INF/TE/IDP/RD/88/Rev.1  
 
27 January 2023  
(23-0663) Page: 1/30 
  Original: English  
 
 
UNOFFICIAL ROOM DOCUMENT1 
 
DIALOGUE ON PLASTICS POLLUTION  
AND ENVIRONMENTALLY SUSTAINABLE PLASTICS TRADE  
FACTUAL SUMMARY OF DISCUSSIONS ON SUSTAINABLE AND EFFECTIVE  
ALTERNATIVES AND SUBSTITUTES   
Revision  
Workshop 6 December 2022  
_______________  
 
 
 
  
 
1 Documents issued in the RD series are not official WTO documents. They are intended for use in the 
WTO meeting rooms and are attributed an unofficial symbol for archiving purposes only.  INF/TE/IDP/RD/88/Rev.1  
 
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DIALOGUE ON PLASTICS POLLUTION AND ENVIRONMENTALLY SUSTAINABLE  
PLASTICS TRADE   
FACTUAL SUMMARY OF DISCUSSIONS ON SUSTAINABLE AND EFFECTIVE  
ALTERNATIVES AND SUBSTITUTES  
Revision  
1. In furthering the objectives of the 2021 Ministerial S tatement2, the Dialogue's Plan for 20223 
envisaged, under the workstream "Promoting Trade to Tackle Plastic Pollution", discussions 
covering  inter alia sustainable and effective substitutes and alternatives, as well as technologies 
for such substitutes and alternatives of interest to developing Members and least developed 
Members . During early discussions in the year, a proposal was made to organize a dedi cated 
workshop on the topic to help advance technical work.4 Coordinators agreed to do so as reflected 
in their Ministerial Statement adopted at the 12th Ministerial Conference.5 The objective of the 
workshop was to provide a strong basis for discussions in 2023 in moving towards expanding 
trade in environmentally sustainable and effective substitutes and alternatives and help 
implement the call from the Dialogue co -sponsors Ministers to "look for concrete, pragma tic, 
and effective outcomes … at the latest by the 13th Ministerial Conference. "6 
2. The exploratory workshop on sustainable alternatives and substitutes to plastic  (the Workshop) , 
organized in cooperation with the United Nations Conference on Trade and Deve lopment 
(UNCTAD), took  place on 6 December 2022  and cover ed four specific issues: (i) working 
definitions for terms relevant to trade in substitutes and alternatives; (ii) Harmonized 
Commodity Description and Coding System (HS) code identification exercise  and trade -related 
measures enabling substitution of single -use plastic products (SUPP) and other "problematic" 
goods by sustainable materials; (iii) illustrative and extended list of material substitutes and 
material identification exercise; and (iv) mini mum criteria for lifecycle analysis and affordability, 
accessibility and availability. The objective of this Factual Summary is  in turn  to compile and 
showcase the wealth of information produced by the Dialogue on the se topics both before and 
in the wake o f the Workshop.  
3. In total, since the Dialogue's first 2021 meeting7 and up to the date of the Workshop, 
60 interventions (presentations and statements) were made on topics directly related to trade 
promotion to tackle plastic pollution by 15 different dele gations, 18 stakeholders and by the 
WTO Secretariat (see table 1 below). Most interventions (32) took place in the last two pre -
plenary meetings (September and November 2022) and at the last plenary meeting before the 
Workshop (October 2022).  
  
 
2 See Ministerial Statement on Plastic Pollution and Environmentally Sustainable Plastics Trad e 
(WT/MIN(21)/8/Rev.2 ), 10 December 2021.  
3 See Dialogue Plan 202 2 (INF/TE/IDP/W/5 ), 21 February 2022.  
4 Aide Memoire  (INF/TE/IDP/RD/41 ), 11 May 2022 Pre -Plenary  Meeting, para. 12.  
5 See Ministerial Statement by Coordinators on Plastic Poll ution and Environmentally Sustainable Plastics 
Trade (WT/MIN(22)/12) , 13 June 2022.  
6 See Ministerial Statement on Plastic Pollution and Environmenta lly Sustainable Plastics Trad e 
(WT/MIN(21)/8/Rev.2 ), 10 December 2021.  
7 One intervention captured by this Factual Summary was made at the Committee on Trade and 
Environment in 2019, specifically by Bangladesh.  INF/TE/IDP/RD/88/Rev.1  
 
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  Table 1: Delegations and Stakeholders who intervened on topics related to trade 
promotion to tackle plastic pollution  
Australia  Ecuador  Maldives  Russian Federation  
Bangladesh  European Union  Morocco  Switzerland  
China  Guatemala  New Zealand  United Kingdom  
Colombia  Jamaica  Philippines   
ALADI  IISD Plastics Recyclers Europe  World Bank  
Aptar Group  INBAR  TESS WEF 
CIEL Nestle  UNCTAD  Yves Rocher Foundation  
FAO OECD  UNEP  Global Plastics Policy Centre 
(University of Portsmouth)  QUNO  Pew Charitable Trusts  WBCSD  
 
4. Delegations provided 26 interventions, stakeholders 29, and the WTO Secretariat 5 (see graph  1 
below). Interventions covered a wide range of topics and mostly consisted of concrete 
suggestions (25) and actionable points (22) related to trade promotion to tackle plastic pollution, 
including related to the topics covered by the Workshop. These were followed by observations 
(15), challenges (9), and domestic policies (7).8 Specifically on the topics covered by the 
Workshop, 21 interventions provided elements related to "minimum criteria for lifecycle analysis 
and affordability, accessibility and availability ", 14 related to "working definitions ", 12 related to 
"illustrative  and extended list of material substitutes and material identification exercise ", and 
nine to "HS code identification exercise and trade -related measures enabling substitution of 
SUPP and other 'problematic ' goods by sustainable materials ." 
Graph 1:  Breakdown of interventions by delegations, stakeholders and the WTO 
Secretariat  
 
5. In the following sections, a summary of the interventions related to each of the topics covered 
by the Workshop is provided.  
1  WORKING DEFINITIONS FOR TERMS  RELEVANT TO TRADE IN SUBSTITUTES AND 
ALTERNATIVES  
6. The 2021 Ministerial Statement highlights the  importance of continuing to engage and support 
actions in other international processes, including  definitions. The Dialogue's  participants have 
noted that an  important aspect of transparency is to build better understanding of the 
terminology commonly used in regard to plastics, plastic substitutes, and circularity in ways that 
are relevant to trade and trade policy discussion s.9 The need to develop certain  working 
definitions  for terms like substitutes, alternatives, reusable, compostability, recyclability, 
biodegradab ility was raised early in the discussions.10 It was suggested that t entative working 
 
8 Each intervention could include simultaneously suggestions, actionable points, observations, challenges 
and/or dome stic policies. In this sense, the total number of these add up to more than the total number of 
interventions.  
9 Aide Memoire  (INF/TE/IDP/RD/41 ), 11 May 2022 Pre -Plenary , para. 11.  
10 UNCTAD  presentation  (INF/TE/IDP/RD/36 ), 11 May 2022 Pre -Plenary Meeting . 29, 49%
26, 43%5, 8%
Stakeholder
Members
SecretariatINF/TE/IDP/RD/88/Rev.1  
 
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  definitions could be developed for terms such as plastic; microplastic; plastic substitutes; plastic 
alternatives; environmentally sustainable; effective; single -use; reusable; biodegradable; 
erodible; recyclable; recyclable content; compostable; plastic -related emissions; waste 
managem ent technologies.   
7. Several Members and stakeholders highlighted that in the absence of international ly agreed 
definitions on plastic substitutes and alternatives, many international bodies had adopted their 
own definitions, for example the United Nations Environment Programme ( UNEP ), Basel 
Convention , and the International Organization for Standardization ( ISO). One Member observed 
that the WTO also need ed its own set of definitions  which should  have a trade facilitating  
function. One important considerati on in this regard was  that the definitions had to  be identifiable 
or testable at the border.11 
8. One stakeholder emphasized that while Public International Law already addressed alternatives 
and substitutes to other forms of pollutants or substances of conce rn, it did not make a clear 
differentiation between substitutes and alternatives. There were also several principles of 
international environmental law that had to be taken into consideration when identifying or 
liberalising trade in alternatives and subst itutes to plastics: (i) the precautionary principle and 
the polluter -pays principle in the Rio Declaration; (ii) the principle of self -sufficiency and the 
principle of prevention mentioned in other international legally binding treaties; and (iii) the no 
harm principle of customary international law.12 It also underscored that, in order to effectively 
compare substitutes or alternatives, it was first of all essential to understand the negative 
lifecycle  impacts of plastic thoroughly. Furthermore, when  searching for alternatives to plastics 
it could  be useful to proceed with an ecological or "true cost" approach asking the following 
questions: (i) is there really a serious societal need for the plastic pr oduct? Does the value of 
the product in performing that need exceed the true costs of the product including the damage 
created in its lifecycle , including the extended life of the plastic once produced and becomes 
waste? (ii) Is there a way to fulfil the s ame societal need ( e.g. without plastics), that can increase 
the ratio of societal worth over costs of damage done (negative externalities)?13  
9. One stakeholder noted that it was not only single -use plastics ( SUP) that were the challenge but 
also unnecessar y and problematic plastics. This included inter alia recyclable plastics that in 
practice were uneconomic or too difficult to recycle due to their size or how they were combined 
or multi -layered with other plastics. Therefore, there was a  need for harmoniz ed definitions .14 It 
was also observed that alternatives were usually heavier than plastic packaging which increased 
logistics costs, consumption of fuel, and the intensity of transport units ' usage. Alternatives could 
increase the mass of packaging waste, reduce food shelf life, and have a potential to contribute 
even more to both consumption and waste due to the food spoilage and transportation losses. 
All these factors had to be carefully co nsidered.15 
10. Across the meetings, discussions and written submissions, a series of proposed definitions were 
put forward by delegations and stakeholders . In addition, several stakeholders responded to the 
guiding questions circulated along with the Workshop  agenda.16 In particular, UNEP provided a 
written submission17 to the Workshop reflecting relevant definitions used in two documents  
prepared  for the first session of the intergovernmental negotiating committee (INC-1) launched 
by the United Nations Enviro nmental Assembly (UNEA) to develop an international legally 
binding instrument on plastic pollution, including in the marine environment .18 The table below 
reflects d efinitions and key elements to be taken into account, as suggested by  participants and  
stakeholders  at the Dialogue's pre -plenary and plenary meetings, as well as in response to the 
guiding questions to the Workshop : 
 
11 Informal summary, 7 December 20 22 Plenary Meeting. (forthcoming)  
12 CIEL submission to the Workshop ( INF/TE/IDP/RD/80 ). 
13 CIEL presentation ( INF/TE/IDP/RD/79 ), 17 November 2022 Pre -Plenary Meeting.  
14 University of Portsmouth statement ( INF/TE/IDP/RD/68 ), 17 October 2022 Pre -Plenary Meeting.  
15 Informal Summary ( INF/TE/IDP/R/8 ), 11 October 2022, Plenary Meeting.  
16 Workshop on sustainable alternatives and substitutes to plastic  agenda and guiding questions  
(INF/TE/IDP/RD/87 ). 
17 UNEP submission to the Workshop ( INF/TE/IDP/RD/91 ) 
18 The documents are: Glossary of key terms , Note by UNEP Secretariat ( UNEP/PP/INC.1/6 ); and Plastic 
Science, Note by UNEP Secretariat ( UNEP/PP/INC.1/ 7). INF/TE/IDP/RD/88/Rev.1  
 
