INF/TE/IDP/RD/102 * 
 
7 February 2023 
(23-0856) Page: 1/9 
 Original: English /anglais/inglés  
 
  
UNOFFICIAL ROOM DOCUMENT1 
  
 DIALOGUE ON PLASTICS POLLUTION  
AND ENVIRONMENTALLY SUSTAINABLE PLASTICS TRADE  
SUBMISSION  BY THE FORUM ON TRADE, ENVIRONMENT & THE SDGS (TESS)  
Workshop on Plastic Substitutes - 6 December 2022  
 
DOCUMENT DE S ÉANCE NON OFFICIEL1 
 
DIALOGUE ON PLASTICS POLLUTION  
AND ENVIRONMENTALLY SUSTAINABLE PLASTICS TRADE  
SUBMISSION  BY THE FORUM ON TRADE, ENVIRONMENT & THE SDGS (TESS)  
Workshop on Plastic Substitutes - 6 December 2022  
 
DOCUMENTO DE SALA NO OF ICIAL1 
 
DIALOGUE ON PLASTICS POLLUTION  
AND ENVIRONMENTALLY SUSTAINABLE PLASTICS TRADE  
SUBMISSION  BY THE FORUM ON TRADE, ENVIRONMENT & THE SDGS (TESS)  
Workshop on Plastic Substitutes - 6 December 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 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 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 ún icamente.  INF/TE/IDP/RD/10 2 
 
- 2 - 
 
   
 
WORKSHOP ON SUSTAINABLE AND EFFECTIVE SUBSTITUTES AND ALTERNATIVES 
FOR PLASTICS  
Questions for written submissions  by delegations and stakeholders  
 
Submission from the Forum on Trade, Environment and the SDGs (TESS)  
 
5 December 2022  
 
1) Working definitions  
 
Q. What are the concepts for which a "working definition" could help the identification of 
"environmentally sustainable and effective substitutes and alternatives " (please select all that 
apply). For each, what are the key elements that should be included in a working def inition?  
 
 concept  Key elements   Potential source  
☐ plastic    
☐ microplastics    
☐ plastics 
substitutes  • Contains naturally occuring  
polymers (of plant or animal 
origin) or non -renewable 
mineral substances found in 
nature  
• Minimal or simple processing or 
transformation that does not 
create synthetic or semi -
synthetic polymers  
• Does not contain harmful 
chemicals or additives  
• Does not require special 
composting facilities to enable 
“end of life” composting (for 
animal and plant -based 
materials)  
• Does not have any toxic or 
harmful impact upon disposal or 
leakage into the environment 
(both land and oceans)  
• Time taken for biodegradation 
in natural environment may 
also be important to consider 
(too long of a time can still 
cause damage in terrestrial and 
marine environment to 
species). For instance, plastic 
substitutes must demonstrate  
disintegration and inher ent 
biodegradation during  marine 
water exposure and must not 
exhibit any  adverse 
environmental impacts on the 
survival of  marine organisms 
while in the marine 
environment  • United Nations Conference on 
Trade and Development. (2021). 
Material substitutes to address 
marine plastic pollution and 
support a circular economy: 
Issues and options for trade 
policymakers .  
https://unctad.org/system/files/o
fficial -
document/ditctedinf2021d5_en.p
df 
 
• Oceana (2022).  
Bioplastic Remains Plastic:Bio -
based, biodegradable and 
compostable plastics . 
https://europe.oceana.org/wp -
content/uploads/sites/26/2022/1
1/FACTSHEET -BIOPLASTIC -
REMAINS -PLASTIC.pdf  
☐ plastic 
alternatives  • Irrespective of feedstock 
source, are composed of • United Nations Conference on 
Trade and Development. (2021). 
Material substitutes to address INF/TE/IDP/RD/10 2 
 
- 3 - 
 
  synthetic or semi -synthetic 
polymers.  
• Can include products made of 
recycled plastics  
• Do not contain harmful 
chemicals or additives  
 
• Can require special composting 
facilities to enable “end of life” 
composting  
• Have same impact as 
conventional plastics in case of 
leakage into the environment.  
• Time taken for biodegradation 
in natural environment may 
vary and is important to 
consider (too long of a time can 
still cause damage in terrestrial 
and marine environment, 
including through degradation 
into microplastics)  marine plastic pollution and 
support a circular economy: 
Issues and options for trade 
policymakers .  
https://unctad.org/system/files/o
fficial -
document/ditctedinf2021d5_en.p
df 
 
