigger concern than just harnessing the economic potential of RDF imports.
  • Lastly, it is of highest importance to engage with the EU on the need to suspend acceptance of RDF and related waste imports to Nigeria.

Environmental justice should be upheld. Developing countries like Nigeria don’t have the capacity to manage a continuous dumping of waste… We cannot continue to put economics above people and the environment. So far, the angle is purely economic. We need to use this opportunity to engage with the EU on the need to suspend acceptance of RDFs and related waste imports in Nigeria.

Textile Exports and Management Options

Ieva RUCEVSKA | Senior Expert, GRID-Arendal

• The plastic waste partnership under the Basel Convention acts as a collaborative platform to bring together relevant stakeholders in tackling the global plastic waste crisis. GRID-Arendal contributes to this effort by developing knowledge briefs focused on key issues, including textile waste, with the aim of supporting better-informed policy decisions through scientific insight and stakeholder engagement.
• Textile waste has been identified as a material of particular concern in UNEP’s 2024 Solid Waste Management Outlook, alongside e-waste, food waste, and end-of-life vehicles. The concern stems from significant challenges in collection, treatment, and broader waste management processes, which hinder the achievement of human health and environmental protection goals.
• The waste hierarchy remains central to textile waste management and emphasizes prioritizing prevention through product longevity, followed by reuse, recycling, and lastly, recovery or disposal. Prevention involves producing durable, high-quality clothing to extend product lifespans. Reuse—such as passing textiles from one user to another—must be clearly defined and regulated to avoid misuse. Recycling is pursued when reuse is not viable, while disposal should only occur when no other options are available.
• Despite this hierarchy, the reality of textile waste management remains heavily reliant on a “produce and dispose” model. Currently, only about 13% of textile waste is recycled through open-loop processes that repurpose materials in other sectors, like construction. Closed-loop recycling, where textiles are transformed back into new textile products within the same industry, accounts for merely 1%. Around 75% of textile waste ends up in landfills or is incinerated, with significant material loss occurring during production and collection stages.
• Within the textile production and consumption chain, reuse strategies such as trading, renting, borrowing, and swapping are already practiced and represent a closed-loop system. However, after their reuse, most second-hand textiles are discarded through dumping or burning. Open-loop systems allow material transfer across industries—for example, creating garments from PET bottles or using textiles as insulation—representing a cascading flow of material rather than full circularity.
• A major challenge in textile waste management lies in low collection rates, which vary significantly between regions. In areas with strong policy frameworks, such as Europe, collection is improving, especially through extended producer responsibility (EPR) schemes. Conversely, many developing countries experience low textile collection due to the limited market value of used textiles, despite the vital role of the informal sector in recycling other materials like plastic, glass, and metal.
• While progressive EPR policies improve collection, they may have unintended consequences such as encouraging overconsumption. In some cases, individuals may feel environmentally responsible for disposing of clothes properly, which leads to higher clothing turnover and more waste. Moreover, with the rise of online shopping, EPR systems must evolve to encompass both traditional retail and digital commerce platforms to remain effective.
• Various recycling and material conversion methods exist for textile waste, applicable in both open- and closed-loop contexts. Mechanical recycling works best for mono-materials like cotton or polyester and involves sorting, shredding, and reprocessing. However, the resulting fibers are shorter and weaker. Thermal mechanical recycling handles synthetic fabrics, like nylon, by melting and reprocessing thermoplastics, but this too degrades polymer quality and demands high material purity.
• More complex textile blends and composite materials, such as laminated textiles with glue layers, complicate recycling. These often combine synthetic and natural fibers, making separation difficult. Additionally, chemicals of concern embedded in textiles pose further obstacles. Chemical recycling methods like depolymerization and dissolution theoretically offer promising results but require large energy inputs and produce hazardous waste. These processes also currently lack standardized international guidelines, limiting their scalability and environmental safety.
• At present, only about 13% of textile waste is managed through chemical and thermal-mechanical recycling methods, while just 1% is recycled within a closed loop. This starkly illustrates the ongoing technological and systemic barriers that prevent widespread, sustainable textile recycling at scale.
• Textile waste is not only a local concern but also a transboundary issue due to its role in global trade. Second-hand textiles and textile waste are frequently exported from developed to developing countries, forming part of a global value chain. While the trade generates revenue and supports livelihoods, there is growing concern over environmental externalities, as the exported materials are often eventually incinerated or landfilled.
• Trade data shows that the European Union is the leading exporter of second-hand textiles by value, accounting for roughly 30%, followed by the United States, China, and the United Kingdom. On the importing side, the pattern is more varied. Pakistan and the European Union are top importers, with the EU re-importing for re-export. Many other importers are located in the Global South, including Malaysia, Kenya, India, Tunisia, the Democratic Republic of Congo, Guatemala, and Chile.
• The global pattern of textile trade highlights an imbalance where most second-hand textiles originate from wealthier nations, while the environmental and logistical burdens of disposal disproportionately fall on countries in Asia, Africa, and Latin America. This underlines the need for globally coordinated efforts to address the sustainability and fairness of textile waste management.