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  Table 2: Working definitions for terms relevant to substitutes and alternatives raised in 
the context of Di alogue discussions  
CONCEPT  KEY ELEMENTS  
Plastic  Usually a synthetic material, either a polymer or combination of 
polymers of high molecular mass modified or compounded with 
additives such as fillers, plasticizers, stabilizers, lubricants, pigments. 
According to ISO , "plastic is a material which contains as an essential 
ingredient a high polymer and which, at some stage in its processing 
into finished products, can be shaped by flow ". Polymers are natural 
or synthetic substances composed of very large molecules, called 
macromolecules, that are multiples of simpler chemical units called 
monomers. There are a number of detailed definitions of the term 
"polymer ", such as by the OECD .19 
Plastic means a solid material which contains as an essential 
ingredient one or more high -molecular -mass polymers and which is 
formed (shaped) during either manufacture of the polymer or the 
fabrication into a finished product by heat and/or pressure. Pla stics 
have material properties ranging from hard and brittle to soft and 
elastic.20 
Micro -plastics  Generic term for small pieces of plastic under 5 mm.21 
Sources, challenges are related to its "behavio ur": chemical ( e.g. 
POPs), physical, and biological effects .22 
Primary and secondary microplastics .23 
Microplastics refers to plastic particles less than five millimeters in 
diameter, including nano -sized particles.  There is ongoing debate 
about the size limit; the definition of microplastics as particles less 
than 5 mm in diameter is used.  
Microplastics are categorized into primary and secondary . Primary 
microplastics are manufactured to carry out a specific function (e.g., 
cosmetics, abrasive cleaning beads).  Secondary microplas tics result 
from wear and tear or fragmentation of larger objects, both during use 
and following loss to the environment.24 
 
19 BRS submission to th e Workshop  (INF/TE/IDP/R D/85), referring to Draft technical guidelines on the 
environmentally sound management of ESM of plastic wastes (TG on ESM of plastic waste) . 
20 UNEP submission to the Workshop, referring to Amendment to the annex of the Protocol of 1978 
Relating to the Int ernational Convention for the Prevention of Pollution from Ships (MARPOL), resolution 
MEPC.201(62), annex, "Revised MARPOL annex V ", regulation 1.13 . 
21 "Addressing Single -use Plastic Products Pollution Using a Life Cycle Approach" , UNEP 2021. 
22 BRS submission to th e Workshop  (INF/TE/IDP/RD/85 ), referring to UNEP Brochure Microplastics 
(https://wedocs.unep.org/bitstream/handle/20.500.11822/12079/brochure -
microplastics. pdf?sequence=1&amp%3BisAllowed=) . 
23 Response to Workshop guiding questions.  
24 UNEP submission to the Workshop, referring to U nited Nations Environment Assembly resolution 2/11, 
"Marine litter and microplastics ", para. 1 ; Plastics science. Note by the secre tariat, Appendix I 
(UNEP/PP/INC.1/7), building on UNEP, From Pollution to Solution: A Global Assessment of Marine Litter and 
Plastic Pollution (Nairobi, 2021); M. Cole and others, "Microplastics as contaminants in the marine environment: 
A review ", Marine Pollution Bulletin, vol. 62, no. 12 (Dec. 2011), pp. 2588−2597; and Joint Group of Experts on 
the Scientific Aspects of Marine Environmental Protection, Sources, Fate and Effects of Microplastics in the Marine 
Environment: A Global Assessment (London, Inte rnational Maritime Organization, 2015) . INF/TE/IDP/RD/88/Rev.1  
 
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  Plastics substitutes  Non-polymer natural materials from mineral, marine, plant, or animal 
origin, that have similar properties of f ossil fuel -based plastics. They 
should have lower environmental impact along their life cycle (e.g., 
natural fibers, agricultural wastes, and other forms of biomass). 
Depending on the case, they should be biodegradable/compostable or 
erodible, and should b e suitable for reuse, recycling, or sound waste 
disposal as defined by national, regional regulations or in 
internationally agreed definitions. They can include by -products. 
Plastic substitutes should not be hazardous for human, animal, or plan 
life.25 
Similar or better quality than plastics .26 
International legal instruments mention that when looking at 
substitute materials or activities a particular consideration needs to be 
given to the potential environmental benefits or penalties of substitute 
materials or activities (i.e. negative externalities).27 
Substitutes should offer the same level of functionality. For instance, if 
substituting plastic with another material for packaging leads to 
product  losses and waste, the environmental i mpact will likely be more 
important than that of the packaging - this trade -off should be 
avoided .28 
Plastic alternatives  They can include bioplastics or biodegradable plastics. The former 
term usually means polymers materials produced from renewable 
biomass sources (e.g., vegetable fats and oils, corn starch, straw, 
woodchips, sawdust, and recycled food waste) and should be subject 
to material recycling. The latter usually refers to the end of life of 
plastics indicating that they biodegrade  in the natural environment, or 
they can be composted. They can include their by -products. Plastic 
alternatives should not be hazardous for human, animal, or plan life. 29 
Similar or better quality than plastics .30 
An alternative reduces or efficiently eliminates [pollution] : Art. 1(4) 
Convention for the Protection of the Ozone Layer : "Alternative 
substances" means substances which reduce, eliminate or avoid 
adverse effects on the ozone layer . 
International agreements emphasize that human health risks and 
environmental implications of alternatives need to be promoted when 
identifying alternatives (could also be applied to substitutes), as well 
as their economic and social costs .31 
Parties to the Basel Convention and others are invit ed to significantly 
reduce SUPP, notably through specific measures, such as the 
development of affordable and environmentally friendly  alternatives, 
the use of substitutes for such products where alternatives are 
economically available, the reduction in th eir consumption . 
Alternative materials with less environmental impact or by reducing 
the size of the products .32 
 
25 UNCTAD  submission to the Workshop  (INF/TE/IDP/RD/83 ). 
26 Response to questions circulated by the WTO Secre tariat.  
27 CIEL submission to the Workshop ( INF/TE/IDP/RD/80 ). 
28 Response to Workshop guiding questions.  
29 UNCTAD submission to the Workshop  (INF/TE/IDP/RD/83 ). 
30 Response to questions circulated by the WTO Secretariat.  
31 CIEL submission to the Workshop  (INF/TE/IDP/RD/80 ). 
32 BRS submission to th e Workshop  (INF/TE/IDP/RD/85 ), referring to Decision BC -14/13: Further actions 
to address plastic waste under the Basel Convention (section II on Preventing and minimizing the generation of 
plastic waste, improving its environmentally sound management and controlling its transboundary movement)  
and TG on ESM of plastic wastes (draft) . INF/TE/IDP/RD/88/Rev.1  
 
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  Alternatives providing the same service .33 
Environmentally 
sustainable  Alternatives and substitutes that do not  generate waste.34 
Substitution by multi -use products preferable to substitution of a 
single -use (plastic) product by another single -use (e.g. paper) 
product.35 
Substitute or alternative materials  that have far less negative impactful 
externalities  than plastics.36  
Truly circular alternatives and substitutes  that are toxic free.37 
Must not  contribute more than plastics  to consumption and waste due 
to food spoilage and transportation losses.38 
Renewable .39 
Competitive price .40 
Holistic approach of environmental impacts, consideration of trade -
offs.41 
Effective (including 
cost and functionally 
effective)  Air and water permeability, water solubility, customer equipment and 
handling requirements, tensile strength, failure rate, part or total 
replacement costs, supply availability risk, lead time, upper and lower 
capacity constraints .42 
Need for improved access to cost -effective and environmentally 
friendly alternatives to plastics, in particular SUP, in developing 
countries .43  
Opportunities for  displacing plastic imports in domestic marketplace in 
some developing countries, while also supporting livelihoods in rural 
communities, including by generating employment for women.44 
Accessible and available with  a preference for indigenous and/or 
localized/regional supply chains ; integrating the notion of industrial 
development .45 
Disposable .46 
Single -use Not conceived, designed , or placed on the market to accomplish, 
within its life span, multiple trips or rotations by being returned to a 
producer for refill or re used for the same purpose for which it was 
conceive d.47 
Made wholly or partly from plastic and that is single -use; no threshold 
for a minimum level of plastic content, i.e. considered a single -use 
plastic product as soon as it contain s any amount of plastic.48 
 
33 Response to Workshop guiding questions.  
34 CIEL statement  (INF/TE/IDP/RD/66 ), 19-20 September 2022 Pre -Plenary  Meeting.  
35 Aide Memoire ( INF/TE/IDP/R/9 ), 17 November 2022 Pre -Plenary Meeting, para. 17.  
36 CIEL statement (INF/TE/IDP/RD/79 ), 17 November 2022 Pre -Plenary Meeting.  
37 CIEL statement ( INF/TE/IDP/RD/79 ), 17 November 2022 Pre -Plenary Meeting.  
38 Informal Summary ( INF/TE/IDP/R/8 ), 11 October 2022, Plenary Meeting.  
39 Response to Workshop guiding questions.  
40 Response to Workshop guiding questions.  
41 Response to Workshop guiding questions.  
42 FORTUNA COOLS submission to the Workshop  (INF/TE/IDP/RD/84 ). 
43 3rd co-sponsors meeting, June 2021.  
44 TESS Statement ( INF/TE/IDP/RD/63/Rev.1 ), 11 May 2022 Pre -Plenary  Meeting.  
45 Aide Memoire  (INF/TE/IDP/R/9 ), 17 Novembe r 2022 Pre -Plenary Meeting.  
46 Response to Workshop guiding questions.  
47 Aide Memoire ( INF/TE/IDP/R/9 ), 17 November 2022 Pre -Plenary Meeting.  
48 Aide Memoire ( INF/TE/IDP/R/9 ), 17 November 2022 Pre -Plenary Meeting.  INF/TE/IDP/RD/88/Rev.1  
 
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  UNEA -4 resolution 9 on "Addressing SUPP pollution " encourages 
member States to develop and implement actions to address the 
environmental impacts of SUPP, identify environmentally friendly 
alternatives to SUP, promote improved waste management and more 
resource -efficient design, production, use and sound mana gement of 
plastics across their life cycle .49 
SUPP are designed and produced to be used once before being thrown 
away or recycled.50 
Single -use plastic 
product  Plastic products not conceived, designed, or introduced into the 
market for multiple circuits, rotations, or uses throughout their life 
cycle but designed to be used only once and with a short useful life ; 
useful life was understood as the average time in w hich the product 
performs its function.51 
Single-use (low durability), non -biodegradable and non -recyclable, 
containing harmful additives, prone to leaching, and impact on inland 
waterways and oceans .52 
Key factor is extent of usage before disposal (e.g. plastic chair as 
compared to plastic packaging and cutlery)53 
Products made wholly or partly from plastic and that are not 
conceived, designed or placed on the market to accomplish, within 
their lifespan, multiple trips or rotations by being returned to a 
producer for refill or reused for the same purpose for which they were 
conceived. Often also referred to as disposable plastic products.54 
Products made from oxo -degradable plastics which degraded  into 
micro plastic  partic les when littered .55 
Particularly 
problematic 
products  Single-use (low durability), non -biodegradable and non -recyclable, 
containing harmful additives, prone to leaching, and impact on inland 
waterways and oceans .56 
Reusable  Durable .57 
Reuse of packaging: Operation by which packaging is refilled or used 
for the same purpose for which it was conceived, with or without the 
support of auxiliary products present on the market, enabling the 
packaging to be refilled.58 
 
49 BRS submission to th e Workshop  (INF/TE/IDP/RD/85 ). 
50 UNEP submission to the Workshop ( INF/TE/IDP/RD/91 ), referring to Plastics science . Note by the 
secretariat , Appendix I  (UNEP/PP/INC.1/7 ). 
51 Aide Memoire ( INF/TE/IDP/R/9 ), 17 November 2022 Pre -Plenary Meeting.  
52 Aide Memoire ( INF/TE/IDP/R/9 ), 17 November 2022 Pre -Plenary Meeting.  
53 CIEL statement ( INF/TE/IDP/RD/79 ), 17 November 2022 Pre -Plenary Meeting.  
54 "Addressing Single -use Plastic Products Pollution Using a Life Cycle Approach" , UNEP 2021. 
55 Aide Memoire ( INF/TE/IDP/R/9 ), 17 November 2022 Pre -Plenary Meeting.  
56 Aide Memoire ( INF/TE/IDP/R/9 ), 17 November 2022 Pre -Plenary Meeting.  
57 Response to Workshop guiding questions.  
58 "Addressing Single -use Plastic Products Pollution Using a Life Cycle Approach" , UNEP 2021. INF/TE/IDP/RD/88/Rev.1  
 
