INF/TE/IDP/RD/79* 
1 December 2022  
(22-8957) Page: 1/7 
  Original: English/anglais/inglés  
 
  
UNOFFICIAL ROOM DOCUMENT1 
 
DIALOGUE ON PLASTICS POLLUTION  
AND ENVIRONMENTALLY SUSTAINABLE PLASTICS TRADE  
STATEMENT BY CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW  (CIEL) 
Pre-plenary  Meeting 17 November  2022 
 
 
DOCUMENT DE S ÉANCE NON OFFICIEL1 
 
DIALOGUE ON PLASTICS POLLUTION  
AND ENVIRONMENTALLY SUSTAINABLE PLASTICS TRADE  
STATEMENT BY THE FORUM ON TRADE, ENVIRONMENT & THE SDGS (TESS)  
Pre-plenary  Meeting 17 November  2022 
 
 
DOCUMENTO DE SALA NO OF ICIAL1 
 
DIALOGUE ON PLASTICS POLLUTION  
AND ENVIRONMENTALLY SUSTAINABLE PLASTICS TRADE  
STATEMENT BY THE FORUM ON TRADE, ENVIRONMENT & THE SDGS (TESS)  
Pre-plenary  Meeting 17 November  2022 
 
_______________  
  
 
* In Original language only/En langue originale seulement/En el idioma original solamente.  
1 Documents issued in the RD series are not official WTO documents. They usually appear in their 
language of submission and will not be translated systematically into the working languages of the WTO. They 
are intended for use in WTO meeting rooms and are attributed an unofficial symbol for archiving purposes only.  
Les documents de la série RD ne sont pas des documents officiels de l 'OMC. Ils ne paraissent 
généralement que dans la  langue dans laquelle ils ont été communiqués et ne seront pas systématiquement 
traduits dans les langues de travail de l'OMC. Ils sont destinés aux salles de réunion de l'OMC et une cote non 
officielle leur est attribuée à des fins d'archivage.  
Los docume ntos de la serie RD no son documentos oficiales de la OMC. Por lo general se distribuyen en 
el idioma en que han sido presentados y no se traduce n sistemáticamente a los idiomas de trabajo de la 
Organización. Se distribuyen para su uso en las salas de reunión de la OMC y se les asigna una signatura no 
oficial a efectos de archivo únicamente.  INF/TE/IDP/RD/79  
 
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WTO Dialogue on Plastics  
 
CIEL’s Written Statement  
 
17th of November 2022  
 
STATEMENT FOR DISTRIBUTION  
 
 
Your excellencies,  
Ladies and gentlemen,  
Distinguished members of the WTO,  
 
Thank you for the invitation to this Pre-plenary meeting of  the WTO’s Dialogue on Plastics.  
 
On behalf of the Center for International Environmental Law (CIEL),2 we elaborate our responses to 
the following technical questions provided in the agenda (INF/TE/IDP/CN/9):  
 
I. On Single Use Plastics (SUP) and products  
 
What are the key criteria to be considered when identifying single used plastics (SUP) and 
products targeted by Trade -related Plastics Measures (TrPMs)? Are there examples of 
particularly problematic SUP and products that would fit these criteria?  
 
The fact  that some plastics products are designed for "single use" is not the foundational problem  
with what we commonly refer to as SUP. Some durable plastic products, such as a plastic chair, 
could be said to be designed for "single use", but the use of that ite m should last for many years. 
When we compare this to plastic packaging, or throw -away utensils that are designed to be disposed 
of, the difference is that the latter are meant to become waste very shortly after their initial (single) 
use. The key factor h ere is the " extent of usage " before expected disposal (e.g. it can be said that 
the chair is designed for long -term single use, but plastic packaging, containers, and plastic cutlery, 
are designed for very short term, single use).   
 
Without a compelling r eason for short -term (e.g. specific medical uses with concerns over 
sanitization - such as ostomy, or respiratory equipment, syringes, IV bags and tubes etc. - where 
identifying adequate alternatives might actually be challenging), single usage SUP needs t o be 
urgently targeted for phase -out and substitution. The substitution can be done through systems -
design  alternatives ,3 or through better, more long -lasting sustainable material  substitutes or 
alternatives that can be used multiple times.   
 
