INF/TE/IDP/RD/77* 
1 December 2022  
(22-8933) Page: 1/7 
 Original:  English /anglais/ inglés  
 
  
UNOFFICIAL ROOM DOCUMENT1 
 
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 
 
 
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 d ans 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 documentos 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 sal as de reunión de la OMC y se les asigna una signatura no 
oficial a efectos de archivo únicamente.  INF/TE/IDP/RD/77  
 
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Statement by the Forum on Trade, Environment & the SDGs (TESS)  
Dialogue on Plastics Pollution  
Pre-Plenary  
17 November 2022  
 
 
Agenda Item 2. Focused discussions on Single Use Plastics (SUP) and products  
 
i. What are the key criteria to be considered when identifying SUP and products 
targeted by Trade -related Plastics Measures (TrPMs)? Are there examples of 
particularly problematic SUP and products that would fit these criteria?  
ii. What are the key criteria to be considered when identifying environmentally 
sustainable and effective substitutes and al ternatives 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?  
 
We would like to thank the Dialogue Coordinators and Facilitators to convening t his pre -plenary and 
for the very specific topics and relevant questions for discussion.  
Single -use products are one of many problematic and unnecessary plastics that need to be addressed 
in order to tackle plastic pollution. However, as has been noted alre ady, there is no universally 
accepted definition of single -use products, nor for problematic or unnecessary plastics. Notably, 
submissions from a range of governments for the first session of the international negotiating 
committee (INC) responsible for ad vancing work on an international legally binding instrument on 
plastic pollution by 2024 have highlighted the need for clear definition of concepts such as 
“problematic plastics.”  
In terms of single use plastics, as we have heard in the presentations, Memb ers have adopted 
different working definitions and approaches to regulating single use products. While there are 
commonalities, the scope of products targeted for regulation by Members varies widely. Sometimes 
the definition is broad but the number of spec ific products targeted is narrow, due to considerations 
ranging from technical capacity to implement specific kinds of measures, political feasibility as well 
as local social and economic considerations.  
UN Environment Programme (UNEP) has offered a worki ng definition of single -use plastics:  
“Single -use plastics …are commonly used for plastic packaging and include items intended to be 
used only once before they are thrown away or recycled.”  Single use plastics  include commonly 
used items such as grocery ba gs, food packaging, drink bottles, straws, containers, cups, plates 
and cutlery that are usually disposed of after one use.  
A critical point for discussions at the WTO on trade and plastic pollution is that for many of single 
use plastics there is no spec ific corresponding HS code. Where there is an HS code describing a 
certain kind of relevant plastic good, we do not know from the HS classification whether and what 
share of goods classified under this HS code are for single or multiple use. The figure bel ow provides 
a sample of relevant HS codes for some of these products.  INF/TE/IDP/RD/77  
 
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Notably, some countries provide more granular differentiation of specific single use plastics at the 
8- and 10 -digit levels in their national classifications. For a range of topics w here amendments at 6 -
digit level through the HS may be difficult, there is considerable scope for more countries to adopt 
8 and d10 digit codes that allow for more differentiation in ways that support transparency and 
regulation of trade in key problematic  plastics, and also to coordinate among countries on these 
codes.  
 
While amendments to the HS at the WCO and to national classifications will be important to help 
countries target trade flows in single use plastics they wish to regulate, there is also lik ely to be a 
need for creative technological solutions for tracking trade in single use plastics at the border (such 
as bar, QR and RFID codes). Cooperation on international standards and labelling of products could 
also promote transparency of the material  composition of plastics that enter countries.  
Importantly, as noted above, problematic plastics are not limited to single use plastics. There are a 
range of plastic products that can be considered problematic due to their design and material 
composition, including designs that make them hard to recycl e (such as mixed -polymer, multi -layer 
and mixed -material products and packaging) as well as products that contain harmful additives.  
Further, from a life cycle perspective, in addition to problematic plastic products, there is also a need 
to address the e xpanding production and trade of problematic plastic materials as  well as harmful 
and toxic chemicals and additives, which contribute to the problematic nature of final products 
(including those that are not single use) as well as plastics embedded in othe r products (such as 
electronic goods). Notably, the High Ambition Coalition to End Plastic Pollution, formed in the context 
of the plastic pollution treaty negotiations, has noted importance of the “elimination of problematic 
plastics that hinder progress towards a circular economy, pose critical health risks or have a high 
risk of ending up in the environment.” It has also noted the challenge of avoiding unintentional 
release of microplastics from diffuse sources, such as wear and tear of tyres, paint and textiles.   All 
of these are products that are highly traded internationally. On a related matter, the coalition is also 
calling for enhanced transparency in the value chain of plastics, including for material and chemical 
composition, precisely to support countries to identify, monitor and regulate production, use and 
trade in problematic plastics.  
 