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  Waste management hierarchy: rec ognized by decision BC -10/2 as 
prevention, minimization, reuse, recycling, other recovery including 
energy recovery, and final disposal; in doing so, encouraging 
treatment options that deliver the best overall environmental 
outcome, taking into account lif e-cycle thinking.  
Waste prevention (i.e. strict avoidance, source reduction and direct 
reuse), while part of waste minimi zation (that also covers reuse and 
recycling), is fundamentally different from all other activities within 
the waste management hierarc hy as it is implemented before products 
or materials become wastes. Waste prevention measures occur prior 
to waste management, as part of strategies and actions promoting or 
even mandating environmentally sound production, trade and 
consumption.  
Waste pre vention may involve the following strategies:  
(a) Strict avoidance involves the prevention of waste generation by 
elimination of the need for a product, or material, or by a reduction of 
hazardous substances and inputs, or by reducing material or energy 
intensity in production, consumption, and distribution. Strict avoidance 
also includes designing products for prolonged life. Waste prevention 
in this latter context extends the life of products and acts as a 
diversion of waste flows;  
(b) Source reduction involves altering production processes to 
minimize the use of toxic or harmful substances and/or minimizing 
material or energy consumption and/or maximally substituting 
primary raw materials with secondary raw materials that result from 
high quality recycl ing. Waste prevention in this context reduces or 
eliminates waste and pollution at source through process changes;  
(c) Direct reuse means the using again of a product, object or 
substance that is not waste for the same purpose for which it was 
conceived wi thout the necessity of repair or refurbishment .59 
Biodegradable  Biodegradable in natur al condition .60 
Capable of biodegrading under biological process of organic matter, 
which is completely or partially converted to water, CO2/methane, 
energy and new biomass by microorganisms (bacteria and fungi).61 
Biodegradable plastics are plastics that can be broken down by living 
organisms into elements that are found in nature, such as carbon 
dioxide or methane, water and biomass.  When true biodegradation is 
complete, no microplastics remain. Biodegradable plastics can be 
manufactured from renewable feedstocks or fossil fuels.  Soil-
biodegradable plastics can be broken down by organisms found in soil. 
Marine -biodegradable plastics can be broke n down by organisms found 
in seawater.62 
Oxo-degradable (also called oxo -biodegradable or oxo -plastics): Oxo -
degradable plastics contain additives that cause them to break down 
under favourable conditions, most often ultraviolet radiation or heat. 
Oxo-degradable plastic fragments into smaller and smaller plastic 
particles but has not yet been shown to truly biodegrade, raising 
concerns that oxo -degradable plastics are a source of microplastics.63 
 
59 BRS submission to th e Workshop  (INF/TE/IDP/RD/85 ), referring to Practical manual for the promotion 
of the environmentally sound management of waste: terminology  (footnotes omit ted).  
60 Response to Workshop guiding questions.  
61 "Addressing Single -use Plastic Products Pollution Using a Life Cycle Approach" , UNEP 2021. 
62 "Single -Use Plastics Products and their alternatives: Recommendations from Life Cycle Analysis" , 
UNCTAD 2022.  
63 "Single -Use Plastics Products and their alternatives: Recommendations from Life Cycle Analysis" , 
UNCTAD 2022.  INF/TE/IDP/RD/88/Rev.1  
 
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  Only plastics that are completely and naturally biodegradable, and 
NOT: partially biodegrad able and form ing micro plastics , plastics that 
are biodegrade but contain toxic additives, or plastics that are 
biodegradable under industrial composting conditions but survive for 
years un der most normal environmental conditio n.64 
Biodegradable plastics are broadly understood to refer to plastics that 
can be degraded under certain conditions, such as temperature, UV, 
humidity, oxygen content and pH, by microorganisms in nature, such 
as ba cteria, mould, and algae, and turn into water or carbon dioxide 
and other small molecules. The timeframe, the level of 
biodegradation, and the environment condition required for 
biodegradation need to be provided, along with claim of 
biodegradability of pl astics (European Bioplastics, 2018). Standard 
specifications or protocols are required for biodegradability of plastics.  
Some of the available standard protocols for assessment of 
biodegradation of plastics include ISO/17556 for aerobic 
biodegradability o f plastic materials in soil, ISO/15985 for anaerobic 
biodegradation under high -solids anaerobic -digestion conditions. Both 
fossil-based plastic and bio -based plastic can be biodegradable or non -
biodegradable under certain conditions.65 
Switch to biodegradables should be carefully considered as they might 
be more ha rmful for the environment (lack of controlled waste 
management, hindering recycling systems, higher emissions, etc.) .66 
Erodible  - 
Recyclable  Recyclable under normal condition .67 
That can be effectively and efficiently collected, separated  from the 
waste stream,  sorted and aggregated into defined streams for 
recycling processes, and recycled at scale through  state-of-the-art 
processes so that it is turned into secondary raw materia l of a 
sufficient quality  so that it can find end markets to substitute for the 
use of the primary raw material or organic.68 
Material recycling: Reprocessing, by means of a manufacturing 
process, of a used (packaging) material into a product, a componen t 
incorporated into a product, or a secondary (recycled) raw material; 
excluding energy recovery and the use of the product as a fuel.69 
A packaging or packaging component is recyclable if its successful 
post-consumer collection, sorting and recycling is  proven to work in 
practice and at scale.70 
Recyclable plastics must not be  uneconomic or too difficult to recycle 
due to their size or how they were combined or multi -layered with 
other plastics.71 
 
64 WCO Statement  (INF/TE/IDP/RD/20 ), 18 March 2022 Pre -Plenary Meeting.  
65 BRS submission to th e Workshop  (INF/TE/IDP/RD/85 ), referring to Draft TG on ESM of plastic wastes 
(subject to ongoing discussions) . 
66 Response to Workshop guiding questions.  
67 Response to Workshop guiding questions.  
68 Plastic Recyclers Europe presentation ( INF/TE/IDP/RD/74 ), 17 November 2022 Pre -Plenary Meeting.  
69 "Addressing Single -use Plastic Products Pollution Using a Life Cycle Approach" , UNEP 2021. 
70 "Single -Use Plastics Products and their alternatives: Recommendations from Life Cycle Analysis" , 
UNCTAD 2022.  
71 University of Portsmouth statement ( INF/TE/IDP/RD/68 ), 17 October 2022 Pre -Plenary Meeting.  INF/TE/IDP/RD/88/Rev.1  
 
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  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; plastics, due to their 
inability to break  down in the environment into benign materials, 
equate unsightliness and damage to the aesthetics of nature and 
wilderness.72 
Plastic waste recycling (operation R3) can be categorized as follows:  
(a) Mechanical recycling, with the processing of waste plastic through 
physical sorting, size reduction, cleanin g and drying, thermal melt -
extrusion and pelletizing, and compounding;  
(b) Physical recycling, with the removal of constituents (e.g., flame -
retardants) from plastic waste while keeping the plastic polymer 
molecules chain largely intact (solvent -based pur ification);  
c) Chemical recycling, where the plastic polymer molecules chains are 
broken down (recovery of chemical constituents that have been de -
polymerized) and used as base chemicals, including feedstock for 
plastic manufacture (feedstock recycling).  
There are also specific aspects of recycling of common types of plastic 
waste (PE, PP, PS, ABS, PET, PC, PVC).  
"Recyclable " also could also be assumed as free of POPs and other 
hazardous chemicals .73 
Recycled content  Bamboo material .74 
Plastic polymers made from recycled material .75 
Compostable  Compostable in natural condition .76 
Implies that plastics will break down  which per se  is not a net positive 
unless breakdown products are benign (e.g. do not create toxicity 
issues, or microplastics) ; conditions and time by when breakdown 
takes place: Does it break down into benign compounds in a timely 
manner, and can this happen in natur e or open air environments, or  
only in industrial settings? Do the compostable products cause 
conventional waste management systems to malfunction?77 
Capable of biodegrading under specified conditions and timescales, 
usually only encountered in an indust rial composter (standards 
apply).78 
 
72 CIEL presentation ( INF/TE/IDP/RD/79 ), 17 November 2022 Pre -Plenary Meeting.  
73 BRS submission to th e Workshop  (INF/TE/IDP/RD/85 ), referring to Draft TG on ESM of plastic wastes . 
74 Response to Workshop guiding questions.  
75 BRS submission to th e Workshop  (INF/TE/IDP/RD/85 ), referring to Draft report on Global governance 
of plastics  and associated chemicals, November 2022 . 
76 Response to Workshop guiding questions.  
77 CIEL presentation ( INF/TE/IDP/RD/79 ), 17 November 2022 Pre -Plenary Meeting.  
78 "Addressing Single -use Plastic Products Pollution Using a Life Cycle Approach" , UNEP 2021. INF/TE/IDP/RD/88/Rev.1  
 
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  Plastic designed to biodegrade in a certain period of time under 
managed conditions, predominantly characterized by forced aeration 
and natural heat production resulting from the biological activity 
taking place inside the material ; biodegrades during composting but 
does not contribute to the value of the compost product, as it does not 
contain nutrients in its composition ; industrially compostable plastic 
requires conditions achieved only in industrial composting  facilities 
(i.e. temperatures over 50°C) in order to biodegrade ; standards exist 
to specify the conditions and time required in order for a material to 
be labelled as compostable ; home- or backyard -compostable plastic is 
capable of breaking down at the so il temperature and conditions found 
in home compost piles.79 
Compostable plastics are considered those plastics which have been 
tested and adhere to international standards, such as American 
Society for Testing and Materials ASTM D6400 -21 (ASTM, 2001) (in 
the U.S.) or European Standard EN 13432:2001 (European Standard, 
2001) (in Europe), for biodegradation in an industrial composting 
facility: in addition, this may be certified by a third party. For 
compostable plastics to be fully composted, disp osal must happen 
under specific conditions of temperature, moisture, oxygen level and 
microbial activity, normally found in controlled composting .80 
Switch to compostables  should be carefully considered as they might 
be more harmful for the environment ( lack of controlled waste 
management, hindering recycling systems, higher emissions, etc.) .81 
Plastic -related 
emissions  Plastic production most often equates to releasing carbon, sequestered 
as fossil fuel in the earth, into the biosphere and climate;  plastic 
production from extraction through refining and manufacturing is 
highly damaging to the environment, to workers, and communities; all 
plastics require additions of most often unknown and often harmful 
additives .82 
Bamboo products are low -carbon products to reduce high emission of 
plastics after substitution .83 
Landfilling of plastic wastes can have impacts on human health and 
the environment, in particular in non -engineered landfills or open 
dumpsites such as the potential leaching of plastics additives, particles 
and items into the wider environment. Gasification, pyrolysis and 
combustion, in particular open burning, of plastic wastes, can also 
have impacts on human health and the environment due to emissions 
and releases o f greenhouse gases; and pollutants, such as 
unintentionally produced POPs and mercury.  
Pollutant emissions related to disposal and treatment of plastic wastes 
at respective facilities can include liquids, solids, gases, and others, 
which can be determined following the specific national legislation or 
international regulations and standards .84 
 
79 "Single -Use Plastics Products and their alternatives: Recommendations from Life Cycle Analysis" , 
UNCTAD 2022.  
80 BRS submission to th e Workshop  (INF/TE/IDP/RD/85 ), referring to Draft TG on ESM of plastic wastes . 
81 Response to Workshop guiding questions.  
82 CIEL presentation ( INF/TE/IDP/RD/79 ), 17 November 2022 Pre -Plenary Meeting.  
83 Response to Workshop guiding questions.  
84 BRS submission to th e Workshop  (INF/TE/IDP/RD/85 ), referring to Draft TG on ESM of plastic wastes . INF/TE/IDP/RD/88/Rev.1  
 
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  Waste management 
technologies  Technologies are closely linked to the operations which are applied for 
the ESM of plastic wastes. There can be technologies for sortin g, 
mechanic recycling, etc. Detailed information on the technologies is 
available . 
Plastics technologies that are relevant to the environment including 
technologies for prevention, recycling, conversion or disposal of 
waste; for leakage removal; and for bio-based  feedstock .85 
 