The arguments regarding the unsuitability of SUP cannot be divorced from the arguments - too often 
ignored - on the viability of plastics recycling. If plastics recycling was easy and benign, then perhaps 
SUP could be ju stified in a greater number of applications. However, a closer modern examination 
of plastics recycling has revealed a frightening array of fundamental problems.4  
 
2 CIEL would like to thank Mr. Jim Puckett, the Executive Director of the Basel Action Network, for his insights 
and important contribution in the preparation of this Statement.  
3 See e.g. S. Miller, M. Bolger, L. Copello, 2019. “Reusable solutions: how governments can help stop single use 
plastic pollution.” 3Ke el, Oxford, United Kingdom. https://rethinkplasticalliance.eu/wp -
content/uploads/2019/10/bffp_rpa_reusable_solutions_report.pdf ; Seats at  Risk, 2021. “Best practices to 
reduce and phase out single -use plastics in Europe”. https://seas -at-risk.org/wp -content/uploads/2021/06/Best -
Practices -ENG.pdf ; Wagner, C. 2022. “5 inspiring reuse and refill projects from the Global South” Greenpeace 
https://www.greenpeace.org/interna tional/story/55497/5 -inspiring -reuse -and-refill-projects -from-the-global -
south/ .  
4 See e.g. Human Rights Watch, 2022. “Turkey:Plastic Recycling Harms Health, Environment” 
https://www.hrw.org/news/2022/09/21/turkey -plastic -recycling -harms -health -environment ; International 
Pollutants Elimination Network (IPEN) , 2020 “Plastic’s toxic additives and the circular economy” 
https://ipen.org/sites/default/files/documents/plastics_and_additives_final -low-o-en.pdf  IPEN, 2021 “Plastic 
Waste Management Hazards”. https://ipen.org/sites/default/files/documents/ipen -plastic -waste -management -
hazards -en.pdf ; IPEN 2022. “How Plastics Poison the Circular Economy: Data from China, Indonesia and Russia 
and other s reveal the Dangers” https://ipen.org/sites/default/files/documents/ipen -plastic -poison -circ-econ-
v1_4w -en.pdf ; IPEN, 2021 ‘Widespread chemical co ntamination of recycled plastic pellets globally") 
https://ipen.org/sites/default/files/documents/ipen -recycled -plastic -pellets -v1_2.pdf ; Brock, J., Vo lvovici V., INF/TE/IDP/RD/79  
 
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Due to the enormous obstacles presented by the collection and recycling of plastic materials, SUP 
are antithetical to true circularity. Each time a SUP is discarded, the likelihood of a very linear 
negative externality is imposed: collection of such plastics is very difficult primarily due to the 
disincentive to do so as a result of a ve ry low waste value.5 This low valuation results in very limited 
infrastructure to achieve collection in most parts of the world. This is why plastic litter is so pervasive.    
 
However, even if SUP happens to be part of the very small percentage of plasti cs that can be, and 
is collected, then we are faced with the fact that the recycling itself is far from circular.6 This is due 
to a number of factors:  
 
(i) Plastics, as a material, are uniquely heavily laden with a myriad of chemical additives, 
many of wh ich are toxic and yet are not accounted for at end -of-life.7 
 
(ii) The recycling of plastics, without very expensive, energy intensive chemical processes 
(chemical recycling) is rarely a one -to-one operation, but results in recycling that is of lesser 
quality - down -cycling due to ever -shortening polymer chains at each recycling event.8 Thus, 
most recycled polymers require the addition of virgin plastic, which in turn further 
exacerbates both the climate and the plastics crisis.9 
 
It is for these reasons  and more,  that these products are to be targeted for elimination . The 
universe of the latter exception is thought to be very limited.   
 
Given the above, it is important not to focus on what are the worst SUP, but rather (i) which are the 
limited essentia l SUP that could remain in the market and (ii) by what criteria could any SUP be 
tolerated.  
 
So in short, two criteria to consider when assessing single used plastic are : (i) necessary or 
essential single used plastics ; and (ii) the compelling reason for this plastic product to be 
necessary or essential .  
 
One approach to regulate single -use-plastics products is using a "positive list" approach with the list 
of allowed plastics to be produced, and traded. And this list could include some conditions, and a 
few exceptions for necessary or essential uses.    
 
What are the key criteria to be considered when identifying environmentally sustainable 
and effective substitutes and alternatives to SUP and products targeted by TrPMs? Are 
there examples of particularly  desirable substitutes and alternatives to SUP and products 
that would fit these criteria?  
 