The identification and categorization of problematic plastics, with clear criteria, is an important 
ongoing work, which will require engagement of many experts,  and the discussions today are already 
supporting that effort.  Here again, discussions in this Dialogue can benefit from synergies with 
efforts underway in regard to the plastic pollution treaty. In a summary prepared by UNEP of 
submissions that several g overnments have made to the INC, they note the emphasis that 
submissions place on the importance of measures across the plastics life -cycle including those 
relevant to upstream segments such as “reducing and eliminating single -use, problematic, 
INF/TE/IDP/RD/77  
 
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  unnecessary , hazardous and harmful plastics through product design.”2 The note also makes 
reference to calls by a range of governments for the elimination or removal of various types of 
problematic plastics. Submissions also singled out microplastics for particular attention.  
 
In short, we commend the effort of Members to focus in the first instance on potential cooperation 
around readily identifiable single use plastics, particularly given that this is a topic so many countries 
are already seeking to tackle at the national level. We would recommend, however, that this effort 
be approached in the context of the wider range of problematic plastics that require attention as 
well. 
 
On the second guiding question under this item,  with regard to environmentally sound and 
effective plastic substitutes for single use products, we underline the need to carefully differentiate 
between plastic substitutes, which we understand to be non -plastic substitutes, and alternative 
plastics. On alternative plastics, a number of presenter s and Members this morning have already 
highlighted the diverse range of products referred to as alternative plastics, as well as the questions, 
risks and challenges associated with many of those, so we will not repeat.  
The key point to note is that altern ative plastics is a very broad concept that an include a range of 
products of different composition and feedstock and end of life characteristics, but that remain 
plastics. The environmental credentials of many of these products are a subject of considerab le 
scientific debate, and some have been found to have misleading environmental claims and to offer 
no substantial environmental benefits over conventional plastics across the whole life cycle. Indeed, 
some alternative plastics, such as oxo -degradable plas tics, have been found to be worse from an 
environmental viewpoint.   Some plastics, such as recycled plastics, may have a key role to play in a 
shift to a more circular plastics economy, but also raise important environmental and health 
concerns, including related to the carbon footprint of recycling and the toxicity of recycled plastics. 
Many others here can provide more expertise on these points. Importantly, the advice from leading 
experts on plastic pollution is that from a sustainability viewpoint our e mphasis must not be replacing 
unsustainable plastics with alternative plastics, but also to seeing where we can reduce unnecessary 
production and consumption, adopt alternative business models (such as re -use and re -fill systems 
in lieu of unnecessary pack aging), and explore non -plastic substitutes.  
 
In our work at TESS, we have been studying opportunities related to environmentally sound and 
effective non -plastic substitutes. Here, we agree that a consideration of environmental impacts 
across the life cycle is vital. On that basis, non -plastic substitutes that we suggest for consideration 
include natural fibres, such as jute, abaca, coir and kenaf, as well as products made of bamboo, 
many of which are of particular export interest to developing countrie s. In addition, as already 
identified by UNCTAD in their studies on the topic, substitutes made from agricultural waste are also 
worthy of consideration. They can have a low environmental impact if they make use of crops that 
are being already grown for fo od or other purposes and thus do not compete for water or land -use 
with such crops or undermine food -security. Crop waste can also provide farmers an additional 
income stream including in the event the main food crop gets destroyed by weather events or pes ts. 
We look forward to further discussion of this topic at the forthcoming workshop.  
 
Agenda item 3. Focused discussions on plastic packaging, in particular those associated 
with international trade  
 
a. Guiding technical questions:  
 
i. What TrPMs could sup port increased use of recycled content in packaging? How to 
ensure rPET and other recycled plastics, alternatives and substitutes meet trade -related 
sanitary and phytosanitary requirements?  
ii. How could ambitious customs authorities and/or leading enterp rises help identify 
material flows of plastic packaging used in traded goods? Would sectoral averages be a 
potential first step?  
 
