INF/TE/IDP/RD/88  
5 December 2022  
(22-9041) Page: 1/19 
 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  
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  
 
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  DIALOGUE ON PLASTICS POLLUTION AND ENVIRONMENTALLY SUSTAINABLE PLASTICS 
TRADE   
FACTUAL SUMMARY OF DISCUSSIONS ON SUSTAINABLE AND EFFECTIVE ALTERNATIVES AND 
SUBSTITUTES  
1. In furthering the objectives of the 2021 Ministerial Statement2, 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 dedicated Workshop on the 
topic to help advance technical work.4 Coordinators agreed to do so as reflec ted in their Ministerial 
Statement adopted at the 12th Ministerial Conference.5 The objective of the workshop is 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 Ministe rs to "look for concrete, pragmatic, and effective outcomes … at the latest by the 
13th Ministerial Conference. "6 
2. The exploratory Workshop on sustainable alternatives and substitutes to plastic  (Workshop) , 
organized in cooperation with the United Nations Conference on Trade and Development (UNCTAD) 
and scheduled to take place on 6 December 2022, will cover four specific issues: (i) working 
definitions for terms relevant to trade in substitutes and alternatives; (ii) Harmonized Commodity 
Description and Cod ing 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 mat erial 
identification exercise; and (iv) minimum 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 t o date on the se topics covered by the Workshop.  
3. In total, since the Dialogue's first 2021 meeting7, 60 interventions (presentations and 
statements) were made on topics directly related to trade promotion to tackle plastic pollution by 
15 different delegat ions, 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 (October 2022).  
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)   
Pew Charitable Trusts  WBCSD  
 
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  Session, para. 12.  
5 See Ministerial Statement by Coordinators on Plastic Pollution and Environmentally Sustainable Plastics 
Trade (WT/MIN(22)/12) , 13 June 2022.  
6 See Ministerial Statement on Plastic Pollution and Environmentally 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 2 019, specifically by Bangladesh.  INF/TE/IDP/RD/88  
 
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  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 9 to "HS code 
identification exercise and trade -related measures enabling substitution of single -use plastic 
products (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 T ERMS 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 certa in 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 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. One stakeholder  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 alternative s 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 product? Does the value of the product in performing that need exceed the tru e 
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 same societal need ( e.g. 
 
8 Each intervention could include simultaneously suggestions, actionable points, observations, 
challenges and/or domestic 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 Session.  
INF/TE/IDP/RD/88  
 
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  without plastics), that can increase the ratio of s ocietal worth over costs of damage done (negative 
externalities)?11  
8. One stakeholder noted that it was not only single -use plastics ( SUP) that were the challenge 
but also unnecessary 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 fo r harmonized definitions .12 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 packag ing 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 considered.13 
9. Across the meetings, discussions and writt en 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.14 The table below reflects 
definitions and key elements to be taken into account, as suggested by  participants and  stakeholders  
at the Dialogue's pre -plenary and plenary sessions, as well as in response to the guiding questions 
to the Workshop : 
Table 2: Working definitions for terms relevant to substitutes and alternatives raised in 
the context of Dialogue discussions  
CONCEPT  KEY ELEMENTS  
Plastic  - 
Micro -plastics  Generic term for small pieces of plastic under 5 mm.15 
Plastics substitutes  Non-polymer natural materials from mineral, marine, plant, or animal 
origin, that have similar properties of fossil fuel -based plastics. They 
should have lower environmental impact along their life cycle (e.g., 
natural fibers, agricultural wastes, and other forms of b iomass). 
Depending on the case, they should be biodegradable/compostable or 
erodible, and should be suitable for reuse, recycling, or sound waste 
disposal as defined by national, regional regulations or in 
internationally agreed definitions. They can inclu de by -products. 
Plastic substitutes should not be hazardous for human, animal, or plan 
life. .16 
Similar or better quality than plastics .17 
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 
plastic s 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.  .18 
Similar or better quality than plastics .19 
 
11 CIEL presentation ( INF/TE/IDP/RD/79 ), 17 November 2022 Pre -Plenary Session.  
12 University of Portsmouth statement ( INF/TE/IDP/RD/68 ), 17 October 2022 Pre -Plenary Session.  
13 Informal Summary ( INF/TE/IDP/R/8 ), 11 October 2022, Plenary Session.  
14 Workshop on sustainable alternatives and substitutes to plastic  agenda and guiding questions  
(INF/TE/IDP/RD/87 ). 
15 "Addressing Single -use Plastic Products Pollution Using a Life Cycle Approach" , UNEP 2021. 
16 UNCTAD  submission to the Workshop  (INF/TE /IDP/RD/83 ). 
17 Response to questions circulated by the WTO Secretariat.  
18 UNCTAD submission to the Workshop  (INF/TE/IDP/RD/83 ). 
19 Response to questions circulated by the WTO Secretariat.  INF/TE/IDP/RD/88  
 