11. One stakeholder suggested that  a glossary of terms could be developed that draws on work 
already underway and undertaken by international organizations .86 In addition to the definitions 
included in the table above, further  definiti ons were proposed in UNEP  and UNCTAD reports  of 
the term "bio-based  plastics ": "A type of plastic derived from biomass such as organic waste 
material or crops grown specifically for the purpose, which may or may not be biodegradable ."87 
and "Plastics fully or partially produced from renewable feedstocks, such as corn, potatoes and 
sugarcane, or other biomass, rather than fossil fuels. The feedstock used to produce plastic is 
independent of its ability to be biodegraded or composted. " 88  
12. Another stakeh older emphasized that a particular caution seem ed to be appropriate in the 
context of bioplastics, compostable and biodegradable plastics as possible alternative to plastics . 
The definition of the term "bioplastics " varied greatly around the world but was most commonly 
used to describe bio -based, biodegradable, and/or compostable plastics. The use of the term 
"bioplastic " brought  confusion about the difference between bio -based, biodegradable, and 
compostable materials . Just like plastics, bioplastics could  also contain toxic additives and could 
accordingly aggravate the toxification of the planet.89  
13. Stakeholders also proposed definitions of additional terms:  
• Environmentally sound  (waste)  management : Taking all practicable steps to ensure that 
hazardous was tes or other wastes are managed in a manner which will protect human health 
and the environment against the adverse effects which may result from such wastes .90 
• Environmental management system : A set of processes and practices that enable an 
organization t o reduce its environmental impacts and increase its operating efficiency. A 
waste facility should have an environmental management system (EMS) in place, taking into 
account the size of the enterprise, the level of risk associated with the operation of the  
facility and other factors relevant to implementation. An EMS is often designed to be 
integrated into the "plan, do, check and act " model for continuous improvement and many 
existing systems already use this approach. It helps to ensure that environmental  issues are 
systematically identified, controlled and monitored in the context of the need to reinforce 
continuous improvement. Several applicable EMS already exist in countries which are 
members of the Organization for Economic Cooperation and Development  (OECD): 
ISO 14001, which is worldwide; the Eco -Management and Audit Scheme (EMAS), which is 
specific to European countries and has somewhat more ambitious requirements than 
ISO 14001. Also considered to be applicable EMS are those that are tailor --made fo r 
individual circumstances – for example, systems designed for the purpose of specific 
industrial sectors or enterprises .91 
 
85 BRS submission to th e Workshop  (INF/TE/IDP/RD/85 ), referring to Draft TG on ESM of plastic wastes  
and Draft report on Global governance of plastics  and associated chemicals, November 2022 . 
86 TESS Statement ( INF/TE/IDP/RD/63/Rev.1 ), 11 May 2022 Pre -Plenary  Meeting.  
87 "Addressing Single -use Plastic Products Pollution Using a Life Cycle Approach" , UNEP 2021. 
88 "Single -Use Plastics Products and their alternatives: Recommendations from Life Cycle Analysis" , 
UNCTAD 2022.  
89 CIEL submission to the Workshop ( INF/TE/IDP/RD/80 ), referring to the Special Rapporteur on the 
implications for human rights of the environmentally sound management and disposal of hazardous substances 
and wastes, Marcos Orellana, Report on the stages of the p lastics cycle and their impacts on human rights  
(A/76/207) . 
90 BRS submission to th e Workshop  (INF/TE/IDP/RD/85 ), referring to Basel Convention, Article 2(8)  and 
ESM Framework . See also UNEP submission to the workshop.  
91 BRS submission to  the Workshop  (INF/TE/IDP/RD/85 ), referring to Practical manual for the promotion 
of the environmentally sound management of waste: terminolog y. INF/TE/IDP/RD/88/Rev.1  
 
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  • Management (of waste) : The collection, transport and disposal of hazardous wastes or other 
wastes, including after -care of disposal sites.92 
• Oxo-degradable plastic : Made by blending a pro -degradant additive into the plastic during 
the extrusion process, which accelerates the fragmentation of plastics into plastic fragments 
under certain conditions. Once the product is buried i n the soil, and out of sunlight, the 
degradation process stops and residual small plastic particles remain intact, causing the 
release of microplastics .93 
• End-of-waste : The Basel Convention does not clarify when a waste ceases to be a waste. 
The Glossary of Terms of the Basel Convention provides explanatory notes in this regard 
(UNEP, 2017f). Possibilities for waste to cease to be waste referenced in the glossary of 
terms  include when:  (i) It has been prepared for reuse;  (ii) It has undergone a recycling 
operation and that operation is completed; (iii) It has otherwise gained end -of-waste status 
as a result of a recovery operation. Some Parties have adopted conditions in t heir national 
legislation that can determine the point at which a material need no longer be classified as 
waste, such as the European Union (European Union, 2008) and the UK (English 
Environment Agency, 2016) .94 
• Recycling : Processing of waste materials fo r the original purpose or for other purposes, 
excluding energy recovery.95 
• Reuse: Use of a product more than once in its original form .96 
 
14. At the Workshop, p articipants highlighted that there were two types of definitions found in other 
international proce sses/fora: those contained in legally binding or otherwise agreed to 
documents  and those found in more soft-law documents such as draft guidelines.97 Some pointed 
to the fact that it would be important to avoid a multiplicity of competing definitions, especially 
when internationally agreed definitions already existed. Also, caution was called to ensure that 
concepts like biodegradability sufficiently took into conside ration environmental, social and 
economic elements . There seemed to be in any case broad agreement on the value of having at 
least baseline or common understandings on certain key terms, such as plastic substitutes, 
alternatives, recycling, compostability , etc. to help ensure trade promotion could be 
environmentally solid and price effective. In some cases (e.g. recycling) further disaggregation 
of terms was considered  relevant . The importance of continued close coordination with 
international processes suc h as the negotiations launched by UNEA was raised , as well as the 
need to focus on how these definitions would be useful for the Dialogue . In this regard, m any 
stakeholders offered to continue to cooperate on the topic, including by working on new 
definiti ons that might be useful for the Dialogue . Participants also heard UNCTAD's recent 
analysis on trends in plastic s trade, which ha d grown 20% in a short time span to USD 1.2 trillion 
per year, as well as on the potential for a significant increase in trade in  plastic substitutes,  
which amounted to  be  USD 3 88 billion in 20 20.98 
2  HS CODE IDENTIFICATION EXERCISE AND TRADE -RELATED MEASURES ENABLING 
SUBSTITUTION OF SINGLE -USE PLASTIC PRODUCTS (SUPP) AND OTHER "PROBLEMATIC" 
GOODS BY SUSTAINABLE MATERIALS  
15. The 2021  Ministerial Statement emphasizes the importance of identifying actions needed to 
improve gathering of data on trade flows and supply chains, including by utilizing the HS System 
of the World Customs  Organization (WCO). The HS  is an important starting poin t for 
 
92 UNEP submission to the Workshop, referring to Basel Convention, art. 2 (2). UNEP  noted that the 
definition in the Basel Convention was used for environmentally sound management of hazardous wastes or 
other wastes.  
93 BRS submission to th e Workshop  (INF/TE/IDP/RD/85 ), referring to Draft TG on ESM of plastic wastes . 
94 BRS submission to th e Workshop  (INF/TE/IDP/RD/85 ), referring to Draft TG on ESM of plastic wastes . 
95 UNEP submission to the Workshop, referring to International Organization for Standardization, "Plastics 
–Vocabulary ", document ISO:472:2013, s.2.170 6. 
96 UNEP submission to the Workshop, referring to  International Organization for Standardization, "Plastics 
–Vocabulary ", document ISO:472:2013, s.2.1708 . 
97 In both cases, there were several references to existing definitions for terms listed in the guiding 
questions shared in preparation to the workshop – including under the UNEA process, BRS conventions, ISO and 
OECD, as well as regional and domestic con texts.  
98 UNCTAD (forthcoming, 2023). Plastic pollution – The pressing case of natural and environmentally 
friendly substitutes to plastics .  INF/TE/IDP/RD/88/Rev.1  
 
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  governments and stakeholders wishing to have a more granular picture of trade flows across the 
life cycle of plastics  products and their alternatives and substitutes .  
16. Discussions highlighted that, a t present, there is no yet an internationally recog nized and 
comprehensive list (or classification) of plastics  or their alternatives and substitutes  to facilitate 
a straightforward identification99 and p articipants in the Dialogue  discussions identified 
promoting further development of the HS, and more sp ecifically classifications relevant to 
material substitutes, as an area for further exploration.100 As part of the WCO -WTO cooperation 
and as requested by the Dialogue Communication to the WCO101, the WTO Secretariat also 
shared potential areas of work the t wo organizations had agreed to. One of them included  better 
identification/differentiation of preferable goods ( e.g. through exploring additional subheadings 
for finished preferable alternatives  as well as substitutes).102 
17. The WCO summarised the  challenge  with HS code identification as follows: while t here were 
millions of products, there was limited capacity in a usable customs nomenclature with a six -
digit limit. In evaluating a proposal to add a good to the nomenclature, the WCO HS Committee 
examines the  trade value and global relevance  of the proposal , but also whether the goods have 
a high priority for reasons of "global good".103 In addition, the WCO identified several other 
important elements that need to be taken into consideration:  
• A clear rationale: taking the example of efforts to develop HS codes for biodegradable plastic 
bags, the question would be whether this is an effective way to substantially reduce plastic 
pollution from plastic bags which would gain the support of sufficient Membe rs. 
• A robust definition: a definition must be clear and protected against legal challenges. E.g. 
with biodegradable plastic bags, the absence of any globally accepted international 
standards defining the term "biodegradable plastics" meant the scope was un clear. This 
raises a number of questions, such as the meaning of the term, e.g. whether it covers 
plastics that are only partially biodegrade and form micro plastics , plastics that are 
biodegrade but contain toxic additives, or plastics that are biodegradab le under industrial 
composting conditions but survive for years under most normal environmental conditions.  
• Use of verifiable provisions: the ability of customs officials to verify whether goods claiming 
a classification actually comply is essential for a n HS provision. By a practical sense, the 
level of difficulty or the level of expense, time or resources required for such verification, 
should be reasonably within the capacity of Customs in both developed and developing 
countries. The available tests for  biodegradability of plastics involve exposing samples to 
controlled conditions and generally last between 28 days to six months. The practical 
difficulties of this at the border are clear. Given the variety of plastic materials and the 
variety of additive s to plastic that can impact biodegradability, no reliable alternative testing 
methods had been found at that point.  
• An indication of where the goods are currently classified: when goods move to a new 
provision, their duty rates are similarly transposed . It is therefore important to be able to 
identify where the goods are currently classified. In the area of plastic articles or plastic 
packaging, this is a real challenge . Plastic  packaging is one of the largest areas of hidden 
plastic s in the HS. It permeates throughout the HS, with everything from live trees to works 
of art shipped  in plastic packaging that is not separately classified. But it is also a problem 
with plastic articles. For instance, separately classifying articles made of high -shedding 
polyester fleece fabrics into their own provision would involve goods moving not on ly from 
many headings in the  textile and garment chapters, but also the movement of fleece covered 
goods from a range of headings for other goods such as toys, bedding and 
soft-furnishings.104 
 
 
99 "Plastic Pollution and Trade Across the Life Cycle of Plastics: Options for Amending the Harmonized 
System to Improve Tr ansparency ", TESS 2022.  
100 Aide Memoire ( INF/TE/IDP/R/7 ), 19 -20 September 2022 Pre -Plenary 
Meeting https://docs.wto.org/dol2fe/Pages/SS/directdoc.aspx?filename=q:/INF/TEIDP/R7.pdf&Open=True , 
para. 30.  
101 Communication to the World Customs Organization (WCO) on the Work of the IDP in Support of Efforts 
to Address Plastics Pollutio n (INF/TE/IDP/W/6 /Rev.1) , 8 June 2022 . 
102 Aide Memoire ( INF/TE/IDP/R/7 ), 19-20 September 2022 Pre -Plenary Meeting, para. 24.  
103 WCO Statement  (INF/TE/IDP/RD/20 ), 18 March 2022 Pre -Plenary Meeting.  
104 WCO Statement  (INF/TE/IDP/RD/20 ), 18 March 2022 Pre -Plenary Meeting.  INF/TE/IDP/RD/88/Rev.1  
 