First, it is essential to understand the negative  life-cycle impacts  of plastic thoroughly in order 
to effectively compare substitutes or alternatives . These negati ve impacts include the fact 
that: 
 
Geddie, J., 2021. “The Recycling Myth: Big Oil’s Solution for Plastic Waste Littered with Failure. Reuters 
https://www.reuters.com/investig ates/special -report/environment -plastic -oil-recycling . See also CIEL’s 
Statement of the 18th of March 2022, and references therein, 
https://docs.wto.org/dol2fe/Pages/SS/directdoc.aspx?filename=q:/INF/TEIDP/RD24.pdf&Open=True .  
5 IPEN, 2021 “Plastic Waste Management Hazards”. https://ipen.org/sites/default/files/documents/ipen -plastic -
waste -management -hazards -en.pdf . 
6 See CIEL’s Statement of the 18th of March 2022, and references therein, 
https://docs.wto.org/dol2fe/Pages/SS/directdoc.aspx?filename=q:/INF/TEIDP/RD24.pdf&Open=True .  
7 See United Nations Environm ent Programme, 2021. “From Pollution to Solution: A global assessment of marine 
litter and plastic pollution “ https://www.unep.org/r esources/pollution -solution -global -assessment -marine -litter-
and-plastic -pollut ion; IPEN, 2021. “Plastic’s Toxic Chemical Problem: a g rowing public health crisis” 
https://ipen.org/sites/default/files/documents/ipen -problem -with-plastics -v1_5-en.pdf ; Hahladakisa J.N et 
al.2018. “An ove rview of chemical additives present in plastics: Migration, release, fate and environmental impact 
during their use, disposal and recycling” J Hazard Mater. 344:179 -199. doi: 10.1016/j.jhazmat .2017.10.014 .  
8 Warhurst, M. 2020. “Chemical recycling: Is it worth the energy?” ChemTrust https://chemtrust.org/chemical -
recycling/ . 
9 CIEL, 2019. ‘Plastics and Climate: the hidden costs of a plastic planet” https://www.ciel.org/wp -
content/uploads/2019/05/Plastic -and-Climate -FINAL -2019.p df; Schyns, Z.O.G., Shaver, M.P., 2020. 
“Mechanical Recycling of Packaging Plastics: A review” Macromolecular Rapid Communications, Vol.42,3 
https://doi.org/10.1002/marc.202000415 .  INF/TE/IDP/RD/79  
 
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(i) Plastic production most often equates to releasing carbon, sequestered as fossil fuel 
in the earth, into the biosphere and climate .10 This is the "original sin" of most plastics.    
 
(ii) Plastic production from extraction  (e.g. mowing down forests to create roads for 
fracking) through refining (e.g. the cancer corridors in Louisiana and Texas) and 
manufacturing (e.g further occupational and community hazard from emissions and 
residue chemical management) is highl y damaging to the environment, to workers, 
and communities .11 It is also energy intensive .12   
 
(iii) All plastics require additions of most often unknown and often harmful additives  
(including but not limited to at a collection/recycling stage).13 Until v ery recently the impacts 
of these additives in terms of their harm caused during production, use, and at end -of-life 
have been ignored. But increasingly, studies reveal that additives are a serious health 
concern, particularly when passed into food and dri nk, toys, and on to humans.14  
 
(iv) Most plastic recycling is a form of down -cycling by which the polymer chains shorten 
and degrade with each recycling, requiring the addition of virgin plastic to make the second 
use viable.15    
 
(v)  Plastics, due to t heir inability to break -down in the environment into benign materials 
equate to a long -term problem, either due to their toxicity, harm to fauna (e.g. ingestion), 
and unsightliness and damage to the aesthetics of nature and wilderness.16 This latter issue 
causes serious damage to the tourism industry.  
 
(vi) The breakdown of plastics into micro -plastics and the prognosis for a world where 
aquatic ecosystems and even our bodies routinely contain microplastics along with their 
toxicity (supported by studies), is frightening, particularly when one realizes that these 
micro -plastics are very difficult to collect or mitigate.17   
 