• Oceana (2022).  
Bioplastic Remains Plastic:  Bio-
based, biodegradable and 
compostable plastics . 
https://europe.oceana.org/wp -
content/uploads/sites/26/2022/11/
FACTSHEET -BIOPLASTIC -REMAINS -
PLASTIC.pdf  
☐ environmentally 
sustainable  • Often depend s on life -cycle 
variables that are also country -
specific (like energy mix) so 
cannot have an absolute 
determination  
• Variables such as energy -mix or 
presence of adequate waste 
management facilities can also 
change over time  
• No agreed single LCA 
methodology that can be 
applied  United Nations Conference on  Trade 
and Development. (2022). 
Substitutes for Single -Use Plastics in 
Sub-Saharan Africa and South Asia: 
Case Studies from Bangladesh, 
Kenya and Nigeria.  
https://unctad.org/system/files/offi
cial-
document/tcsditcinf2022d3_en.pdf  
☐ effective 
(including cost 
and functionally 
effective)  • Specific end -use of the plastic 
material it is meant to replace  
• Costs need to be viewed in a 
broader context (especially in 
the presence of fossil fuel 
subsidies that keep prices of 
virgin plastics feedstocks low )  
☐ single use    
☐ re-usable  • Re-use means use of a product 
more than once in its original 
form.  Term included in UNEP glossary for 
INC-1. 
 
https://wedocs.unep.org/bitstream/
handle/  
20.500.11822/41266/   
Glossary_Key_Terms_E.pdf   
☐ biodegradable  • The degradation time required 
for items to be labelled as  
“biodegradable” should be short 
enough to prevent any  harmful 
effects on biota and/or the 
environment.  
• Biodegradability labels shoul d 
ensure actual biodegradability  
of products in all kinds of 
environments, includingg the 
deep sea  
• Future testing standards should 
be adapted to replicate the 
actual conditions where  plastics Oceana (2022).  
Bioplastic Remains Plastic : 
Bio-based, biodegradable  
and compostable plastics . 
https://europe.oceana.org/wp -
content/uploads/sites/26/2022/11/
FACTSHEET -BIOPLASTIC -REMAINS -
PLASTIC.pdf   INF/TE/IDP/RD/10 2 
 
- 4 - 
 
  accumulate and consider 
degradation time as a  key 
criterion for biodegradable 
plastics.  
☐ erodible    
☐ recyclable  • A key question related to the 
designation of products as 
recyclable is whether adequate 
capacity exists within a certain 
jurisdiction or other 
arrangements have been made 
to ensure that recyclable 
products are in fact recycled.  
• A further question is wheth er 
they require special sorting 
capacities or recycling facilities? 
(such as for products made with 
mixed polymers or materials).  
• A further question is relates to 
the toxicity of recyclable 
products and the material 
composition of products, which 
impacts whether or not these 
can be safely recycled.  
• Key considerations are whether 
that there is a threshold for the  
number of times the product 
can be recycled for the same 
functional end -use  
• There is a need to define the 
threshold of the minimum 
number of tim es a polymer can 
be recycled without losing much 
of its functional value and 
qualities such as durability  
• There is a need to specify the 
material content of recycled 
materials, including the 
material composition, such as 
presence and concentration of 
additives.  
• A further questions relates to 
the environmental impacts and 
cost-effectiveness of recycling 
processes used (including GHG 
emissions) and an integration of 
this into LCA assessments of 
products.   
☐ recycled 
content  • Key considerations are whether 
that there is a threshold for the  
number of times the product 
can be recycled for the same 
functional end -use  
• There is a need to define the 
threshold of the minimum 
number of times a polymer can 
be recycled without losing much 
of its functional value and 
qualities such as durability  
• There is a need to specify the 
material content of recycled 
materials, including the  INF/TE/IDP/RD/10 2 
 