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  18. Essentially,  there were four broad categories : (i) alternatives /substitutes that were currently 
classified under "traditional" plastic products HS code s (e.g. shopping bags made of vegetable 
starch);  (ii) alternatives/substitutes that were not classified under the same HS code, but in 
"general", material based HS code s that did not differentiate the specific good (e.g. moulded 
dinner plates made of sugar cane); (iii) alternatives/substitutes that already had their own, 
well-defined HS codes ( e.g. certain bamboo goods); (iv) alternatives/substitutes that could 
potential ly be classified in more than one HS code leading to potential confusion. For some 
materials (e.g. banana leaves) even the base input was not well defined under the HS.105 
19. Discussions amongst participants underscored that the revisions of WCO HS2027 were currently 
ongoing, and the Dialogue  should  contribute to it. One delegation noted that the refinement of 
the HS Code in differentiating plastics products for environmental purposes was one of the key 
elements in reducing plastics pollution and thus WCO 's exp ert advice was essential to Dialogue  
discussions.106 Another delegation noted that customs classifications on recycling were unclear,  
and this was also an issue that had to be addressed.107 
20. Stakeholders also highlighted the lack of transparency with regard t o types of plastics, plastic 
products, plastic additives as well as plastic  alternatives and  substitutes that were traded 
internationally, in part because these were not fully captured by the HS classification. A  policy 
brief on the potential amendments to  the HS classification  laid out concrete options for 
addressing the main gaps identified and that could be pursued as part of the current amendment 
cycle at the WCO , such as c reating new HS subheadings for the most commonly recycled primary 
polymers  or amending HS subheadings to incorporate specific information for products made of 
polymers that contain POPs and other harmful chemical additives .108 
21. One suggested area for further resear ch was to compile an illustrative list of plastic substitutes 
and alternatives with their HS codes, as well as to produce analysis of production, trade flows 
and employment related to plastic substitutes and alternatives based on identified HS codes.109 
One stakeholder  proposed an initial illustrative HS codes list for purposes of facilitating trade in 
plastics substitutes.110 Another stakeholder indicated bamboo and ratan as specific examples of 
HS code development. Historically, there had been a lack of spe cific HS codes for these products 
leading to  them being misclassified or mixed with timber products and other materials. However, 
in 2007 and 2017 , the WCO approved  a series of individual HS codes and c urrently there were 
24 HS codes  – 18 for bamboo and six for rattan  – reflecting a much broader range of commonly 
traded bamboo and rattan commodities.111 
22. On the topic of trade -related measures enabling substitution of SUPP, one delegation 
emphasized that regulatory measures to support or stimulate the usage of  plastic substitutes or 
alternatives in terms of international trade should be consistent with WTO rules.112 Such 
measures had to take into account readiness of industry to switch to alternatives or substitutes 
and the timing for such a transition, as well as the cost of the alternatives, consequences for 
consumers and environment and the expediency of plastic substitutes against other regulatory 
instruments. It was also highlighted that the life cycle of most substitutes to plastic was more 
carbon -intensive  and therefore due consideration should be given to consequences of such 
decisions for the environment. It was important to ensure the usage of only those alternatives 
and substitutes that were truly circular and non -toxic.113  
23. The following table reflects specific HS codes  put forward by participants and  stakeholders  during 
Dialogue's pre -plenary and plenary meetings, as well as in response to the guiding questions to 
the Workshop : 
 
105 WCO presentation ( INF/TE/IDP/RD/98 ) at the Workshop.  
106 Aide Memoire  (INF/TE/IDP/RD/41 ), 11 May Pre -Plenary Meeting, para. 8.  
107 Aide Memoire  (INF/TE/IDP/RD/41 ), 11 May Pre -Plenary Meeting, para. 8.  
108 TESS Statement ( INF/TE/IDP/RD/63/Rev.1 ), 11 May 2022 Pre -Plenary  Meeting , referring to Policy Brief 
"Plastic Pollution and Trade Across the Life Cycle of Pla stics: Options for Amending the Harmonized System to 
Improve Transparency ". 
109 UNCTAD presentation  (INF/TE/IDP/RD/25 ), 18 March 2022 Pre-Plenary Meeting.  
110 UNCTAD presentation ( INF/TE/IDP/RD/36 ), 11 May 2022  Pre-Plenary  Meeting.  
111 INBAR presentation ( INF/TE/IDP/RD/73 ), 17 November 2022 Pre -Plenary Meeting.  
112 Aide Memoire ( INF/TE/IDP/R/7 ), 19-20 September 2022 Pre -Plenary Meeting, para. 19.  
113 Aide Memoire ( INF/TE/IDP/R/7 ), 19-20 September 2022 Pre -Plenary  Meeting, para. 19.  INF/TE/IDP/RD/88/Rev.1  
 
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  Table 3: HS Codes for plastic substitutes and alternatives  
HS code  Description  
04 Dairy produce; birds' eggs; natural honey; edible products of animal origin, 
n.e.c.  
05 Animal originated products; not elsewhere specified or included  
07 Vegetables and certain roots and tubers; edible  
08 Fruit and nuts, edible; peel of citrus fruit or melons  
12 Oil seeds and oleaginous fruits, ..., industrial or medicinal plants; straw and 
fodder  
14 Vegetable plaiting materials; vegetable products not elsewhere specified or 
included  
14.01  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)  
1401.10  Bamboos  
1401.20  Rattans  
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 [ can be used for banana 
leave ] 
15 Vegetable waxes (other than triglycerides); whether or not refined  
20 Preparations of vegetables, fruit, nuts or other parts of plants  
20.05  Other vegetables prepared or preserved otherwise than by vinegar or acetic 
acid, not frozen, other than products of heading 20.06  
2005.91  Bamboo shoots  
23 Food industries, residues and wastes thereof; prepared animal fodder  
28 Inorganic chemicals; organic and inorganic compounds of precious metals  
32 Glass; glass frit and other glass, in the form of powder, granules or flakes  
39  
3907.70  Polyactic  acid (PLA) [ a bio -based  plastic ] 
41 Raw hides and skins (other than furskins) and leather  
42 Articles of leather; saddlery and harness; travel goods, handbags and similar 
containers; articles of animal gut (other than silk -worm gut)  
4202.92  Nonwoven natural fibre insulation (as a finished cooler box product)  
44 Wood and articles of wood; wood charcoal  
44.02  Wood charcoal (including shell or nut charcoal), whether or not agglomerated  
4402.10  Of bamboo  
44.09  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  
4409.21  (Non -coniferous) Of bamboo  
44.12  Plywood, veneered panels and similar laminated wood  
4412.10  Of bamboo  
44.18  Builders' joinery and carpentry of wood, including cellular wood panels, 
assembled flooring panels, shingles and shakes  
 - Assembled flooring panels  
4418.73  -- Of bamboo or with at least the top layer (wear layer) of bamboo  
 - Other  
4418.91  -- Of bamboo  
44.19  Tableware and kitchenware, of wood  
 - Of bamboo  INF/TE/IDP/RD/88/Rev.1  
 
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  4419.11  -- Bread and boards, chopping boards and similar boards  
4419.12  -- Chopsticks  
4419.19  -- Other  
44.21  Other articles of wood  
 - Other  
4421.91  -- Of bamboo  
45 Cork and articles of cork  
46 Manufactures of straw, of esparto or of other plaiting materials; basketware 
and wickerwork  
46.01  Plaits and similar products of plaiting materials, whether or not assembled into 
strips; plaiting materials, plaits and similar products of plaiting materials, 
bound together in parallel strands or woven, in sheet form, whether or not 
being finished articles (for example, mats, matting, screens)  
4601.21  -- Of bamboo  
4601.22  -- Of rattan  
4601.90  - Other  
4601.92  -- Of bamboo  
4601.93  -- Of rattan  
46.02  Basketwork, wickerwork, and other articles, made directly to shape from 
plaiting materials or made op from goods of heading 46.01; articles of loofah  
 - Of vegetable materials  
4602.11  -- Of bamboo  
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 [ Food containers: 
banana/plantain leaf; coconut husk; Straws: wheat fibre ] 
4602.22  -- Of rattan  
47 Pulp of wood or of other fibrous cellulosic material; recovered (waste and 
scrap) paper or paperboard  
47.06  Pulps of fibres derived from recovered (waste and scrap) paper or paperboard 
or other fibrous cellulosic material  
 - Other  
4706.30  -- Of bamboo  
48 Paper and paperboard; articles of paper pulp, of paper or of paperboard  
4811.90  Other paper, paperboard, cellulose wadding and webs of cellulose 
fibres  
4819.10  Food containers: paper  
4819.20  Food containers: paper  
4819.30  Grocery bags/packaging: paper  
4819.40  Grocery bags/packaging: paper  
48.23  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 fibre s 
 - Trays, dishes, plates, cups and the like, of paper or paperboard  
4823.61  -- Of bamboo  
4823.69  Food containers: paper  
4823.90  Straws: paper  
50 Silk 
51 Wool, fine or coarse animal hair; horsehair yarn and woven fabric  
52 Cotton  
53 Vegetable textile fibres; paper yarn and woven fabrics of paper yarn  
5303.10  Jute and other textile base fibres, raw or retted  INF/TE/IDP/RD/88/Rev.1  
 
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  54 Man-made filaments; strip and the like of man -made textile materials  
56 Wadding, felt and nonwovens, special yarns; twine, cordage, ropes and cables  
5607.21  Binder or baler twine; Of sisal  
5607.29  Other; Of sisal  
57 … 
5702.20  Nonwoven natural fibre insulation (to replace plastic foams, incl. 
expanded PS and PE)  
63 Textiles, made up articles; sets; worn clothing and worn textile articles; rags  
6305.10  Grocery bags/packaging: jute  
6305.20  Grocery bags/packaging: Cotton  
6305.90  Sacks and bags, of a kind used for the packing of goods; Of other 
textile materials [ Grocery bags/packaging: Hemp ] 
67 Feathers and down, prepared; and articles made of feather or of down  
68 Stone, plaster, cement, asbestos, mica or similar materials; articles thereof  
69 Ceramic products  
70 Glass and glassware  
7010.90  Liquid containers: glass  
76 Aluminium  and articles thereof  
7612.90  Liquid containers: aluminium  
7615.90  Liquid containers: aluminium  
7616.99  Liquid containers: aluminium  
94 Furniture; bedding, mattresses, mattress supports, cushions and similar stuffed 
furnishings; lamps and lighting fittings, not elsewhere specified or included; 
illuminated signs, illuminated name -plates and the like; prefabricated buildings  
94.01  Seats (other than those of heading 94.02), whether or not convertible into 
beds, and parts thereof  
 - Seats of cane, osier, bamboo or similar materials  
9401.52  -- Of bamboo  
9401.53  -- Of rattan  
94.03  Other furniture and parts thereof  
 - Furniture of other materials, including cane, osier, bamboo or similar 
materials  
9403.82  -- Of bamboo  
9403.83  -- Of rattan  
95 Toys, games and sports requisites; parts and accessories thereof  
 
24. At the Workshop, d iscussions broadly recognized that there already existed several substitutes 
and alternatives being traded internationally. However, they were not easily identifiable in 
current trade data and HS code classifications, complicating efforts to understand market 
opportunities as well as potential trade barriers. The experience with the development of new 
HS code subdivisions for bamboo goods was highlighted as a positive example ; the existence of 
commercial interest and the fact that goods were easily identifiable were noted as clear positives . 
However , this was hard to replicate for all material subst itutes as it would require many HS 
subdivisions and countries would need additional  flexibility to  create further domestic 
subdivisions . There was a potential for coordination then among national customs authorities on 
such domestic subdivisions. On specif ic HS reforms, a few elements were raised such as the 
need for countries or trade institutions to come forward with proposals; the potential for technical 
support to "clean up" proposals and make them operational; and the importance of commonly 
accepted de finitions . Finally, in terms of trade measures to promote substitutes and alternatives, 
it was noted that the Dialogue's survey captured a number of them, which mostly included 
regulatory measures indicating a general intention to promote sustainable subst itutes and 
alternatives. It was noted that the issue of access and price sensitivity was an important point 
to consider with regards to these measures. At the same time, coherence was necessary  between INF/TE/IDP/RD/88/Rev.1  
 