10 CIEL, 2019. ‘P lastics and Climate: the hidden costs of a plastic planet” https://www.ciel.org/wp -
content/uploads/2019/05/Plastic -and-Climate -FINAL -2019.pdf . 
11 UNGA 2021  Doc. A/76/207 “Report of the Special Rapporteur on the implications for human rights of the 
environmentally sound management and disposal of hazardous substances and wastes, Marcos Orellana” 
https://documents -dds-ny.un.org/doc/UNDOC/GEN/N21/201/78/PDF/N2120178.pdf?OpenElement .  
12 CIEL, 2019. ‘Plastics and Climate: the hidden costs of a plastic planet” https://www.ciel.org/wp -
content/uploads/2019/05/Plastic -and-Climate -FINAL -2019.pdf . 
13 CIEL, 2019. Plastic & Health: The Hidden Costs of a Plastic Planet, https://www.ciel.org/wp -
content/uploads/2019/02/Plastic -and-Health -The-Hidden -Costs -of-a-Plastic -Planet -February -2019.pdf  ;  IPEN, 
2021. “Plastic’s Toxic Chemical Prob lem: a growing public health crisis” 
https://ipen.org/sites/default/files/documents/ipen -problem -with-plastics -v1_5-en.pdf ; IPEN 2022. “Hazardous 
Chemi cals in Plastic Products: brominated flame retardants in consumer products made of recycled plastic from 
eleven Arabic and African countries”  https://ipen.org/sites/default/files/documents/ipen -toxic-plastic -products -
africa -v2_3w -en.pdf . See also references provided above in this Statement.  
14 Wang, Z., Weiesinger, H.,& Groh, K.J., 2021. “Time to Reveal Chemical Identities of Polymers and UVCBs”  
Environ Sci. Technol, doi: 10.1021/acs.est.1c05620 ; Health and Environment Alliance (HEAL), 2021. “Turning 
the plastic tide: the chemicals in plastic that put our health at risk” https://www.env -health.org/turning -the-
plastic -tide-the-chemicals -in-plastic -that-put-our-health -at-risk/. 
15 Schyns, Z.O.G., Shaver, M.P., 2020. “Mechanical Recycling of Packaging Plastics: A review” Macromolecular 
Rapid Communications, Vol.42,3 https://doi.org/10.1002/marc.202000415 ;  CIEL, 2019. ‘Plastics and Climate: 
the hidde n costs of a plastic planet” https://www.ciel.org/wp -content/uploads/2019/05/Plastic -and-Climate -
FINAL -2019.pdf .  
16 European Environment Agency, 2020. “Bi odegradable and compostable plastics - challenges and opportunities” 
https://www.eea.europa.eu/publications/bi odegradable -and-compostable -plastics/biodegradable -and-
compostable -plastics -challenges ; Break Free From Plastics, 2022.” Biodegradable and compostable plastics.” 
Plastic Solutions Review.  https://plasticsolutionsreview.com/biodegradable -and-compostable -plastics/ ; UNEP, 
2015. “Biodegradable Plastics and Marine Litter. Misconceptions, concerns and impacts  
on marine environments.” United Nations Environment Programme (UNEP), Nairobi. 
https://wedocs.unep.org/bitstream/handle/20.500.11822/7468/ -
Biodegradable_Plastics_and_Marine_Litter_Misconceptions,_concerns_and_impacts_on_marine_environments -
2015BiodegradablePlasticsAndMarineLitter.pdf.pdf?sequence=3&amp%3BisAllowed= .  
17 Swiss Federal Laboratories for Materials Science and Technology (EMPA), 2021. “Nanoplastics -- an 
Underestimated Problem?,” ScienceDaily,  https://www.sciencedaily.com/releases/2021/05/210504112641.htm  
; Koelmans, A.A. et al., 2022. “Risk Assessment of Microplastic Particles,” Nature Reviews Materials  7, no. 2, 
138–52, https://doi.org/10.1038/s41578 -021-00411 -y;  It’s estimated that humans can inhale up to 22,000,000 INF/TE/IDP/RD/79  
 
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These are but some of the known problems with plastics.    
 
Second , When searching for alternatives to plastics it may be useful to pro ceed with an ecological 
or "true cost" approach.  With such an approach, each of the problems above need to be 
understood in ecological terms. For example, what does it cost society, including future generations, 
to introduce toxicity via additives?  With t his kind of approach the following questions will need to 
be asked:  
 
(i) Is there really a serious societal need for the plastic product? Does the value of 
the product in performing that need exceed the true costs of the product including the 
damage created in its life -cycle, including the extended life of the plastic once produced and 
becomes waste?  
 
(ii) Is there a way to fulfill the same societal need (e.g without plastics), that can 
increase the ratio of societal worth over costs of damage done  (negative 
externalities)?  
 