The Problem of Imports of Textiles and Other Plastic Wastes in Tunisia

Semia GHARBI | Chairperson of The Association of Environmental Education for Future Generations (AEEFG)

• Imports of second-hand textiles into Tunisia have existed since 1944 and play a social role by supporting decent living conditions for lower- and middle-class populations. Over the years, particularly up to 2024, the volume of these imports has significantly increased, with major exporting countries including EU nations such as Italy, Germany, and France, as well as Canada, Switzerland, the US, the Netherlands, Turkey, and Portugal.
• Tunisian legislation regulates the import of second-hand textiles through a decree that mandates imports be in their original state, sorted and packaged appropriately, with exceptions for certain fabrics like acrylic and polyester knitwear meant for fraying. However, the legislation is not particularly strict, allowing a wide variety of used items into the country, some of which are technically categorized as waste but still end up being sold in local second-hand markets.
• The decree includes categories like clothing, accessories, blankets, household linens, and furnishing articles, but also covers numerous miscellaneous used items. Despite certain products like shoes, toys, and handbags being classified as waste and not permitted, these still appear frequently in second-hand markets, indicating weak enforcement and regulatory loopholes.
• A 2005 amendment to Article 11 introduced the obligation to destroy non-compliant imports rather than reship them, typically through incineration. Since only a portion of imported textiles is suitable for the market, the rest often ends up burned, raising environmental concerns about toxic emissions, especially when such incineration occurs in community areas or near agricultural zones, where the full extent of pollution and its impact remains unknown.
• Tunisia also imports plastic waste under customs code HS 3915, with a significant portion originating from the EU. A case of illegal waste imports from Italy, involving municipal waste, took two years to resolve and highlighted persistent issues with transparency and governance around waste trade. Despite EU commitments to limit waste exports, certain non-OECD countries, including Tunisia, remain recipients, with unclear criteria and management practices.
• Tunisia sometimes serves as a transit point for waste shipments between other countries, not all of which are properly accounted for in national records. Discrepancies between Tunisia’s import figures and those reported by partner countries, particularly EU exporters, raise serious concerns about data reliability, potential corruption, and illegal trade practices.
• Trade records from Tunisia’s National Institute of Statistics show consistently higher volumes of waste imports than those acknowledged by exporting countries. This mismatch suggests a lack of transparency, especially concerning how the waste is ultimately handled—whether it is processed, incinerated, or managed in other ways remains largely unknown.
• Additional issues arise from waste entering illegally from neighboring countries like Libya. The volume of such undocumented imports further complicates Tunisia’s capacity to manage its waste effectively, especially given the limited tracking of how this waste is handled or where it originates, such as unexplained plastic waste reportedly from Libya or Yemen.
• Trade codes used to document waste imports and exports often lack specificity, making it difficult to identify the exact nature of the materials being traded. This ambiguity hinders efforts to achieve clarity and control over waste flows, both for plastic and textiles, and makes it harder to address illegal practices and ensure accountability in the waste trade system.
• The incineration of second-hand textiles in Tunisia is a widespread practice due to the sheer volume of unsellable items. This process releases numerous toxic chemicals, with incineration sites spread across the country, including near populated and agricultural areas. The prevalence of this informal business model, combined with the environmental impact, underscores the urgent need for sustainable management solutions and improved regulatory enforcement.

Documents

• Presentations made during the event

Links

• Plastic Waste | Basel Convention
• Road to 2025 BRS COPs
• Global Waste Management Outlook 2024 | UNEP | February 2024
• The Plastics Treaty in 2025: IPEN Views on the Chair’s Text | IPEN | March 2023
• Plastic Waste Trade: The Hidden Numbers | IPEN | March 2023
• Plastic Waste Fuels | IPEN | March 2022
• Malaysia: Repackaged Waste Imports | IPEN | March 2022
• Process Engineered Fuel – Fuel Product Or Plastic Waste Export In Disguise? National Report on PEF Importation and Use in the Philippines | IPEN | March 2022