TESS would like to thank the Dialogue Coordinators and Facilitators for including plastic packaging 
as a specific topic for di scussion at this pre -plenary.  
On the first question, regarding TrPMs that could support use of recycled packaging, the options that 
we have identified include design principles around packaging to improve recylability, domestic 
 
2 https://wedocs.unep.org/bitstr eam/handle/20.500.11822/40721/K2221859%20 -%20UNEP -PP-INC.1 -11%20 -
%20ADVANCE.pdf . INF/TE/IDP/RD/77  
 
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  packaging recyclable conten t standards and labelling requirements, standards to restrict excessive 
packaging for food and cosmetics, collection and recovery targets, extended producer responsibility 
requirements, green procurement policies, and mandates and regulations setting packa ging-related 
recycling and recycled content. Import tariffs, bans, import licensing and export restrictions are also 
being harnessed by countries to target non -recycled or non -recyclable plastic packaging. Notably, 
efforts to promote greater recycled packa ging will also rely on upstream measures that address the 
low price of virgin plastic feedstock relative to recycled feedstock.  
 
Notably, while the emphasis on recycled and recyclable packaging is an important element of a 
systems change approach to tackl ing plastic pollution, we urge governments to recall that efforts in 
this regard should be advanced in the context of wider efforts to reduce unnecessary packaging, to 
promote non -plastic substitutes and alternative business models that use less plastics, and in 
recognition of the fact that we will not recycle our way out of the plastic pollution challenges 
associated expanding plastics production and use. Recycling and recycled plastics – and the 
associated markets for them – also present a range of enviro nmental and health challenges. 
Recycled plastics, for instance, also shed microplastics, can be recycled only a certain number of 
times, and can only be used for certain applications because they present a range of health concerns, 
including increased toxi city. 
 
On the second question, we all know from our daily experience that there is an enormous volume of 
overpackaging and unnecessary plastic packaging.  We have heard this morning that many types of 
this plastic packaging and the plastic materials used in packa ging are problematic or substitutable. 
Tackling plastic packaging will be a critical component of trade -led and trade -related policy efforts 
to address plastic pollution. Imports of plastic packaging, both empty plastic packaging as well as 
packaging assoc iated with pre -packaged products and the transportation and distributions of plastic 
products, add to the growing volume of plastic waste that countries face and can overwhelm national 
waste management capacities, particularly in developing economies.  
 
Our comments today will focus on the challenge of identifying material flows of plastic packaging at 
the border, including plastic packaging used in traded goods.  
 
According to the OECD, almost two -thirds of plastic waste comes from applications with lifeti mes 
below five years, with packaging being the biggest contributor (40%) followed by consumer products 
(12%) and textiles (11%). One reason for this is the extremely short lifespan of most packaging 
(OECD, 2022).  
 
As noted by our colleagues by Pew this mo rning, packaging comprises the largest share of single -
use plastic material designed for immediate disposal and for over 35% of global plastics produced 
annually. This morning our colleagues from Pew also highlighted certain types of packaging that 
offer t he most reduction potential. These include sachets and multilayer/multimaterial flexibles (such 
as for shampoo and condiments, chips, and sweets packets), followed by business -to-business (B2B) 
packaging such as crates and pallet wrap, monomaterial films, bottles, carrier bags, and food service 
items. Together these categories account for 86% of the total reduction of plastic mass achievable 
in 2040 compared with business as usual.  
 
On other hand, most national and subnational product bans and regulations t oday focus on carrier 
bags and food service items. In fact, these two categories make up only 10% of the entire plastic 
waste stream and represent just 16% of potential reduction by 2040. So a key challenge is to make 
sure we are focusing policy action, in cluding trade related measures, on the kinds of plastic 
packaging that is most important in terms of pollution.  
 