Additionally, alternatives or substitutes to plastics do not need to be alternative or substitute 
materials. They can also be alternative systems: for example through the development of reuse and 
refill systems, which have demonstr ated to be less polluting and more advantageous from an 
economic perspective.18  
 
Therefore, when considering alternatives the following questions must be asked:  
 
(i) Are there  alternative systems  that can be used to fulfill  the same societal need with 
less negative impact?   
 
(ii) What are the  negative externalities of the alternative systems ?    
 
(iii) For necessary plastics , are there substitute or alternative materials  that can be 
used that have far less negative impactfu l externalities?   
 
(iv) What are the negative externalities of those substitute or  alternative materials ? 
 
This is especially useful, as our decisions of what materials and systems to use have in the past 
ignored the true costs of negative externalities - the environmental debt placed on the global 
commons, on biological integrity and the health of future generations.   
On bioplastics, the definition of the term “bioplastics” varies greatly around the world, but 
is most commonly used to describe bio -based,  biodegradable, and/or compostable 
plastics .Conflicting definitions like these make “bioplastic” an unhelpful term that confuses policy -
makers and consumers about the difference between bio -based, biodegradable, and compostable 
materials. But generally sp eaking Bio-based plastics  are plastics that are partly or entirely made 
from biological feedstocks such as corn or potato starch, but still contain fossil fuels.  So we can call 
them better plastics, but they still carry some environmental and human rights problems, which 
means that we have to approach them with a lot of care.  
Biodegradable p lastics  are plastics that can, under certain environmental conditions, be broken 
down by microorganisms like bacteria and fungi into water, carbon dioxide, and naturally occurring 
minerals. So “Biodegradable,” therefore, refers to a material’s end -of-life behavior, regardless of its 
 
micro - and nanoplastics per year, see for e.g. Cox, K.D. et al., 2019. “Human Consumption of Microplastics,”  
Environmental Science & Technology  53, no. 12,  https://doi.org/10.1021/acs.est.9b01517 . Micro - and 
nanoplastics enter human bodies, see for e.g. Gasperi et al., “Microplastics in Air,” 3; Joanne M. Don kers et al., 
2022, “Advanced Epithelial Lung and Gut Barrier Models Demonstrate Passage of Microplastic Particles,” 
Microplastics and Nanoplastics  2, no. 1, https://doi.org/10.1186/s43591 -021-00024 -w. Micro - and nanoplastics 
inhalation present health impacts, see for e.g. Alessio Facciolà et al., 2021 “Newly Emerging Airborne Pollutants: 
Current Knowledge of Health Impact of Micro and Nanoplastics,” International Journal of Environmental Research 
and Public Health 18, no. 6 https://doi.org/10.3390/ijerph18062997 . 
18 ZeroWasteEurope, Reusable VS single -use packaging: a review of environmental impact, 
https://zerowasteeurope.eu/library/reusable -vs-single -use-packaging -a-review -of-environmental -impact/ .  INF/TE/IDP/RD/79  
 
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  component materials, which can include biological material, fossil fuels, or both. For this same 
reason, biodegradable plastics can reduce the quality of mixed recyclable materials,19 and are 
sometimes considered contaminants in recycling systems. Many studies show that 
biodegradable plastics fail to fully biodegrade in real world environments, and can remain 
intact for years before fragmenting into equally persistent microplastics.20 This is 
particularly concerning given the common perception that biodegradable plastics are 
“eco-friendly” and can biodegrade naturally.  Biodegradable plastics pose serious environmental 
and human health problems because they can break down into toxic resi dues.  
II. On plastic packaging, in particular those associated with international trade  
 
What TrPMs could support increased use of recycled content in packaging? How to ensure 
rPET and other recycled plastics, alternatives and substitutes meet trade -related s anitary 
and phytosanitary requirements?  
 
It would be a mistake to assume that there will be a net gain for the environment using 
recycled content in new products . This notion has been promoted without weighing the potential 
harm from post -consumer plastic  use against alternatives such as switching to other materials and 
delivery methods. This needs to be scrutinized taking into account ecological economics, more 
precisely by examining:  
 
(i) The cost of subsidizing collection and cleaning of low-value plastics.  
 
(ii) The costs of harmful additives being passed into new products.  
 
(iii) The costs of removing such additives from recycling, and the cost of disposing of these 
additives as hazardous waste.  
 
III. On plastic waste management and trade  
 
What are the key criteria to be considered when identifying compostable plastics targeted 
by TrPMs? What related capacity needs can be identified?  
 
