INF/TE/IDP/RD/132*  
 
20 June 2023 
(23-4232) Page: 1/5 
 Original: English /anglais/inglés  
 
  
UNOFFICIAL ROOM DOCUMENT1 
 
DIALOGUE ON PLASTICS POLLUTION AND  ENVIRONMENTALLY SUSTAINABLE 
PLASTICS TRADE  
SOLUTIONS TO PLASTIC POLLUTION  - IISD’S RESPONSES  
Workshop on reduction and circularity to tackle plastic pollution – 27 April 2023 
 
DOCUMENT DE S ÉANCE NON OFFICIEL1 
 
DIALOGUE ON PLASTICS POLLUTION AND  ENVIRONMENTALLY SUSTAINABLE 
PLASTICS TRADE  
SOLUTIONS TO PLASTIC POLLUTION  - IISD’S RESPONSES  
Workshop on reduction and circularity to tackle plastic pollution – 27 April 2023  
 
DOCUMENTO DE SALA NO OF ICIAL1 
 
DIALOGUE ON PLASTICS POLLUTION AND  ENVIRONMENTALLY SUSTAINABLE 
PLASTICS TRADE  
SOLUTIONS TO PLASTIC POLLUTION  - IISD’S RESPONSES  
Workshop on reduction and circularity to tackle plastic pollution – 27 April 2023  
______________ _ 
  
 
* 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 a ttributed 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 systématiquemen t 
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 documentos de la serie RD no son documentos oficiales de la OMC. Por lo general se d istribuyen en 
el idioma en que han sido presentados y no se traducen 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 ún icamente.  INF/TE/IDP/RD/132  
 
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DIALOGUE ON PLASTICS POLLUTION AND ENVIRONMENTALLY SUSTAINABLE PLASTICS 
TRADE  
 
INTERNATIONAL INSTITUTE FOR SUSTAINABLE DEVELOPMENT (IISD) SUBMISSION  
 
ANNEX – Questions for written submissions by delegations and stakeholders  
 
Break -out sessions will focus on the guiding questions below. Delegations and invited stakeholders 
are kindly invited to send written answers to these questions prior to the event to idp@wto.org . 
 
IISD would like to submit the responses to the questions following up the DPP workshop based on 
the upcoming policy brief that analyses plastic -related notifications collected in the EDB. Therefore, 
the conclusions are currently preliminary until the brief is published (expected end of May 2023).  
 
1) Types of trade measures most often used and best practices  
 
Q. What principles and criteria should be taken into account when identifying "best practices" in 
relation to Trade -related Plastic Measures (TrPMs) aimed at reduction to tackle plastic pollution, 
while bearing special attention to issues and challenges arising for developing members, including 
SIDS.  
 
Based on EDB data, IISD’s brief shows that the mos t notified types of trade -related plastic pollution 
reduction measures are bans, followed by technical regulations and import licensing schemes (see 
figure below). Technical regulations are often used as a “vehicle” to introduce bans, which means 
that ther e is only a relatively small number of technical regulations do not also fall in the ban 
category.  
 
 
 
IISD’s  analysis also shows, by looking at a number of concrete examples, that similar types of 
measures on similar products can differ quite significantly in how they designed by different 
members. This confirms the importance of further thinking on whether, and  how, it is possible to 
promote convergence around a set of best practices.  
 
The existing collection of notifications in the EDB is not providing enough data that would allow to 
extract a comprehensive set of “best practices”. However, there are some concl usions that can 
already be drawn to support further thinking about such measures:  
INF/TE/IDP/RD/132  
 