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  Environmentally 
sustainable  Alternatives and substitutes that do not  generate waste.20 
Substitution by multi -use products preferable to substitution of a 
single -use (plastic) product by another single -use (e.g. paper) 
product.21 
Substitute or alternative materials  that have far less negative impactful 
externalities  than plastics.22  
Truly circular alternatives and substitutes  that are toxic free. 23 
Must not  contribute more than plastics  to consumption and waste due 
to food spoilage and transportation losses.24 
Renewable .25 
Competitive price .26 
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 .27 
Need for improved access to cost -effective and environmentally 
friendly alternatives to plastics, in particular single -use plastics , in 
developing countries .28  
Opportunities for  displacing plastic imports in domestic marketplace in 
some developing countries, while also supporting livelihoods in rural 
communities, including by generating em ployment for women.29 
Accessible and available with  a preference for indigenous and/or 
localized/regional supply chains ; integrating the notion of industrial 
development .30 
Disposable .31 
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.32 
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.33 
Single -use plastic 
product  Plastic products not conceived, designed, or introduced into the 
marke t 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 which the product 
performs its function.34 
 
20 CIEL statement  (INF/TE/IDP/RD/66 ), 19-20 September 2022 Pre -Plenary  Session.  
21 Aide Memoire (upcoming), 17 November 2022 Pre -Plenary Session, para. 17.  
22 CIEL statement ( INF/TE/IDP/RD/79 ), 17 November 2022 Pre -Plenary Session.  
23 CIEL statement ( INF/TE/IDP/RD/79 ), 17 November 2022 Pre -Plenary Ses sion. 
24 Informal Summary ( INF/TE/IDP/R/8 ), 11 October 2022, Plenary Session.  
25 Response to Workshop guiding questions.  
26 Response to Workshop guiding questions.  
27 Response to Workshop guiding questions.  
28 3rd co-sponsors meeting, June 2021.  
29 TESS Statement ( INF/TE/IDP/RD/63/Rev.1 ), 11 May 2022 Pre -Plenary  Session.  
30 Aide Memoire  (upcoming) , 17 November 2022 Pre -Plenary Session.  
31 Response t o Workshop guiding questions.  
32 Aide Memoire (upcoming), 17 November 2022 Pre -Plenary Session.  
33 Aide Memoire (upcoming), 17 November 2022 Pre -Plenary Session.  
34 Aide Memoire (upcoming), 17 November 2022 Pre -Plenary Session.  INF/TE/IDP/RD/88  
 
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  Single-use (low durability), non -biodegradable and non -recyclable, 
containing harmful additives, prone to leaching, and impact on inland 
waterways and oceans .35 
Key factor is extent of usage before disposal (e.g. plastic chair as 
compared to plastic packaging and cutler y)36 
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.37 
Products made from oxo -degradable plastics which degraded  into 
micro -plastic particles when littered .38 
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 .39 
Re-usable  Durable .40 
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.41 
Biodegradable  Biodegradable in natur al condition .42 
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).43 
Biodegradable plastics are plastics that can be broken down by living 
organisms into elements th at 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 c an be broken down by organisms found in soil. 
Marine -biodegradable plastics can be broken down by organisms found 
in seawater.44 
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 a re a source of microplastics.45 
 
35 Aide Memoire (upcoming), 17 N ovember 2022 Pre -Plenary Session.  
36 CIEL statement ( INF/TE/IDP/RD/79 ), 17 November 2022 Pre -Plenary Session.  
37 "Addressing Single -use Plastic Products Pollution Using a Life Cycle Approach" , UNEP 2021. 
38 Aide Memoire (upcoming), 17 November 2022 Pre -Plenary Ses sion. 
39 Aide Memoire (upcoming), 17 November 2022 Pre -Plenary Session.  
40 Response to Workshop guiding questions.  
41 "Addressing Single -use Plastic Pr oducts Pollution Using a Life Cycle Approach" , UNEP 2021. 
42 Response to Workshop guiding questions.  
43 "Addressing Single -use Plastic Products Pollut ion Using a Life Cycle Approach" , UNEP 2021. 
44 "Single -Use Plastics Products and their alternatives: Recommendat ions from Life Cycle Analysis" , 
UNCTAD 2022.  
45 "Single -Use Plastics Products and their alternatives: Recommendations from Life Cycle Analysis" , 
UNCTAD 2022.  INF/TE/IDP/RD/88  
 