- 5 - 
 
  material composition, such as 
presence and concentration of 
additives.  
• A further consideration is 
whether  variati ons in threshold 
levels among countries for 
recycled content requirements 
are appropriate.  
☐ compostable  ▪ Differentiation is needed on 
whether a product is naturally 
compostable or home 
compostable (under what 
conditions and in what time 
frame) or if th ere is a need for 
special composting facilities  
▪ Producers and vendors of 
‘compostable ’ plastics should  be 
required to specify that these 
are  “compostable for industrial 
compostin g” where they do not 
decompose in the natural 
environment and have similarly 
damaging  effects to other 
plastics (Oceana, 2022).  
▪ According to the EU, 
“Compostable packag ing means 
packaging capable of 
undergoing physical,  chemical, 
thermal or biological 
decomposition such that most 
of the finished  compost 
ultimately decomposes into 
carbon dioxide, mineral salts, 
biomass and  water, […] and 
does not hinder the separate 
collection and the composting 
process or activity into which it 
is introduced in industrially 
controlled condition ” (European 
Commission, 2022).  
 • Oceana (2022).  
Bioplastic Remains Plastic : 
Bio-based, biodegradable  
and compostable plastics . 
https://europe.oceana.org/wp -
content/upload s/sites/26/2022/11/
FACTSHEET -BIOPLASTIC -REMAINS -
PLASTIC.pdf  
 
• European Commission (2022).  
Commission proposal on 
packaging and packaging waste, 
amending Regulation (EU) 
2019/1020 and Directive (EU) 
2019/904, and repealing Directive 
94/62/EC. Under Article 3 -
"Definitions" on page 53  
 
 
☐ plastic -related 
emissions  ▪ This terms covers all emissions 
across the life cycle of a plastic 
product, including emissions in 
terms of air, water or terrestrial 
pollution linked to production 
through to  end of life.   
☐ waste 
management 
technologies  This term refers to a broad range of 
technologies for sorting, collection, 
management, recycling and clean 
up of plastic waste. The 
sustainability credentials of 
different waste management 
technologies varies, including their 
appropriateness for local 
employment and social 
circumstances and priorities, as well 
as their environmental implications. 
The GHG emissions intensity of 
different waste management 
technologies varies as do chemical 
emissions and toxicity of the waste  INF/TE/IDP/RD/10 2 
 
- 6 - 
 
  mana gement processes and the  
products generated. In short, not all 
waste management technologies 
are environmentally sound and their 
effectiveness and environmental 
credibility will depend on local 
regulatory systems and 
enforcement, as well as on 
capacities for the operation and 
maintenance of technologies.  
☐ Other    
 
2) HS code identification exercise, and trade -related measures enabling substitution of 
single -use plastic products (SUPP) and other “problematic” goods by sustainable 
materials.  
 
Q. Please indicate what " environmentally sustainable and effective substitutes and alternatives " are 
already being traded – even if not perfect/ideal solutions – and their identification codes under the 
Harmonized Commodity Description and Coding System (H S) – even if those codes currently cover 
other products.  
 
As noted in a 2022 report from UNCTAD:  
“From a trade -policy perspective, identifying plastic substitutes, particularly end -use products, 
within the Harmonized Commodity Coding and Description System  (HS) is not easy. Whereas 
some natural fibre feedstocks such as jute and sisal have their own specific HS code at the 
six-digit level (the most detailed level at which product codes are harmonized globally), others 
such as banana and areca leaves are “hid den” within broader six -digit codes that include a 
large number of vegetable plaiting materials such as bamboo, reeds and rushes. Similarly, 
although paper, paperboard, and products made from paper and paperboard are relatively 
easy to identify, drinking s traws made from wheat fibre are classified under a broader category 
that includes baskets and other articles made from vegetable materials. This makes it 
challenging to calculate precisely the global trade flows in these straws” (UNCTAD, 2022) . 
 
Illustrati ve examples are highlighted in the tables below.  
 