As we have noted in earlier presentations to this Dialogue on Plastics Pollution, official trade statistics 
based on the World Customs Organiza tion’s (WCO) Harmonized System (HS) codes are available 
only for trade in empty plastic packaging.  But official statistics reveal very little about trade flows 
associated with the thousands of pre -packaged goods or used for their international distributio n and 
business to businesses purposes, which as our colleagues from Pew mentioned this morning is a key 
area where reductions in plastic packaging is most important.  Specifically, the HS reveals very little 
about trade in the types of packaging that Pew n otes as offering the most reduction material (notably 
sachets and multilayer/multimaterial flexibles (such as for shampoo and condiments, chips, and 
sweets packets), followed by business -to-business (B2B) packaging.  INF/TE/IDP/RD/77  
 
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  A core challenge is that in the HS syst em packaging associated with pre -packaged products is 
classified with the product itself and no options are provided to differentiate among products in light 
of that packaging.  
 
Taking first the available data on trade flows of empty plastic packaging, the  figure below presents 
2020 data. The figure highlights that the greatest exporter of empty plastic packaging, by far, is the 
EU, followed by China and the US, and then Japan, Korea, Canada and UK. Notably, the EU, China, 
and the US are also the largest im porters of empty plastic packaging, presumably due to their large 
domestic markets and also potentially to be used for packaging used in relation to exports of various 
products.  
 
 
 
Looking ahead, a core challenge is to find ways to better identify and mo nitor the volume, value and 
composition of plastic packaging associated with trade flows and their transportation, including 
through potential amendments to HS subheadings at the WECO and nationally. This could start by 
identifying what kinds of packaging are associated with certain pre -packaged products, including by 
polymer and specifying the presence of harmful chemicals where relevant. For instance, 
governments could consider amending and tailoring specific HS codes to provide more transparency 
on the v olume, share and material composition of packaging, including for instance:  
 
- Bottled water, such as specifying where there packaging is PET, R -PET (i.e., polymer type), 
aluminium or glass, or the share of recycled content or recyclability of packaging.  
- Food, cosmetic and personal products packaged in single polymers versus mixed polymers, 
or multi -material versus mono -material packaging.  
As others have mentioned, cooperation on mandatory requirements and voluntary standards that 
aim to reduce plastic pollu tion associated with plastic packaging would support efforts across 
international supply chains. Standards, for instance, on disclosure of material composition, on design 
of packaging, and on the labelling of products with regard to associated packaging wo uld assist 
efforts to reduce packaging used across international supply chains and to regulate packaging at the 
border. Such efforts will also call for careful consultations and international cooperation, including 
for instance on SPS requirements that may  be relevant to plastic packaging. Changes in plastic 
packaging rules may, for, instance, have implications for exporters, and options for addressing 
challenges, especially for MSMEs and developing countries, arising from changing requirements in 
regard to  plastic packaging in key export markets, such as for food products.  
 
Governments can also consider how to cooperate on the use of technological tools, such as bar 
codes, RFID + QR codes, to enhance traceability and enhancing transparency of what is in pro ducts. 
INF/TE/IDP/RD/77  
 
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  Going back to the issue of packaging, for instance, you could scan a pallet of pre -packaged products 
to know how much packaging is associated with the product and to have information about the 
material composition of packaging (what polymers and add itives are included, if it is multi -material 
packaging). This kind of information could help governments working limit certain kinds of packaging 
or to prioritise packaging with certain characteristics over others.  This Dialogue could also consider 
the st ate of play on electronic product passports and potential for cooperation on those. An important 
consideration with such technological tools is to ensure that companies, including MSMEs, have 
affordable access to these technologies, and there will be issue s of ensuring that data is collected 
and entered correctly. Alongside, customs authorities are still likely to need enhanced capacity and 
systems to verify and test goods in a cost -effective manner.  
 
Notably, we also wanted to draw your attention to ongoi ng efforts to identify sectoral and product 
averages for packaging intensity for different kinds of products.  A key resource in this regard is the 
EXIOBase database, which provides estimates of “plastic intensity” per sector and could be used to 
support e fforts to generate estimates of the share of plastic in the material composition of a product, 
including those traded internationally. TESS has been working with colleagues at the research group 
EA on using this database to determine the volume of ‘hidden plastics’ traded internationally, and 
would be pleased to share further information about this work in future meetings.  
 
Finally, in regard to unnecessary secondary packaging used for shipping goods and B2B packaging, 
Members could review any requirements related to packaging that may exist nationally, including 
on the part of SPS, port or customs authorities, or that are re quired by companies across corporate 
supply chains, including by retail companies and shipping companies, to determine the scope for 
revisions that would reduce the incidence of unnecessary packaging.  
 
 
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