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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 under most normal environmental conditio n.46 
Erodible  - 
Recyclable  Recyclable under normal condition .47 
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 material of a 
sufficient quality  so that it can find end markets to substitute for the 
use of the primary raw material or organic.48 
Material recycling: Reprocessing, by means of a manufacturing 
process, of a used (packaging) material into a product, a component 
incorporated into a product, or a secondary (recycled) raw material; 
excluding energy recovery and the use of the product as a fuel.49 
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.50 
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.51 
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.52 
Recycl ed content  Bamboo material .53 
Compostable  Compostable in natural condition .54 
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?55 
Capable of biodegrading under specified conditions and timescales, 
usually only encountered in an industrial composter (standards 
apply).56 
 
46 WCO Statement  (INF/TE/IDP/RD/20 ), 18 March 2022 Pre -Plenary Session.  
47 Response to Workshop guiding questions.  
48 Plastic Recyclers Europe presentation ( INF/TE/IDP/RD/74 ), 17 November 2022 Pre -Plenary Session.  
49 "Addressing Single -use Plastic Products Pollution Using a Life  Cycle Approach" , UNEP 2021. 
50 "Single -Use Plastics Products and their alternatives: Recommendations from Life Cycle Analysis" , 
UNCTAD 2022.  
51 University of Portsmouth statement ( INF/TE/IDP/RD/68 ), 17 October 2022 Pre -Plenary Session.  
52 CIEL presentation ( INF/TE/IDP/RD/79 ), 17 November 2022 Pre -Plenary Session.  
53 Response to Workshop guiding questions.  
54 Response to Workshop guiding questions.  
55 CIEL presentation ( INF/TE/IDP/RD/79 ), 17 November 2022 Pre -Plenary Session.  
56 "Addressing Single -use Plastic Products Pollution Usi ng a Life Cycle Approach" , UNEP 2021. INF/TE/IDP/RD/88  
 
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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 comp osting 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 soil temperature and conditions found 
in home compost piles.57 
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 extrac tion 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 .58 
Bamboo products are low -carbon products to reduce high emission of 
plastics after substitution .59 
Waste management 
technologies  - 
 
10. One stakeholder suggested that  a glossary of terms could be developed that draws on work 
already underway and undertaken by international organizations .60 In addition to the definitions 
included in the table above, further  definitions were proposed by UNEP  and UNCTAD  of the term 
"biobased plastics ": "A type of plastic derived from biomass such as organic waste material or crops 
grown specifically for the pu rpose, which may or may not be biodegradable ."61 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. " 62 
2  HS CODE IDENTIFICATION EXERCISE AND TRADE -RELATED MEASURES ENABLING 
SUBSTITUTION OF SINGLE -USE PLASTIC PRODUCTS (SUPP) AND OTHER "PROBLEMATIC" 
GOODS BY SUSTAINABLE MATERIALS  
11. The 2021 Ministerial Statement em phasizes 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 point for 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 .  
12. Discussions highlighted that, a t present, there is no internationally recognized and 
comprehensive list (or  classification) of plastics  or their alternatives and substitutes  to facilitate a 
straightforward identification63 and p articipants in the Dialogue  discussions identified promoting 
further development of the HS, and more specifically classifications relevant to material substitutes, 
as an area for further exploration.64 As part of the WCO -WTO cooperation and as requested by the 
 
57 "Single -Use Plastics Products and their alternatives: Recommendations fr om Life Cycle Analysis" , 
UNCTAD 2022.  
58 CIEL presentation ( INF/TE/IDP/RD/79 ), 17 November 2022 Pre -Plenary Session.  
59 Response to Workshop guiding questions.  
60 TESS Statement ( INF/TE/IDP/RD/63/Rev.1 ), 11 May 2022 Pre -Plenary  Session.  
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 "Plastic Pollution and Trad e Across the Life Cycle of Plastics: Options for Amending the Harmonized 
System to Improve Transparency ", TESS 2022.  
64 Aide Memoire ( INF/TE/IDP/R/7 ), 19-20 September 2022 Pre -Plenary Session , para. 30.  INF/TE/IDP/RD/88  
 