Non-plastic Substitutes  - Feedstocks (Illustrative Examples)  
Feedstock [Category]  HS code  
 HS subheading description  
Paper and cardboard  
[Natural Fibres]  4811.90  
 Other paper, paperboard, cellulose wadding and webs of 
cellulose fibres  
Jute  
[Natural Fibres]  5303.10  
 
 Jute and other textile bast fibres, raw or retted  
Sisal 
[Natural Fibres]  5607.21  Binder or baler twine;Of sisal  
5607.29  Other;Of sisal  
Banana leaves  
[Agriculture by -product]  1401.90  
 Vegetable materials of a kind used primarily for plaiting (for 
example, bamboos, rattans, reeds, rushes, osier, raffia,  
cleaned, bleached or dyed cereal straw, and lime bark);Other  
Cotton  
[[Natural Fibres]  5201.00  
 Cotton;not carded or combed  
Hemp  
[Natural Fibres]  5302.10  
 True hemp, raw or retted  
Coconut Husks  
[Natural Fibre]  
 5305.00  Coconut, abaca (Manila hemp or Musa textilis Nee), ramie and 
other vegetable textile fibres, not elsewhere specified or 
included,  raw or processed but not spun; tow, noils and waste 
of these fibres (including yarn waste and garnetted stock)  
Areca leaf  
[Agriculture by -product]  
 1401.90  
 Vegetable materials of a kind used primarily for plaiting (for 
example, bamboos, rattans, reeds, rushes, osier, raffia,  
cleaned, bleached or dyed cereal straw, and lime bark);Other  
Wheat husks  
[Agriculture by -product]  1213.00  Cereal straw and husks, unp repared, whether or not chopped, 
ground, pressed or in the form of pellets  INF/TE/IDP/RD/10 2 
 
- 7 - 
 
  Bamboo wood  
[Natural vegetable material]  4409.21  Wood (including strips and friezes for parquet flooring, not 
assembled) continuously shaped (tongued, grooved, rebated, 
chamfered, V -jointed, beaded, moulded, rounded or the like) 
along any of its edges, ends or faces, whether or not planed, 
sanded or end -jointed.  
-Of Bamboo  
4412.10  Plywood, veneered panels and similar laminated wood  
-Of bamboo  
Glass  
[Mineral Product]  7001.00  Cullet and other waste and scrap of glass; glass in the mass  
Aluminium  
[Mineral Product]  7601  
 Unwrought aluminium  
 7602  Aluminium waste and scrap  
 
Non-plastic Substitutes  - Products  
Compostable or recyclable 
substitute  HS code  
 HS subheading description  
Grocery and other bags (paper)  
[Grocery bags/packaging]  
 4819.30  
 Sacks and bags, having a base of a width of 40  cm or more; 
of paper, paperboard, cellulose wadding or webs of cellulose 
fibres  
4819.40  
 Other sacks and bags, including cones; of paper, 
paperboard, cellulose wadding or webs of cellulose fibres  
Grocery and other bags (jute)  
[Grocery bags/packaging]  
 6305.10  Sacks and bags, of a kind used for the packing of goods; Of 
jute or of other textile bast fibres of heading 5303  
Grocery and other bags (cotton)  
[Grocery bags/packaging]  
 6305.20  
 Sacks and bags, of a kind used for the packing of goods; Of 
Cotton  
Grocery and other bags (hemp)  
[Grocery bags/packaging]  
 6305.90  
 Sacks and bags, of a kind used for the packing of goods; Of 
other textile materials  
Take-out/take -away containers 
and plates for food (Of paper 
and paperboard)  
[Food containers & 
accessories]  
 4819.10  
 Cartons, boxes and cases, of corrugated paper or 
paperboard  
4819.20  
 Folding cartons, boxes and cases, of non -corrugated paper 
or paperboard  
4823.69  
 Trays, dishes, plates, cups and the like, of paper or 
paperboard;Other  
Take-out/take -away containers 
and plates for food (Of 
banana/plantain/areca leaves)  
[Food containers & 
accessories  4602.19  
 Basketwork, wickerwork and other articles, made directly to 
shape from plaiting materials or made up from goods of 
heading  4601; articles of loofah; Of Other vegetable 
material s 
Take-out/take -away containers 
and plates fo r food (Of coconut 
husks)  
[Food containers & 
accessories]  4602.19  
 Basketwork, wickerwork and other articles, made directly to 
shape from plaiting materials or made up from goods of 
heading  4601; articles of loofah; Of Other vegetable 
materials  
 
Paper str aws 
[Food containers & 
accessories]  
 4823.90  
 Other paper, paperboard, cellulose wadding and webs of 
cellulose fibres, cut to size or shape; other articles of paper 
pulp, paper, paperboard, cellulose wadding or webs of 
cellulose fibres; Other  
Wheat fibre straws  
[Food containers & 
accessories]  
 4602.19  
 Basketwork, wickerwork and other articles, made directly to 
shape from plaiting materials or made up from goods of 
heading  4601; articles of loofah; Of other vegetable 
materials  
Bamboo crockery and cu tlery 
[Food containers & 
accessories]  4419.11  Tableware and kitchen ware of bamboo  
- Bread boards, chopping boards and similar boards  
 4419.12  Chopsticks  
 4419.19  Others  INF/TE/IDP/RD/10 2 
 