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  1. Transparency. Comparing the data in the EDB notifications to, for example, data available 
in the Duke University Plastics Policy Inventory (including as highlighted here: 
https://www.iisd.org/system/files/2023 -
04/fighting_plastic_pollution_taking_the_first_step_taking_the_next_step.pdf  ) or some o f 
the UNEP’s research (for example, bans and prohibitions mentioned here: 
https://www.unep.org/resources/report/legal -limits -single -use-plastics -and-microplastics  
), it would seem that a good share of measures is not notified to the WTO. It might be 
because of the general lack of understanding that such measures are or could be trade -
related or miscommunication between the ministries responsible for envi ronment and trade. 
IISD’s research, however, shows that at least 90 WTO Members have not only adopted such 
measures but also notified them to various WTO bodies 
(https://www.iisd.org/system/files/2023 -
04/fighting_plastic_pollution_taking_the_first_step_taking_the_next_step.pdf  ). It is very 
important to make sure that TrPMs are notified to the WTO and that Members have an 
oppor tunity for an exchange regarding new measures. This is particularly important to 
developing country members that might not have the capacity to collect a broad range of 
information on TrPMs from a variety of sources.  
2. Respect for the fundamental WTO princip les while delivering on environmental objectives. 
When introducing trade -related measures to tackle plastic pollution, members should 
respect the basic principles of the WTO, including those of MFN and national treatment, and 
seek to adopt measures that ar e not more trade -restricting than necessary to fulfil an 
objective to tackle plastic pollution. In particular this means that, for example, import 
restrictions, prohibitions or requirements need to be matched with the equivalent 
restrictions, prohibitions or requirements for domestic sale, manufacturing or distribution. 
Preliminary IISD’s research ( https://www.iisd.org/system/f iles/2023 -
04/fighting_plastic_pollution_taking_the_first_step_taking_the_next_step.pdf ) shows that 
while this is respected in most cases of import bans, it is not the case universally.  
3. International cooperation while developing trade -related plastic measures. While the INC 
process for a global plastics treaty is currently ongoing, the variety of currently existing 
technical regulations related to measures aimed at plastic pollution reduc tion creates a 
“spaghetti bowl” of prohibitions and specifications. The full variety of which can be illustrated 
here: https://www.unep.org/resources/r eport/legal -limits -single -use-plastics -and-
microplastics  and which, to a lesser extent, is reproduced in the WTO members notifications 
collected at the EDB. Such diversity might not only create an uncertain business environment 
and increase business costs but also do poor service for the environmental objectives by 
setting the bar too low for the measure to have any meaningful impact. This, in particular, 
could be relevant for the specification of products deemed “single -use plastics” or other 
undesirable p lastics that could often be defined by their physical properties, such as 
thickness, or material qualities, such as composition, as well as use -related or end -of-life 
considerations.  
4. Inclusiveness. Development of TrPMs needs to rely on a broad consultative  process that 
would include scientific advice, business and other stakeholders, as well as the WTO 
Members’ trading partners. Our analysis of notified measures show that many of them 
include exemptions that could be based on particular qualities of product  (use of 
biodegradable or recycled plastic), on particular uses (medical purposes, waste collection, 
research), for particular sectors (agriculture, health) or specific situations (absence of 
substitutes/alternatives, emergency situations). While the exemp tions that are too broad 
might compromise the effectiveness of the measure, an inclusive consultative process can 
help to avoid the situations where the shortage of a specific plastic product could cause 
social unrest or serious economic implications and w ould put the whole measure at risk.  
5. Predictability. It is important to allow impacted sectors and societal groups to prepare for 
the introduction of the new measure if the situation does not demand an urgent action. The 
WTO already has existing practices i n this area, for example, demanding the 6 -month 
notification of the drafts of planned technical regulations to the TBT Committee to allow 
sufficient time for the trading partners to provide their comments and for the business 
community to prepare for the u pcoming changes in business environment. Many submitted 
notifications respected such timeline, however, some governments saw a certain emergency 
that demanded them to act more swiftly – it would be quite important to make sure that 
such actions are proport ionate to the degree of urgency of the situation.  
 
An important observation stemming from the analysed measures is that different targeted plastics 
will demand the introduction of different trade -related policies. This will directly stem from the INF/TE/IDP/RD/132  
 
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  plastics problem that the government will aim to address. For example, reducing the source of plastic 
pollution, targeting public littering, enhancing recycling or protecting public health are all objectives 
linked to problems created by plastic pollution, yet each  of them might be addressed by different 
measures, sometimes tailored to suit the needs of specific jurisdiction.  
 
2) Trade policies and practices requiring realignment with the objective of ending plastic 
pollution.  
 
Q. What are the trade policies, if any , that are misaligned with the objectives of ending plastic 
pollution to protect human health and the environment, through reduction?  
 