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  Dialogue Communication  to the WCO65, the WTO Secretariat also shared potential areas of work the 
two organizations had agreed to. One of them included  better identification/differentiation of 
preferable goods ( e.g. through exploring additional subheadings for finished preferabl e alternatives  
as well as substitutes).66 
13. 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".67 In addition, the WCO identified several other impo rtant 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 f rom plastic bags which would gain the support of sufficient Members.  
• 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 unclear. 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 
biodeg rade but contain toxic additives, or plastics that are biodegradable 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 an HS provision. By a practical sense, the 
level of difficulty or the level of expense, time or resources requ ired 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 additives 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 pla stic 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 n ot 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 only 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.68 
 
14. 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 p urposes was one of the key 
elements in reducing plastics pollution and thus WCO 's expert advice was essential to Dialogue  
discussions.69 Another delegation noted that customs classifications on recycling were unclear,  and 
this was also an issue that had to be addressed.70 
15. Stakeholders also highlighted the lack of transparency with regard to types of plastics, plastic 
products, plastic additives as well as plastic  alternatives and  substitutes that were traded 
internationally, in part because these were not f ully 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 creating new HS subheadings for the most commonly recycled primary polymers  or 
 
65 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 . 
66 Aide Memoire ( INF/TE/IDP/R/7 ), 19-20 September 2022 Pre -Plenary Session, para. 24.  
67 WCO Statement  (INF/TE/IDP/RD/20 ), 18 March 2022 Pre -Plenary Se ssion.  
68 WCO Statement  (INF/TE/IDP/RD/20 ), 18 March 2022 Pre -Plenary Session.  
69 Aide Memoire  (INF/TE/IDP/RD/41 ), 11 May Pre -Plenary Session, para. 8.  
70 Aide Memoire  (INF/TE/IDP/RD/41 ), 11 May Pre -Plenary Session, para. 8.  INF/TE/IDP/RD/88  
 
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  amending HS subheadings to incorporate specific information for products made of polymers that 
contain POPs and other harmful chemical additives .71 
16. One suggested area for further research 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 H S codes.72 UNCTAD 
proposed an initial illustrative HS codes list for purposes of facilitating trade in plastics 
substitutes.73One 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 6 for rattan  – reflecting a much broader range of commonly traded bamboo and 
rattan commodities.74 
17. On the topic of trade -related measures enabling substitution of SUPP, one delegation 
emphasized that regulatory measures to support or stimulate the usage of p lastic substitutes or 
alternatives in terms of international trade should be consistent with WTO rules.75 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 a nd 
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.76  
18. The following table reflects sp ecific 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 : 
Table 3: HS Codes for plastic substitutes and alternat ives 
CHAPTER  HS CODE  PRODUCTS  
14 1401.10 Bamboo raw materials  
42 4202.92  Nonwoven natural fibre insulation (as a finished cooler box product)  
44 4402.10 Bamboo charcoal  
4409.21 Bamboo flooring  
4412.10 Bamboo plywood  
4418.73 Assembled bamboo flooring panels used for construction  
4418.91 Other bamboo panels used for construction  
4419.11 Bamboo chopping boards  
4419.12 Bamboo chopsticks  
4419.19 Small bamboo sticks  
4421.91 Bamboo articles of daily use  
46 4601.21 Bamboo mats/screens  
4601.92 Semi-finished bamboo plaits & plaiting articles  
4602.11 Bamboo basketwork/ wickerwork products  
4602.19  Food containers: banana/plantain leaf; coconut husk  
Straws: wheat fibre  
47 4706.30 Bamboo pulp  
 
71 TESS Statement ( INF/TE/IDP/RD/63/Rev.1 ), 11 May 2022 Pre -Plenary  Session , referring to Policy 
Brief "Plastic Pollution and Trade Across the Life Cycle of Plastics: Options for Amending the Harmonized 
System to Impro ve Transparency ". 
72 UNCTAD presentation  (INF/TE/IDP/RD/25 ), 18 March 2022 Pre -Plenary Session.  
73 UNCTAD presentation ( INF/TE/IDP/RD/36 ), 11 May 2022  Pre-Plenary  Session.  
74 INBAR presentation ( INF/TE/IDP/RD/73 ), 17 November 2022 Pre -Plenary Ses sion.  
75 Aide Memoire ( INF/TE/IDP/R/7 ), 19-20 September 2022 Pre -Plenary Session, para. 19.  
76 Aide Memoire ( INF/TE/IDP/R/7 ), 19-20 September 2022 Pre -Plenary Session, para. 19.  INF/TE/IDP/RD/88  
 