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  trade policies promoting substitutes and those imposin g restrictions on traditional plastics to 
avoid stifling innovation.  
3  ILLUSTRATIVE AND EXTENDED LIST OF MATERIAL SUBSTITUTES AND MATERIAL 
IDENTIFICATION EXERCICE  
25. The 2021 Ministerial Statement highlights the importance of moving towards environmentally 
sustainable and effective substitutes and alternatives  and the role for multilateral trade 
cooperation in promoting good practices. It also identifies addressing tra de-related capacity 
building and technical assistance needs of developing Members, including expanding trade in 
environmentally sustainable and effective substitutes and alternatives, as an area of common 
interest where work must be intensified.  
26. Participan ts in the Dialogue's  discussions in 2021 and 2022 highlighted this difference between 
plastic substitutes and plastic alternatives. According to the definition proposed by one 
stakeholder, p lastic substitutes were non -plastic or polymer materials of vegeta ble, animal, or 
mineral origin ( e.g. agriculture, waste, marine or mineral -based). These were materials such as 
paper that could be reused and were biodegradable, compostable, or recycled. In general, they 
had a more positive lifecycle  analysis impact than  plastics  and did not include additives. Plastic 
alternatives , on the other hand, would  comprise products made of biomass -based polymer 
molecule with zero or low -carbon footprint, as well as of biodegradable polymer s which did not 
accumulate in nature (bio plastics or biodegradable plastics). They could therefore have similar 
properties to plastics because they were made of similar molecules. These c ould be used for 
nonfuel feedstock use and some could  be reused, were compostable or biodegradable.114 
However,  several participants noted that some plastic alternatives had similar waste disposal 
problems to conventional  plastic depending on chemical composition.  
27. The following substitutes and alternatives were raised and/or discussed:  
Table 4: Plastic substitutes  
CATEGORY115 PLASTIC SUBSTITUTES  
General  Vegetable fibres; animal fibres; mineral materials  
Traditional  Aluminium  
Cardboard  
Cellulose  
Ceramics  
Clay 
Cotton  
Glass   
Linen  
Natural fibers and wools 
Paper  
Steel 
Mulch  Hay 
Leather  
Ray 
Straw  
Seaweed film & fibers  
White clover  
Wood bark  
Woodchip  
Wool 
Textiles/  
Pack aging / 
SUP Abaca (Manila hemp)  
Algae biomass  
Balsa Wood  
Bamboo  
 
114 UNCTAD presentation ( INF/TE/IDP/RD/36 ), 11 May 2022  Pre-Plenary  Meeting.  
115 Categories based on UNCTAD  submission to the Workshop  (INF/TE/IDP/RD/83 ). INF/TE/IDP/RD/88/Rev.1  
 
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  Cellulose nanofibers  
Coconut Husks  
Coir 
Cork 
Corn-based  
Cotton  
Flax 
Fish skin or residues  
Hemp  
Jute 
Leather  
Microbial cellulose of mixed vegetables and bacteria  
Nettles  
Rattan  
Seaweed – brown and red algae by -products  
Silk 
Sisal 
Sugarcane pulp – bagasse  
Other plant materials  
Palm 
Plant Waste  
Wheat Husks  
Wheat stems  
Wood Pulp  
Woodchip  
Textiles  Areca leaves  
Banana leaves, stem, or fibers  
Bamboo fib res 
Beeswax -coated cloth  
By-products  of ready -made garments  ("jhoot")  
Fruit peels  
Down   
Grape waste  
Murta  
Pineapple leaves  
Tofu waste  
Silk  
Various animal wools (alpaca, angora, cashmere, sheep, etc.)    
Packaging/  
SUP Banana /Plantain pseudo -stems,  leaves and paper  
Calabash hard shell  
Casein  
Cotton linters  
Mushroom  
Ray 
Rice paper  
Seaweed and fruit peels Films & paper  
Wood bark  
Table 5 : Plastic alternatives  
PLASTIC ALTERNATIVES  
Bioplastics  
Biodegradable plastics  
Recyclable plastic  
Recyclable resin  
rPET 
Bio-polypropylene  
Low-density polyethylene (multiple use)  
Polylactic acid (PLA) and CPLA  
Polybutylene succinate (PBS)  INF/TE/IDP/RD/88/Rev.1  
 
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  28. Participants also identified a number of avenues for further exploration as regards material 
substitutes which would support progress in the Dialogue116: 
• Develop an expanded list of material substitutes (e.g., vegetable and animal fibers, algae 
biomass, and mineral materials)  and produce an illustrative list of plastic alternatives 
including HS codes and related life cycle analysis.  
• Promote further researc h, development, and adoption of material substitutes to SUP to 
address plastic pollution in the ocean.  
• Explore opportunities to make use of natural materials, marine by -products, and post -
harvest agricultural waste, which could help spur innovation, suppor t circular economy, and 
develop new industrial capacities.  
• Promote incentives to eliminate plastics, including by addressing the tariff rates applied to 
substitute materials to facilitate trade of substitute materials which are less polluting.  
• Need for co llaborative action with other stakeholders in identifying best practices as well as 
barriers to dissemination of green alternatives to plastics.  
• Support positive and negative incentives for environmentally sustainable and effective 
substitutes and alternat ives to plastics.  
• Undertake a material identification exercise: Countries, IGOs and NGOs introduce and justify 
materials they consider more suitable as better SUP substitutes in terms of Life Cycle 
Analysis (LCA) , sustainable production, scale -up and dispo sal. 
• Improve working definitions to assist the Dialogue and the INC process.  
• Work on consolidated list of plastics substitutes based on identified clusters and 
corresponding identified HS codes for plastics substitutes .  
• Phase out fossil fuel subsidies to  create economic incentives to move towards material 
substitution.  
• Explore policy options to enable sunrise industries focusing on substitutes, especially where 
those can be competitive, scalable, recyclable, and promoting job creation.    
• Undertake additi onal exploratory work to identify existing innovative and scalable products 
(with the lowest carbon footprint possible) that could substitute plastics.  
• Agree on a minimum set of LCA indicators on which actionable policy could be based to 
define substitutes which should be produced.  
 
29. Trade -related challenges in using substitute packaging materials were also discussed, including 
lack of coherence in national regulations and differences in recycling processes posed a barrier 
to trade.117 Some delega tions underscored specific limitations in national legislations, for 
instance a law stating that environmentally unacceptable products should not be prohibited 
unless there were alternatives available to consumers at no more than ten percent greater cost 
than the disposable product. The law had made it very challenging to identify solutions that 
would meet this legal requirement.118 At the same time, other Members had banned some SUP, 
such as straws and cutlery, and other measures were in place for items for which no clear 
sustainable alternatives were available (e.g. consumer information labelling requirements).119 
Certain delegations had coordinated efforts in place to educate population on plastic waste, to 
intercept plastic waste, and to redesign alternative and new solutions to plastics.120 Others had 
introduced national waste policies that would require all packaging to be recyclable or 
compostable by 2025.121 
30. Discussions amongst participants underscored the need for assistance for developing count ries 
to produce environmentally sustainable and effective substitutes or alternatives to plastics.122 
Delegations from developing countries emphasized the need for improved access to 
cost-effective and environmentally friendly alternatives to plastics, in p articular SUP. 
International cooperation and assisting developing countries were important to incentivize trade 
 
116 See UNCTAD presentation s at the 18 March 2022 Pre -Plenary Meeting ( INF/TE/IDP/RD/25 ), 
30 March  2022 Plenary Meeting ( INF/TE/IDP/RD/32 ), 11 May 2022  Pre-Plenary  Meeting ( INF/TE/IDP/RD/36 ), 
and at the Workshop  (XX/XX/XX/RD/XX ). See also 116 Informal summary  (INF/TE/IDP/R/5 ), 30 March 2022 
Plenary Meeting, paras. 5 and 14.  
117 Nestlé presentation  (INF/TE/IDP/RD/54 ), 19-20 September 2022 Pre -Plenary . 
118 Informal summary  (INF/TE/IDP/R/5 ), 30 March 2022 Plenary Meeting.  
119 3rd co-sponsors meeting, June 2021.  
120 3rd co-sponsors meeting, June 2021.  
121 Informal summary  (INF/TE/IDP/R/5 ), 30 March 2022 Plenary Meeting.  
122 Aide Memoire  (INF/TE/IDP/RD/41 ), 11 May 2022 Pre -Plenary  Meeting.  INF/TE/IDP/RD/88/Rev.1  
 
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  and investment opportunities in new markets of substitute and alternative plastics.123 It was 
also observed that plastic substitutes may be of ex port interest to some developing countries 
and that they may also have a role in displacing plastic imports. That is, in domestic marketplace 
in some developing countries, there could  be opportunities for communities that produce 
traditional packaging mate rials to replace plastic imports while also supporting livelihoods in 
rural communities, including by generating employment for women.124 For instance, some plastic 
substitutes, such as jute, that were of export interest to developing countries and LDCs, we re 
still subject to high tariffs in certain markets and also faced non -tariff barriers related to 
certification. Competing synthetic fibres also faced lower costs of production, partly because of 
energy subsidies.125 One delegation highlighted that alternat ives and substitutes should be 
accessible and available with  a preference for indigenous and/or localized/regional supply chains , 
and should integrate the notion of industrial development .126 
31. More generally, an analysis of applied tariff rates specifically on finished plastics and plastics 
substitutes based on an HS codes analysis revealed that not only substitutes were more 
expensive, but also faced higher tariffs.127 
32. Delegations shared experiences with local alternatives and substitutes, mentioning mechanic al 
recycling (e.g. PET bottle -to-bottle recycling, as well as of polyethylene, polypropylene, and 
polystyrene), use of flexible plastic waste as filler material for plastic products and construction 
materials, and use of mixed plastic waste to asphalt  road and plastic lumber.128 A number of 
alternatives and substitutes for specific products were discussed, including the use of:  
• Marine -biodegradable plastic and recyclable plastic for fishing gear.129 
• Recycled resin as an alternative to conventional resin.130 
• Cellulosic fibre in place of plastic for cosmetics packaging.131 
• Jute polybags replacing low -density polyethylene (LDPE) plastic bags.132 
 
33. One stakeholder presented a study identifying the six plastic subcategories with the largest 
substitute potential by mass: monomaterial films ( 45 million metric tons ); other rigid 
monomaterial packaging (9.5  million metric tons ); sachets and multimaterial films (4  million 
metric tons ); carrier bags (4  million metric tons ); pots, tubs, and trays (3  million metric tons ); 
and food service disposables (2  million metric tons ).133 
34. The following substitutes and alternatives were proposed for specific categories of plastic 
products134: 
Table 6: Products, base line materials and substitutes/alternatives  
PRODUCT TYPE  BASE CASE  SUBSTITUTES / ALTERNATIVES  
Fishing nets  Nylon  Polypropylene, cotton, hemp  
Beverage bottles  PET Aluminium, glass, polypropylene  
Beverage cups and 
food containers  EPs Paper (cardboard), PLA, polypropylene, 
Banana/plantain leaf, coconut husk  
Shopping bags  LDPE (single -use) LDPE (multiple use), jute, paper, cotton, hemp  
 
123 3rd co-sponsors meeting, June 2021.  
124 TESS Statement ( INF/TE/IDP/RD/63/Rev.1 ), 11 May 2022 Pre -Plenary  Meeting.  
125 CTE minutes ( WT/CTE/M/68 ), meeting held on 26 -27 November 2019 . 
126 Aide Memoire ( INF/TE/IDP/R/9 ), 17 November 2022 Pre -Plenary Meeting.  
127 UNCTAD presentation ( INF/TE/IDP/RD/36 ), 11 May 2022  Pre-Plenary  Meeting.  
128 Informal summary  (INF/TE/IDP/R/5 ), 30 March 2022 Plenary Meeting.  
129 OECD presentation  (INF/TE/IDP/RD/18 ) and policy pape r "Towards G7 action to combat ghost fishing 
gear" , 18 March 2022 Pre -Plenary Meeting.  
130 Aptar Group presentation  (INF/TE/IDP/RD/53 ), 19-20 September 2022 Pre -Plenary  Meeting.  
131 Yves Rocher Foundation presentation ( INF/TE/IDP/RD/61 ), 19 -20 September 2022 Pre -Plenary  
Meeting.  
132 CTE minutes ( WT/CTE/M/68 ), meeting held on 26 -27 November 2019 . 
133 PEW presentation ( INF/TE/IDP/RD/76 ) referring to the Breaking the Plastic Wave study , 
17 November  2022 Pre -Plenary Meeting.  
134 World Bank Group presentation  (INF/TE/IDP/R/7 ), Aide Memoire, September 2022 Pre -Plenar y 
Meeting.  INF/TE/IDP/RD/88/Rev.1  
 