While the data is relatively sparse on the exact quantification, it is quite evident that the plastics 
sector is benefitt ing from a broad range of subsidies, including both direct subsidies to the production 
of plastic polymers or plastic products, as well as the indirect effect of subsidies to fossil fuels that 
are artificially lowering the price of inputs in the industry t hat is highly energy -intensive. Continued 
access to government support for the plastics industry is paradoxically causing higher expenses 
related to recycling, waste management, environmental protection or even health. This, in turn, is 
also provoking some  WTO members to also subsidize the plastic waste management or recycling 
activities2. 
 
 
3) Unnecessary or harmful plastics and plastic products most targeted by trade policies, 
including single -use plastics and plastic packaging associated with international trade  
 
Q. What unnecessary or harmful plastics and plastic products, including single -use plastics and 
plastic packaging associated with international trade, are already being targeted by [your] trade 
policies and what are their identificatio n codes under the Harmonized Commodity Description and 
Coding System (HS) (even if those codes currently cover other products)?  
 
Our research shows that most notified measures target finished plastic products, in particular single -
use plastic items used or  sold in the retail, food and, increasingly, personal care sectors. The product 
categories that were targeted by the largest number of measures notified between 2009 and 2021 
were plastic bags (30 measures) and plastic waste (28 measures), which likely ref lects both the fact 
that these two categories are widely recognized as environmentally harmful and perceived as a 
policy priority in plastic pollution reduction efforts.  
Other relatively frequent categories involved measures to address the problems caused  by excessive 
plastic packaging, plastic food containers, plastic tableware, bottles and straws, as well as the rigid 
plastic foam used for the food containers. Some of these products (e.g., plastic food containers and, 
to a lesser extent, plastic packagin g) featured particularly strongly in the notifications of 2021, which 
could be linked to the changes of shopping and food ordering patterns during the COVID -19 
pandemic.  
Two other categories —cotton buds and cosmetics containing microbeads —provide an intere sting 
group of measures focused on the personal care sector. While not as widespread as measures 
focused on other products, these two categories show a separate area of focus of policymakers 
where, particularly in the case of cosmetics containing microbead s, products are a direct cause of 
pollution from microplastics.  
Finally, a number of measures targeted types of products that are not reflected in the main 
categories noted above, either exclusively or coupled with products reflected in these main 
categori es. Such products include plastic beverage stirrers, fishing nets, some types of plastic films, 
rubber tires, balloon sticks, fruit stickers, as well as some specific plastic materials (e.g., 
polyethylene), chemicals (e.g., plasticizers), components of par ticular plastic products (e.g., 
components of plastic bags), and plastic parts of other products (e.g., plastic parts of electronic 
displays).  
Our research was not focused on the identification of HS codes of targeted products.  
 
4) Criteria used when prior itizing trade action on unnecessary or harmful plastics, plastic 
products and other goods.  
 
 
2 More on subsidies for plastics can be found here: https://snis.ch/wp -
content/uploads/2020/01/2019_Littoz -Monnet_Working -Paper -6.pdf.pdf  INF/TE/IDP/RD/132  
 
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  Q. Please select from below (and assign a grade of 1 to 5 in order of importance, with 5 being of 
highest importance) the criteria used when prioritizing trade acti on on particularly unnecessary or 
harmful plastics and plastic products, including single -use plastics and plastic packaging associated 
with international trade . 
 
 
 
relative importance in total plastics waste generation  Order of importance (1 to 5)  
relative importance in leakage   
relative importance of material flows of plastics moved by trade    
Human health   
Environmental damage   
Risk of pollution   
Food security   
Costs of cleaning up and losses for tourism, fisheries and shipping   
potential to negatively impede circularity   
single vs multi -use goods   
Multi-material, multi -polymer structure   
substitutability for the same functionality and cost effectiveness 
(incl. in the health system)   
Negative impact in non -plastic materials' industries being 
substituted by plastics   
embedded and related (e.g. transport) GHG -emissions   
Technical and economic viability of recycling the product   
Other:   
 
IISD’s  research does not provide detailed analysis of such criteria due to rather modest amount of 
related information in the WTO notifications, nevertheless, it is important to note that some of the 
notified policy documents went into some detail when explainin g the specific choice of targeted 
plastics and plastic products, and such instances in particular were related to (using categories 
above):  
- Product’s importance in leakage;  
- Product’s importance in plastics waste generation;  
- Environmental damage;  
- Human heal th; 
- Costs of cleaning up and losses for tourism, fisheries and shipping.  
 
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