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  48 4819.10  Food containers: paper  
4819.20  Food containers: paper  
4819.30  Grocery bags/packaging: paper  
4819.40  Grocery bags/packaging: paper  
4823.69  Food containers: paper  
4823.61 Bamboo paper -based  articles  
4823.90  Straws: paper  
57 5702.20  Nonwoven natural fibre insulation (to replace plastic foams, incl. 
expanded PS and PE)  
63 6305.10  Grocery bags/packaging: jute  
6305.20  Grocery bags/packaging: Cotton  
6305.90  Grocery bags/packaging: Hemp  
70 7010.90  Liquid containers: glass  
76 7612.90  Liquid containers: aluminium  
7615.90  Liquid containers: aluminium  
7616.99  Liquid containers: aluminium  
94 9401.52 Bamboo seats  
9403.82 Bamboo furniture  
 
3  ILLUSTRATIVE AND EXTENDED LIST OF MATERIAL SUBSTITUTES AND MATERIAL 
IDENTIFICATION EXERCICE  
19. 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 trade -related capacity building and 
technical assistance needs of developing members, including expanding trade in environmentally 
sustainable and e ffective substitutes and alternatives, as an area of common interest where work 
must be intensified.  
20. Participants 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, 
plastic substitutes were non -plastic or polymer materials of vegetable, 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 (bioplastics or 
biodegradable plastics). They could therefore have similar properties to plastics because they were 
made of similar molecules. These could be used for nonfuel feedstock use and some could  be reused, 
were compostable or biodegradable.77 However, several participants noted that some plastic 
alternatives had similar waste disposal problems to conventional  plastic depending on chemical 
comp osition.  
21. The following substitutes and alternatives were raised and/or discussed:  
Table 4: Plastic alternatives and substitutes  
PLASTIC SUBSTITUTES  PLASTIC ALTERNATIVES  
General categories: Vegetable and animal 
fibres; mineral mate rials Bioplastics  
Algae biomass  Biodegradable plastics  
Cotton, Linen, Hemp  Recyclable plastic  
Abaca (Manila hemp)  Recyclable resin  
 
77 UNCTAD presentation ( INF/TE/IDP/RD/36 ), 11 May 2022  Pre-Plenary  Session.  INF/TE/IDP/RD/88  
 
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  By-products  of ready -made garments  ("jhoot")  rPET 
Murta, Areca leaves  Bio-polypropylene  
Sisal, Wheat stems  Low-density polyethylene (multiple use)  
Wood, Bamboo, Palm  Polylactic acid (PLA) and CPLA  
Bagasse  (sugarcane pulp) , Jute  Polybutylene succinate (PBS)  
Pineapple (clothing fibre)   
Steel, Aluminium   
Glass   
Paper, Cardboard, Cellulose   
Banana/plantain  pseudo -stem and  leaves  
Coconut husk s (coco coir)   
 
22. Participants also identified a number of avenues for further exploration as regards material 
substitutes which would support progress in the Dialogue : 
• 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.78 
• Promote further research, development, and adoption of material substitutes to single -use 
plastics to address plastic pollution in the ocean.79 
• Explore opportunities to make use of natural materials, marine by -products, and post -
harvest agricultural waste, which could help spur innovation, support circular economy, and 
develop new industrial capacities.80 
• 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.81  
• Need for collaborative action with other stakeholders in identifying best practices as well as 
barriers to dissemination of green alternatives to plastics.82 
• Support positive and negative incentives for environmentally sustainable and effective 
substitutes and alte rnatives to plastics.83 
• Undertake a material identification exercise: Countries, IGOs and NGOs introduce and justify 
materials they consider more suitable as better SUP substitutes in terms of LCA,  sustainable 
production, scale up and disposal.84 
 
23. 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.85 Some delegations underscored specific limitations i n 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.86 At the same time, other Members had banned some single -use plastics, such 
as straws and cutlery, and other measures were in place for items for which no clear sustaina ble 
alternatives were available (e.g. consumer information labelling requirements).87 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.88 Others had introduced national waste 
policies that would require all packaging to be recyclable or compostable by 2025.89 
24. Discussions amongst participants underscored the need for assistance for developing countries 
to produce environmentally s ustainable and effective substitutes or alternatives to plastics.90 
Delegations from developing countries emphasized the need for improved access to cost -effective 
 