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  Disposable utensils  Polypropylene  Bio-polypropyl ene, steel, wood  
Food wrappers  PVC Aluminium, PET, Bio -LDPE 
Sachets  HDPE and PET  Aluminium wrap, PET  
Beverage cartons  Multimaterial  PET, Glass  
Clothing  Multimaterial  Cotton, linen, bamboo  
Diapers  Miltimaterial  Cotton, bamboo  
Fishing gear  Durable plastic  Marine -biodegradable and recyclable plastic  
Cosmetics packaging  Plastic  Cellulosic fibre  
Straws  Plastic  Wheat fibre, paper  
 
35. Delegations observed that more information was needed on trade flows in plastic substitutes 
and alternatives.135 There were ongoing regional efforts to build a matrix for the trade of 
substitute products in Latin America, as well as trade discussions with the participation of small 
and medium enterprises (SMEs) focusing on alternatives and substitutes , such as banana leaves 
and biodegradable packaging.136 
36. Several stakeholder studies and publications  were discussed:  
• The OECD "T owards G7 action to combat ghost fishing gear " which found inter alia that trade 
policy could facilitate the trade of less harmfu l plastics and substitutes and dis -incentivize 
(or even forbid) trade in the most harmful plastics.137 
• The UNCTAD Sustainable Manufacturing and Environmental Pollution (SMEP) and the Oceans 
Economy programme conducting a study on alternative materials which can competitively 
substitute SUP in SMEP regions. SMEP had an open call for proposals on plastics in the areas 
of biodegradability of alternatives to plastics and improved manufacturing and 
remanu facturing solutions.138 
• The World Economic Forum conducted the Global Plastic Action Partnership (GPAP) Ghana 
study illustrated that at the national level there was scope for trade policy to play a greater 
role in mitigating plastic pollution and waste, and  in particular moving to alternatives for a 
more circular economy.139  
• The Graduate Institute published a report "How can international trade policy help tackle 
plastic pollution". Among its suggestions was to lower or eliminate tariffs and trade barriers 
to non -plastic substitutes and environmentally sound waste management technologies and 
facilitate trade in recycled plastics and recyclable plastics.140 
 
37. Materials and products identified in reply to the Workshop guiding questions included:  
Table 7: Substitute/alternative material and manufactured product  
MATERIAL  MANUFACTURED PRODUCT  
Coconut fibre  Nonwoven coconut fibre mats , Pulped and moulded coconut fibre dust  
Bagasse  Pulped and mould ed bagasse  
Bamboo  Single -use bamboo products: bamboo straw, cattery, and chopsticks, 
plates, cups, and coffee stir and ice cream sticks,  cotton swab  
Bamboo toothbrush, pen  
Kitchen items: chopping boards, toothbrushes  
Bamboo fibre/pulp packing material  
Bamboo  electronic  product  shell 
Natural bamboo fibre for mattress, mask, and interior decoration 
(vehicles, buildings, etc.)  
Bamboo filling in cooling tower  
Bamboo winding pipe  
Bamboo skateboard, surfboard, bamboo woven helmet  
Bamboo blades  
 
135 Aide Memoire ( INF/TE/IDP/R/7 ), September 2022 Pre -Plenary Meeting.  
136 Aide Memoire ( INF/TE/IDP/R/7 ), September 2 022 Pre -Plenary Meeting.  
137 OECD presentation  (INF/TE/IDP/RD/18 ) and policy paper "Towards G7 action to combat ghost fishing 
gear" , 18 March 2022 Pre -Plenary Meeting.  
138 UNCTAD presentatio n, 3rd co-sponsors meeting, June 2021.  
139 WEF presentation, 3rd co-sponsors meeting, June 2021.  
140 GI presentation, 3rd co-sponsors meeting, June 2021.  INF/TE/IDP/RD/88/Rev.1  
 
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  38. One delegation proposed the Dialogue work on an illustrative list of plastic substitutes and 
alternatives already traded internationally in anticipation of MC13. This illustrative list would be 
non-binding, non -exhaustive, and could be progressively amended. The list could also serve as 
a basis to devel op working definitions which would in turn serve as useful inputs for HS code 
identification and amendments discussions.141 
39. At the workshop,  discussions reflected various  experiences, latest studies , and examples on 
challenges and opportunities in the trade  and use of natural materials and new delivery models 
(e.g., marine by -products, post -harvest agricultural waste, packageless retail, etc .). On intra- 
and extra -regional trade of plastics and its substitutes, it was noted that in, Latin America, 
intra-regional preferences were originally designed based on export interests of countries in the 
region and not on environmental criteria. Statistical data analysis of international trade on 
plastics substitutes was also limited. However, a t the consumer level, reg ulations exist ed to limit 
the use and marketing of SUPP and plastic packaging.  Regarding o ptions for rethinking delivery 
of goods , it was observed that measures related to plastic substitutes products, low inputs 
business models , and environmental consumer  patterns var ied globally and regionally . For 
instance, while the EU  focuse d on waste reduction and limitation , Asia focuse d on new packaging 
forms based on health and safety.  At the private sector level, although companies were proving 
able to adapt to th e ever -changing regulatory landscapes of compliance, the lack of 
harmoni zation on content and scope of such measures persist ed in many markets. It was also 
important for  substitutes and alternatives to be affordable and accessible for low -income 
communitie s. 
4  MINIMUM CRITERIA FOR LIFE CYCLE ANALYSIS (LCA) AND AFFORDABILITY, 
ACCESSIBILITY, AND AVAILABILITY  
40. The 2021 Ministerial Statement recalls the need for further commitment and actions across the 
life cycle of plastics to address marine litter and microplas tics, including through a circular 
economy approach. One of the potential areas for further research suggested  by Dialogue  
participants was minimum criteria for LCA  for plastic alternatives and substitutes such as land 
use, type of feedstocks, emissions,  biodegradability, composability, and recyclability.142 A few 
delegations underscored the need to not lose  sight of the full lifecycle issue while tackling specific 
aspects of plastic value chains, such as plastic substitutes and alternatives, and  ensuring 
environmental soundness.143 
41. Regarding LCA of substitutes more specifically, some participants noted that it was important to 
ensure that substitutes were sustainable and that a lifecycle  environmental impact assessment 
was carried out to avoid cre ating further damage. Products and packaging should be replaced 
exclusively by environmentally friendly materials, as alternative materials such as bio -based 
plastics were not necessarily more environmentally friendly than petroleum -based plastics. This 
demonstrated the importance of a LCA of the foreseen substitute.144 
42. Stakeholders underscored that the criteria for sustainable substitutes would vary spatially, 
depending on resource availability and case -by-case product -level life cycle assessment could 
be necessary. There were some tools in this area that already existed such as the World Business 
Council for Sustainable Development SPHERE145 packaging sustainability assessment 
framework; the World Bank’s Plastic Substitution Trade -off Estimator146 and UNEP 's 
10 Objectives and Guiding Considerations for Green and Sustainable Chemistry147. The need to 
consider re use as well as substitution was underscored.  Substitution was often a favourite 
approach, but re use had a lower climate impact across the entire lifecycl e and kept material 
circulating in the economy for longer.148 
 
141 Informal summary, 7 December 2022 Plenary Meeting. (forthcoming)  
142 UNCTAD presentation  (INF/TE/IDP/RD/25 ), 18 March 2022 Pre -Plenary Meeting.  
143 Informal summary ( INF/TE/IDP/R/6 ), 24 May 2022 Plenary Meeting.   
144 Aide Memoire ( INF/TE/IDP/R/7 ), 19-20 September 2022 Pre -Plenary Meeting.  
145 WBSCD  presentation (INF/TE/IDP/RD/55 ), 19-20 September 2022 Pre -Plenary Meeting.  
146 World Bank  presentation ( INF/TE/IDP /RD/56 ), 19-20 September 2022 Pre -Plenary Meeting.  
147 University of Portsmouth statement ( INF/TE/IDP/RD/68 ), 17 October 2022 Pre -Plenary Meetin g. 
148 University of Portsmouth statement ( INF/TE/IDP/RD/68 ), 17 October 2022 Pre -Plenary Meeting.  INF/TE/IDP/RD/88/Rev.1  
 
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  43. Dialogue  participants discussed research on LCA that had revealed that reusable products had a 
better environmental footprint than SUP. However, research had also shown that plastic 
alternatives and substitutes had different environmental impacts, and the success of a life cycle 
approach was largely contingent on the behaviour of consumers and businesses.149 
44. A number of stakeholders introduced projects related to LCA of alternatives and substitutes . 
UNCTAD  presented certain LCA considerations based on their SMEP programme country specific 
LCA assessments150 underscoring that LCAs can be costly and time consuming and therefore 
necessitate a standard approach.  UNEP  presented its technical work on LCA f or SUP products 
and their alternatives.151 Some of the key messages from this work included:  
• The single -use nature of products was most problematic for the planet, more so than the 
material that they were made of.  
• Cleverly designed products needed to be du rable, and the lighter a product's weight, the 
lower its environmental impact.  
• Countries were encouraged to promote actions that allowed keeping resources at their 
highest value, by replacing SUP products with reusable products.  
• Taking a life cycle appro ach was key in informing the right decision to address plastics 
pollution.  
 
45. Further analysis of specific products, including plastic bags, bottles, beverage cups and nappies, 
revealed that:  
• Reusable options were generally preferable over single -use products of any material.  
• To understand the environmental performance of products, it was critical to look at their life 
cycle and use stage.  
• There was a need to reduce unnecessary or unsafe plas tics and materials as well as to shift 
from single -use to reusable products.  
• Biodegradable or bio -based  products did not necessarily have "better" environmental 
impacts than conventional products.  
• Substitution of a single -use plastic product by another single -use material substitute does 
not necessarily yield a net positive benefit, according to LCA indicators.  
• Substitute materials could have a more positive social impact in terms of income generat ion 
and development of new productive and innovation capacities across various countries.152 
 
46. Yves Rocher Foundation  addressed LCA from the perspective of the (RE)SET Cosmetics initiative 
to replace plastic of cosmetics packaging by cellulosic fibre.153 They faced challenges in terms 
of: 
• Recyclability – developing packaging made up of at least 85% cellulosic fibres for a 
significant material yield during recycling and the need to ensure sustainable fibres (FSC, 
PEFC) or other biomass did not compete with food  crops while guaranteeing the availability 
of resources and the supply capacity of the cosmetics sector; and  
• Chemistry – changing the chemical nature of coatings towards 100% bio -based coatings 
and the need to ensure barrier properties and preservation of  formulas (restitution rate, 
water resistance, formula stability, etc.).  
 