- 8 - 
 
  Glass bottles  
[Liquid containers]  
 7010.90  
 Carboys, bottles, flasks, jars, pots, phials, ampoules and 
other containers, of glass, of a kind used for the 
conveyance or packing of goods; preserving jars of glass; 
stoppers, lids and other closures, of glass; Other  
Aluminium bottles  
[Food containers & single 
use accessories]  
 7612.9 0 
 Aluminium casks, drums, cans, boxes and similar containers 
(including rigid or collapsible tubular containers), for any 
material (other than compressed or liquefied gas), of a 
capacity not exceeding 300  litres, whether or not lined or 
heat-insulated, but not fitted with mechanical or thermal 
equipment; Other  
 7615.10  
 Table, kitchen or other household articles and parts thereof; 
pot scourers and scouring or polishing pads, gloves and the 
like; Of aluminium  
 7616.99  
 Other articles of aluminium; Other  
Source: UNCTAD (2022). Substitutes for Single -Use Plastics in Sub -Saharan Africa and South Asia: Case Studies from 
Bangladesh, Kenya and Nigeria.  https://unctad.org/system/files/official -document/tcsditcinf2022d3_en.pdf  
 
3) Illustrative and extended list of material substitutes and material identification 
exercise  
 
Q. Please indicate the key criteria to be considered when identifying environmentally  sustainable 
and effective substitute materials. Please provide examples of such materials as well as relevant HS 
codes if available.  
 
• End of life -performance upon disposal into the natural environment (including time taken for 
biodegradation and compostability in both soil and oceans)  
• Not composed of synthetic or semi -synthetic polymers (with the exception for recycled 
plastics)  
• Non-use of any toxic chemicals or additives  
• Environmental sustainability should be considered using a life -cycle perspective, with a focus 
on environmental impact as possible along indicators including terrestrial, air and water 
pollution as well as related impac ts. Environmental impacts linked to the production of 
particular substitutes may depend on the specific national context.  
• As much as possible meeting the same end -use functionality as the conventional plastic 
material it is intended to replace.  
 
For a samp le of such materials, please see the section on HS codes above.  
 
4) Minimum criteria for life cycle analysis, including other considerations such as 
tradability, non -toxicity, affordability, accessibility, and availability.  
 
Q. What are the key criteria th at should be included in the life cycle analysis (and other 
considerations such as  tradability, non -toxicity, affordability , accessibility, and availability ) of 
plastics, their alternatives, and substitutes.  
 
Environmental criteria  
 
• Land-use changes involv ed in the production of feedstocks  
• Water -use involved in the production of feedstocks  
• Natural availability in a specific country context  
• Non-use as far as possible of primary biomass i.e. higher scores for the use of agro -waste 
feedstocks (if plant -based m aterials are considered)  
• Greenhouse gas emissions involved in the production and processing of feedstocks as well 
as manufacture of products  
• Greenhouse gas emissions arising from open landfills and covered landfills  
• Air pollution impacts of open burning or  incineration  
• Time taken for biodegradability in soils, fresh -water and sea -water under different 
temperature conditions and depths and propensity to erode into micro -particles during that 
time that could be harmful for terrestrial and marine life  
• Eco-toxicity upon open disposal due to presence of harmful chemicals or additives  INF/TE/IDP/RD/10 2 
 
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  • Existence and extent of specific environmentally sound waste management infrastructure 
available in a country (if this is required for safe end of life disposal. For e.g. industrial 
composting facilities for many bio -based plastics)  
 
Other considerations  
• Established and existing use and acceptability in a country  
• Export potential for developing countries  
• Promotion of rural livelihoods particularly among small farmers  
• Affordability and potential for scale -up (this needs to considered in the context of artificially 
low costs of virgin plastic feedstocks due to fossil fuel subsidies as well as other subsidies 
that may be provided directly for production of primary plastic s and final plastics products)  
 
 
 
__________