78 UNCTAD presentation  (INF/TE/IDP/RD/25 ), 18 March 2022 Pre -Plenary Session.  
79 UNCTAD presentation  (INF/TE/IDP/RD/32 ), 30 March 2022 Plenary Session.  
80 UNCTAD presentation  (INF/TE/IDP/RD/32 ), 30 March 2022 Plenary Session.  
81 UNCTAD presentation  (INF/TE/IDP/RD/32 ), 30 March 2022 Plenary Session.  
82 Informal summary  (INF/TE/IDP/R/5 ), 30 March 2022 P lenary Session , para. 5.  
83 Informal summary  (INF/TE/IDP/R/5 ), 30 March 2022 Plenary Session , para. 14.  
84 UNCTAD presentation ( INF/TE/IDP/RD/36 ), 11 May 2022  Pre-Plenary  Sessio n. 
85 Nestlé presentation  (INF/TE/IDP/RD/54 ), 19-20 September 2022 Pre -Plenary . 
86 Informal summary, 30 March 2022 Plenary Session . 
87 3rd co-sponsors meeting, June 2021.  
88 3rd co-sponsors meeting, June 2021.  
89 Informal summary  (INF/TE/IDP/R/5 ), 30 March 2022 Plenary Session . 
90 Aide Memoire  (INF/TE/IDP/RD/41 ), 11 May 2022 Pre -Plenary  Session.  INF/TE/IDP/RD/88  
 
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  and environmentally friendly alternatives to plastics, in particular single -use plastics. In ternational 
cooperation and assisting developing countries were important to incentivize trade and investment 
opportunities in new markets of substitute and alternative plastics.91 It was also observed that plastic 
substitutes may be of export 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 materials to replace 
plastic imports while also supporting livelihoods in rural communities, including by generating 
employment for women.92 For instance, some plastic substitutes, such as jute, that were of export 
interest to developing countries and LDCs, were 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.93 One delegation highlighted that 
alternatives and substitu tes should be accessible and available with  a preference for indigenous 
and/or localized/regional supply chains , and should integrate the notion of industrial development .94 
25. More generally, an analysis of applied tariff rates specifically on finished plast ics and plastics 
substitutes based on an HS codes analysis revealed that not only substitutes were more expensive, 
but also faced higher tariffs.95 
26. Delegations shared experiences with local alternatives and substitutes, mentioning mechanical 
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 lumb er.96 A number of 
alternatives and substitutes for specific products were discussed, including the use of:  
• Marine biodegradable plastic and recyclable plastic for fishing gear.97 
• Recycled resin as an alternative to conventional resin.98 
• Cellulosic fibre in  place of plastic for cosmetics packaging.99 
• Jute polybags replacing low -density polyethylene (LDPE) plastic bags.100 
 
27. One stakeholder presented a study identifying the six plastic subcategories with the largest 
substitute potential by mass: monomaterial fi lms (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 ).101 
28. The following substitutes and alternatives were proposed for specific categories of plastic 
products102: 
Table 5: 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  
 
91 3rd co-sponsors meeting, June 2021.  
92 TESS Statement ( INF/TE/IDP/RD/63/Rev.1 ), 11 May 2022 Pre -Plenary  Session.  
93 CTE minutes ( WT/CTE/M/68 ), meeting held on 26 -27 November 2019 . 
94 Aide Memoire (upcoming), 17 November 2022 Pre -Plenary Session.  
95 UNCTAD presentation ( INF/TE/IDP/RD/36 ), 11 May 2022  Pre-Plenary  Session.  
96 Informal summary  (INF/TE/IDP/R/5 ), 30 March 2022 Plenary Session . 
97 OECD presentation  (INF/TE/IDP/RD/18 ) and policy paper "Towards G7 action to combat ghost fishing 
gear" , 18 March 2022 Pre -Plenary Session.  
98 Aptar Group presentation  (INF/TE/IDP/RD/53 ), 19-20 September 2022 Pre -Plenary  Session.  
99 Yves Rocher Foundation presentation ( INF/TE/IDP/RD/61 ), 19-20 September 2022 Pre -Plenary  
Session.  
100 CTE minutes ( WT/CTE/M/68 ), meeting held on 26 -27 November 2019 . 
101 PEW presentation ( INF/TE/IDP/RD/76 ) referring to the Breaking the Plastic Wave study , 17 
November 2022 Pre -Plenary Session.  
102 World Bank Group presentation , Aide Memoire, September 2022 Pre -Plenary . INF/TE/IDP/RD/88  
 