"Compostable" implies that the plastics will break down.  But, breaking plastics down per se is 
not a net posi tive unless the breakdown products are benign (e.g. do not create toxicity 
issues, or microplastics) .21 Whether composting is positive or not remains an issue, in particular 
around the conditions and time by when this breakdown takes place: Does it break d own into 
benign compounds in a timely manner, and can this happen in nature or open air 
environments, or only in industrial settings?  This latter question is extremely important as 
requiring industrial conditions implies that the waste will first need to be collected - which, as 
 
19 Samper, M., Bertomeu, D., Arrie ta, M., Ferri, J., & López -Martínez, J. (2018). Interference of Biodegradable 
Plastics in the Polypropylene Recycling Process. Materials, 11(10), 1886. 
http://dx.doi.org/10.3390/ma11101886 ; Alaerts, L ., Augustinus, M., & Van Acker, K. (2018). Impact of Bio -
Based Plastics on Current Recycling of Plastics. Sustainability, 10(5), 1487. 
http://dx.doi.org/10.3390/su10051487 .  
20 Haider, T., Völker, C., Kramm, T., Landfester, K., Wurm, F. (2018). Plastics of the Future? The Impact of 
Biodegradable Polymers on the Environment and on Society. Angewandte Chemie, 58(1), 50 -62. 
https://doi.org/10.1002/a nie.201805766 ; Napper, I., Thompson, R. (2019). Environmental Deterioration of 
Biodegradable, Oxo -biodegradable, Compostable, and Conventional Plastic Carrier Bags in the Sea, Soil, and 
Open -Air Over a 3 -Year Period. Environ. Sci. Technol. 53(9), 4775 –4783. 
https://doi.org/10.1021/acs.est.8b06984 ; Nazareth, M., Marques, M.R., Leite, M.C., Castro, I.B. (2019). 
Commercial plastics claiming biodegradable status: is this also accurate for marine environ ments? J. Hazard. 
Mater. 366, 714 –722. https://doi.org/10.1016/j.jhazmat.2018.12.052 ; UNEP. (2015). Biodegradable Plastics 
and Marine Litter. Misconceptions, concerns and impacts on marine en vironments. United Nations Environment 
Programme (UNEP).  
21 European Environment Agency, 2020. “Biodegradable and compostable plastics - challenges and opportunities” 
https://www.eea.europa.eu/publications/biodegradable -and-compostable -plastics/biodegradable -and-
compostable -plastics -challenges ;  Break Free From Plastic, 2022. “Biodegradable and compostable plastic s.” 
Plastic Solutions Review.  https://plasticsolutionsreview.com/biodegradable -and-compostable -plastics/ . INF/TE/IDP/RD/79  
 
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  discussed, can be very difficult and expensive.22 Finally, do the compostable products cause 
conventional waste management systems to malfunction?    
 
As an example, a possible solution is to design necessary plastics in a way that (i) will not possess 
properties that cause harm to conventional collection/recycling, (ii) that will break down once 
released into the environment and (iii) will break down by themselves into completely harmless 
compounds. In summary, the following criteri a could be considered : 
 
(i) Will it break down when it is desirable to cease acting as plastic packaging and do so in 
a timely manner?  
 
(ii) Will it break down into non -toxic, non -harmful, non -plastic (including microplastics) 
compounds?  
 
(iii) Can this br eakdown occur without industrial or special conditions (e.g. in open air after 
being discarded)?  
 
(iv)  Does the product harm conventional collection and recycling operations?  
 
What TrPMs could support addressing illegal trade in plastic wastes?  
 
Any requirements that enhance transparency of:  
  
(i) What is being traded (including the additives that are being traded);  
 
(ii) Proof of the environmental soundness of management of processing facilities where 
traded plastic waste is sent.  
 
Basel Conve ntion Member States could require to establish penalties for non -compliance that serve 
as disincentives to illegal traffic. This could include mischaracterization of HS codes.   
 
We look forward to working with you in the future,  
 
Please accept, Excellenci es and colleagues, the assurances of our highest consideration.  
 
Helionor de Anzizu  
Staff Attorney,  
Center for International Environmental Law  
hdeanzizu@ciel.org   
 
 
 
__________  
 
22 See e.g. IPEN, 2021 “Plastic Waste Management Hazards” 
https://ipen .org/sites/default/files/documents/ipen -plastic -waste -management -hazards -en.pdf ; Warhurst, M. 
2020. “Chemical recycling: Is it worth the energy?” ChemTrust https://chemtrust.org/chemical -recyclin g.