47. The World Bank Group  shared their recent study on the Plastic Substitution Tradeoff Estimator 
which provided a holistic comparison of the costs and benefits of plastics and their 
alternatives.154 The estimator compared ten plastic products with up to four alternatives 
currently available in the market. The comparison was based on the basis of input, one -to-one 
weight of the alternative, function performed, lifecycle assessment, extern al cost analysis as 
 
149 UNEP and UNCTAD presentations, Informal summary ( INF/TE/IDP/R/6 ), 24 May 2022 Plenary Meeting.  
150 UNCTAD  presentation  (INF/TE/IDP/RD/36 ), referring to its SMEP Programme report "Substitutes for 
single-use plastics in sub -Saharan Africa and south Asia: Case studies from Bangladesh, Kenya and Nigeria" . 
Aide Memoire ( INF/TE/IDP/RD/41 ), 11 May 2 022 Pre -Plenary Meeting.  
151 UNEP Presentation  (INF/TE/IDP/RD/40 ), referring to its report "Single -Use Plastics Products and their 
alternatives: Recommendations from Life Cycle Analysis" , 11 May 2022 Pre -Plenary Meeting.  
152 UNCTAD presentation ( INF/TE/IDP/RD/90) at the Workshop . 
153Yves Rocher Foundation presentation ( INF/TE/IDP/RD/61 ), 19 -20 September 2022 Pre -Plenary  
Meeting.  
154 World Bank  presentation (INF/TE/IDP/RD/56 ), 19-20 September 2022 Pre -Plenary Meeting . INF/TE/IDP/RD/88/Rev.1  
 
- 27 - 
 
  well as on monetary valuation including quantitative assessment and qualitative assessment. 
The tool that was designed to be implemented in any given country, provided best alternatives 
depending on national capacity and possibility for  local production and imports. It compared 
impacts on several fronts including greenhouse gas emissions as well as land and water use, 
consumption etc. The tool not only allowed to tailor the analysis to a country context but also 
allowed monetary valuatio n to determine the external costs of plastics and their alternatives. 
The World Bank had piloted this data -driven model in five countries (Bangladesh, Mozambique, 
Nigeria, St. Lucia, and Vietnam). The estimator also had some limitations: it could not be us ed 
to assess the effectiveness of regulatory schemes and policies; financial implications of product 
substitution; and affordability and acceptability by users of the alternative materials.  
48. The World Business Council for Sustainable Development (WBCSD) pre sented their packaging 
sustainability framework (SPHERE) to support companies in switching to sustainable 
packaging.155 SPHERE  define d packaging sustainability as maximum circularity and minimum 
environmental footprint, while avoiding the presence of harmfu l substances. To support this 
definition, six principles had been developed: minimize the drivers of climate change; optimize 
efficiency; optimize circularity, optimize end of life; avoid harmful substances; and minimize the 
drivers of biodiversity loss.  
49. As regards areas for further analysis, it was recognized that each Member may have different 
substitutes and alternatives appropriate for them and their environmental sustainability across 
the life cycle would depend on local production and disposability op tions. It would therefore be 
useful to learn more about the kinds of challenges Members were facing in the scale -up of 
manufacturing and exports of environmentally sound substitutes and alternatives. It would also 
be helpful to learn more about the operati on of global supply chains for plastic substitutes. For 
example:  
• What sort of North -South private sector linkages or collaboration exists? Are there any 
companies in OECD countries for example that have invested in plastic substitutes in 
developing countri es?  
• How has that worked and what have been the challenges they faced?  
• Are their examples of South -South cooperation or value chains for plastic substitutes?  
• What lessons can be drawn from private sector companies that are involved in such supply 
chains?156 
 
50. Discussions underscored  that circularity considerations, full environmental impact assessments 
and adequate evidence needed to be considered when assessing single -use plastic alternatives 
to avoid unintended consequences. One delegation noted that there  was currently a lack of 
evidence that biodegradable plastic consistently breakdown in real world environments. This 
required a life cycle assessment of a product which should, as far as possible, cover the entire 
life cycle of the product. Another delegation observed  that the scal e of the problem largely 
depended on the efficiency of the waste management systems and recycling and encouraged 
discussions on stimulating measures and development of infrastructure for waste collection, 
transportation, and disposal, for instance, the tra nsformation of waste into valuable raw material 
for the market.  
51. One stakeholder highlighted that w hile substitutes created opportunities, they also had 
trade-offs that needed to be carefully managed and assessed in a case -by-case basis. Possible 
criteria to consider for substitutes included identifying problematic plastic. This could be done 
by using several criteria such as, inter  alia, the likelihood of being littered or ending up in the 
environment; if the product was not reusable, recyclable or compost able, if the product could 
be avoided. Other elements for consideration included the presence of waste infrastructure to 
collect and process substitutes; the issue of lowering overall GHG emissions in production and 
end-of-life disposal phases; and health concerns considerations. Finally, when changing the 
plastic system – many SUPP would be eliminated or replaced by reusable items and new delivery 
 
155 WBSCD  presentation ( INF/TE/IDP/RD/55 ), referring to its report "SPHERE: the packaging sustainability 
framework" , 19-20 September 2022 Pre-Plenary Meeting . 
156 TESS statement ( INF/TE/IDP/RD/65 ), 11 October 2022 Plenary Meeting.  INF/TE/IDP/RD/88/Rev.1  
 
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  models. Non -recyclable  and hard -to-recycle plastics could be substituted for paper or 
compostable materials.157 
52. Bamboo was discussed as a specific example as the fastest -growing plant in the world and with 
high productivity. Bamboo was also a low -carbon, bio degradable  and sustainable substitute for 
plastic and its products could help reduce greenhouse emissions.158 One delegation noted that 
while bamboo was a good candidate for potential substitute for plastic as it was a fast -growing 
grass, the whole lifecycle should be examined, being mindful of the potential biodiversity impacts 
when considering land  use and land  use change for alternatives like bamboo and other products 
materials. The alternative had to be sustainably produced and harvested, durable (lifespan) and 
repairable, and sustainably disposable at end  of life. Another delegation argued that bamboo 
was not  water intensive and did not require the removal of huge carbon sinks by harvesting 
them. The Dialogue could enhance cooperation and build on effort s and experience in promoting 
environmentally sustainable and effective substitutes and alternatives  with bamboo and rattan 
taken as samples to start an in -depth discussion on facilitation.159 
53. One participant underscored that plastic polymers could not be effectively replaced by any 
currently existing substitutes or alternatives either in the context of the econo my or in terms of 
environmental protection for the following reasons: (i) average carbon intensity of polymers: it 
is approximately 0,2 tons of CO2 per 1 ton of manufactured product which is three times less 
than that of cellulose and paper, 3 and a half t imes less than that of a glass, seven  times less 
than that of iron, etc.; (ii) light weight of polymers: polypropylene is eight times lighter than 
steel, nine times lighter than copper, and three  times lighter than aluminium; and (iii) ability of 
polymers to resist diffusion of gas es: highly applicable to food packaging and allows to extend 
the shelf life of content.160 
54. The following table summarised the criteria for LCA highlighted by participants at the Dialogue's 
meetings, as well as in response to the Wo rkshop guiding questions.  
Table 8 : Criteria for lifecycle analysis  
LCA CRITERIA  ELEMENTS  TO CONSIDER  
Cost-effectiveness  • Availability and affordability  
• Scalability of production and usage  
Design / technology  • Type of feedstocks . 
• Material.  
• Air permeability; Water permeability; Water solubility; Tensile 
strength; Colour fastness; UV fastness . 
• Design for recyclability.  
Recyclability, Reusability, 
Compostability, 
Biodegradability  • Recyclability/Compostability: Especially important for naturally 
biodegradable feedstock materials.  
• Reusability: Especially important in the case of reusable 
plastics.  
• Natural breakdown in 30 /90/365 days without extra enzymes 
or inputs . 
• Possibility to enter  municipal recycling, waste, or compost 
streams . 
• Backyard-compostable in 30 days . 
End of life and circularity  • Economic value captured at end of life ; costs associated with 
end of life . 
• Renewable or recy cled content, recovery rate . 
• Different  costs and processes in different regions . 
• Existing or emerging Exten ded Producer Responsibility 
regimes . 
• Industry certifications .  
 
157 PEW presentation ( INF/TE/IDP/RD/76 ) referring to the Breaking the Plastic Wave study , 17 November 
2022 Pre -Plenary Meeting.  
158 INBAR presentation ( INF/TE/IDP/RD/73 ), 17 November 2022 Pre -Plenary Meeting.  
159 Aide Memoire ( INF/TE/IDP/R/9 ), 17 November 2022 Pre -Plenary Meeting.  
160 Aide Memoire ( INF/TE/IDP/R/9 ), 17 November 2022 Pre -Plenary Meeting.  INF/TE/IDP/RD/88/Rev.1  
 
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  Resiliency  • Durable and lightweight.  
• Equipment and handling requirements by intermediate 
processors  (including new machinery and new training 
required to work with substitutes, and frequency of machinery 
replacement and retraining ). 
• Failure rates and manufacturer tolerances .  
• Repairability –potential and cost . 
• Supply disruption risk, present day and 5 -25 years forward  
(present/potential production locations , producer , total number 
of locations where  materials  can theoretically be produced at 
commercial volumes and existing cost, and future propects ). 
• Order lead times, at different volumes . 
• Upper and lower capacity constraints –max and min order 
quantities as well as ability, limits, and timeframe to scale -up 
production, including pricing effects.  
Environmental impact  • Emissions: whether  production, use, and disposal of the 
material increases/decreases the  current  CO2 emissions . 
• Land use: effect of new demand.  
• Water use: whether material  production diverts/pollutes  
potable or non -potable water . 
• Acidificatio n, fresh water and marine eutrophication . 
• Leakage potential or mismanaged waste  index . 
• Energy use of production processes.  
• Impact on biodiversity loss.  
• Other potential environmental impacts: stratospheric ozone 
depletion; ionizing radiation; ozone formation (human health, 
terrestrial ecosystems); fine particulate matter; terrestrial 
acidification; terrestrial, freshwater, and marine ecotoxicity; 
carcinogenic an d non -carcinogenic toxicity; mineral and fossil 
resource scarcity.  
Social impact  • Local community engagement and familiarity with the 
material : level of indigenous knowledge and indigenous 
support present, level of local political knowledge and support 
present.  
• Effect of new demand on local economy.  
• Industrial support: whether  material production creates  new 
business or employment opportunities in places with high 
unemployment and/or limited  advanced industrial 
opportunities . 
Health impact  • Consumer safety  in case of plastic alternatives for food contact 
application: d epending on the application, problems of 
undesired  contamination (e.g. paper/cardboard straws) or 
hygienic risks (e.g. replacement of cling film with oilcloth) are 
possible.  
Supply chain resiliency 
and redundancy  • Climate change risk (important when considering 
biomaterials ): when, where, and what is grow n at what cost, 
and how this could change in a warming climate as well as a 
planet with more intense and less predictable weather.  
• Climate policy risk : new and emerging government restrictions 
and subsidies for things like oil refineries, which impacts all  
plastic and most bioplastic production, as well as direct taxes 
and extended producer responsibility fees on plastics and 
plastic alternatives. Restrictions and taxes on emission -
intensive trade , such as international air freight and mining , 
that can radi cally change material availability and cost.  
• Accessibility : a preference for indigenous and/or 
localized/regional supply chains for material substitutes . INF/TE/IDP/RD/88/Rev.1  
 
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  Local conditions  • Local production, consumption , and end -of-life disposal 
activities .  
• Domestic availability of feedstock, manufacturing capacity, 
price competitiveness of end -use products . 
• Differences in the energy mix and the proportion of energy 
drawn from clean or renewable energy sources.  
• Local w aste management practices, systems , and 
infrastructure.  
• Consumption and post -consumption behaviour of the local 
populatio n (e.g. , frugal or wasteful consumption habits, 
salvaging of resources, and responsible disposal of waste ). 
Efficiency  • Optimize packaging efficiency while ensuring content integrity.  
• Efficiency (e.g. product protection for packaging) . 
 
55. At the Workshop, discussions focused on experiences, examples of key criteria to be included in 
the LCA of plastics, their alternatives and substitutes , and tools to allow comparisons and 
understanding of trade -offs which were faced during material substitution.  A key message was 
that reduction of material use and reduction of waste were the best approach from LCA 
perspective. LCA assessments  were necessary  to support country -level decision and 
policymaking strategies as they provide d guidance to compare products that perform ed similar 
functions. When analysing substitute materials, it was important to examine characteristics such 
as tradabili ty, non -toxicity, affordability, accessibility and availability of substitute materials and 
products. It was equally important to examine considerations on toxicity, GHG emissions, reuse , 
and recyclability.  There was a missing link between setting targets to phase out plastics and 
consideration of material substitutes . To address this, the World Bank plastic substitute 
estimator help ed identify better substitutes at country level.  Comparison had to  be based on a 
similar function, impacts at all stages of th e product lifecycle, trade -offs, the number of times 
that the product would  be used , as well as consumer behaviour and existing local sustainable 
practices.  It was  also mentioned that countries should pay attention to gender aspects related 
to material sub stitution, especially  concerning demand for natural or mineral materials which 
could have social consequences through additional labour demand in different areas. Finally, 
attention had to be paid to  the consequences of reuse systems on gender dimensions a s material 
systems based on reusability tend ed to require additional services for their maintenance which 
in many countries  could be  led by women.  
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