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  Disposable utensils  Polypropylene  Bio-polypropylene, 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  
 
29. Delegations observed that more information was needed on trade flows in plastic substitutes 
and alternatives.103 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 banan a leaves and 
biodegradable packaging.104 
30. 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 harmful plastics and substitutes and dis -incentivize 
(or even forbid) trade in the most harmful plastics.105 
• The UNCTAD Sustainable Manufacturing and Environmental Pollution (SMEP) programme 
conducting a study on alternative materials which can competitively substitute single -use 
plastics 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 remanufacturing 
solutions.106 
• 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.107  
• 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 so und waste management technologies and 
facilitate trade in recycled plastics and recyclable plastics.108 
 
31. Materials and products identified in reply to the Workshop guiding questions included:  
Table 6: 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  
 
103 Informal summary ( INF/TE/IDP/R/7 ), September 2 022 Plenary Session.  
104 Informal summary ( INF/TE/IDP/R/7 ), September 2022 Plenary Session.  
105 OECD presentation  (INF/TE/IDP/RD/18 ) and policy paper "Towards G7 action to combat ghost fishing 
gear" , 18 March 2022 Pre -Plenary Session.  
106 UNCTAD presentatio n, 3rd co-sponsors meeting, June 2021.  
107 WEF presentation, 3rd co-sponsors meeting, June 2021.  
108 GI presentation, 3rd co-sponsors meeting, June 2021.  INF/TE/IDP/RD/88  
 
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4  MINIMUM CRITERIA FOR LIFE CYCLE ANALYSIS (LCA) AND AFFORDABILITY, 
ACCESSIBILITY, AND AVAILABILITY  
32. The 2021 Ministerial Statement recalls the need for further commitment and actions across 
the life cycle of plastics to address marine litter and microplastics, including through a circular 
economy approach. One of the poten tial 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.109 A few delegation s 
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.110 
33. Regarding LCA of substitutes more specifical ly, 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 creating further damage. Products and packaging should be replaced 
exclusively by en vironmentally 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.111 
34. Stakeholders und erscored 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 Wor ld Business 
Council for Sustainable Development SPHERE112 packaging sustainability assessment framework; 
the World Bank’s Plastic Substitution Trade -off Estimator113 and UNEP 's 10 Objectives and Guiding 
Considerations for Green and Sustainable Chemistry114. 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 lifecycle and kept material circulating in the economy for longer.115 
35. Dialogue  participa nts discussed research on LCA that had revealed that reusable products had 
a better environmental footprint than single use plastics. However, research had also shown that 
plastic alternatives and substitutes had different environmental impacts, and the su ccess of a life 
cycle approach was largely contingent on the behaviour of consumers and businesses.116 
36. A number of stakeholders introduced projects related to LCA of alternatives and substitutes. 
UNCTAD  presented certain LCA considerations based on their SM EP programme country specific LCA 
assessments117 underscoring that LCAs can be costly and time consuming and therefore necessitate 
a standard approach.  UNEP  presented its technical work on LCA for single -use plastics products and 
their alternatives.118 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 durable, 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 single -use plastics p roducts with reusable products.  
• Taking a life cycle approach was key in informing the right decision to address plastics 
pollution.  
 
109 UNCTAD presentation  (INF/TE/IDP/RD/25 ), 18 March 2022 Pre -Plenary Session.  
110 Informal summary ( INF/TE/IDP /R/6), 24 May 2022 Plenary Session.   
111 Aide Memoire ( INF/TE/IDP/R/7 ), 19-20 September 2022 Pre -Plenary Session.  
112 WBSCD  presentation ( INF/TE/IDP/RD/55 ), 19-20 September 2022 Pre -Plenary Session.  
113 World Bank  presentation ( INF/TE/IDP/RD/56 ), 19-20 September 2022 Pre -Plena ry Session.  
114 University of Portsmouth statement ( INF/TE/IDP/RD/68 ), 17 October 2022 Pre -Plenary Session.  
115 University of Portsmouth statement ( INF/TE/IDP/RD/68 ), 17 October 2022 Pre -Plenary Session.  
116 UNEP and UNCTAD presentations, Informal summary ( INF/TE/IDP/R/6 ), 24 May 2022 Plenary 
Session.  
117 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, May 2022 Pre -Plenary , 11 May 2022 Pre -Plenary Session . 
118 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 202 2 Pre-Plenary Session.  INF/TE/IDP/RD/88  
 
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37. Further analysis of specific products, including, plastic bags, bottles, beverage cups and 
nappies, revealed that:  
• Reusabl e 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 plastics an d materials as well as to shift 
from single -use to reusable products.  
• Biodegradable or biobased products did not necessarily have "better" environmental impacts 
than conventional products.  
 
38. Yves Rocher Foundation  addressed LCA from the perspective of the (RE)SET Cosmetics 
initiative to replace plastic of cosmetics packaging by cellulosic fibre.119 They faced challenges in 
terms of:  
• Recyclability – developing packaging made up of at least 85% cellulosic fibres for a 
significant material yield during recyclin g 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 coat ings towards 100% bio -based coatings 
and the need to ensure barrier properties and preservation of formulas (restitution rate, 
water resistance, formula stability, etc.).  
 
39. The World Bank Group  shared their recent study on the Plastic Substitution Trade of f 
Estimator which provided a holistic comparison of the costs and benefits of plastics and their 
alternatives.120 The estimator compared ten plastic products with up to four alternatives currently 
available in the market. The comparison was based on the bas is of input, one -to-one weight of the 
alternative, function performed, lifecycle assessment, external cost analysis as 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 
valuation to determine the external costs of plastics and their alternatives. The World Bank had 
piloted this data -driven model in 5 countries (Bangladesh, Mozambiqu e, Nigeria, St. Lucia, and 
Vietnam). The estimator also had some limitations: it could not be used to assess the effectiveness 
of regulatory schemes and policies; financial implications of product substitution; and affordability 
and acceptability by users of the alternative materials.  
40. The World Business Council for Sustainable Development (WBCSD) presented their packaging 
sustainability framework (SPHERE) to support companies in switching to sustainable packaging.121 
SPHERE  define d packaging sustainability a s maximum circularity and minimum environmental 
footprint, while avoiding the presence of harmful 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. 
41. As regards areas for further analysis, it was recognized that each Member may have different 
substitutes and alternatives appropriate for them and their environm ental sustainability across the 
life cycle would depend on local production and disposability options. 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 environmenta lly sound substitutes and alternatives. It would also be helpful to learn more 
about the operation of global supply chains for plastic substitutes. For example:  
 
119Yves Rocher Foundation presentation ( INF/TE/IDP/RD/61 ), 19-20 September 2022 Pre -Plenary  
Session.  
120 World Bank  presentation ( INF/TE/IDP/RD/56 ), 19-20 September 2022 Pre -Plenary Session . 
121 WBSCD  presentation ( INF/TE/IDP/RD/55 ), referring to its report "SPHERE: the packaging 
sustainability framework" , 19-20 September 2022 Pre -Plenary Session . INF/TE/IDP/RD/88  
 
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  • What sort of North -South private sector linkages or collaboration exists? Are there any 
compani es in OECD countries for example that have invested in plastic substitutes in 
developing countries?  
• 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?122 
 
42. Discussions underscored  that circularity considerations, full enviro nmental 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 consistent ly 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 scale of the problem largely depended 
on the effi ciency 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 transformation of waste into valuable raw materi al for the market.  
43. 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 identify ing 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 compostable, 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 changi ng the plastic system – many single -use plastic 
products would be eliminated or replaced by reusable items and new delivery models. Nonrecyclable 
and hard -to-recycle plastics could be substituted for paper or compostable materials.123 
44. 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.124 One del egation 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 cha nge 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.125 
45. One participant underscored that plastic polymers could not be effectively replaced by any 
currently existing substitutes or alternatives either in the context of the economy 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 3 times less than that of 
cellulose and paper, 3 and a half times less th an that of a glass, 7 times less than that of iron, etc.; 
(ii) light weight of polymers: polypropylene is 8 times lighter than steel, 9 times lighter than copper, 
and 3 times lighter than aluminium; and (iii) ability of polymers to resist diffusion of gass es: highly 
applicable to food packaging and allows to extend the shelf life of content.126 
46. The following table summarised the criteria for LCA highlighted by participants at the 
Dialogue's sessions, as well as in response to the Workshop guiding questions.  
  
 
122 TESS statement ( INF/TE/I DP/RD/65 ), 11 October 2022 Plenary Session.  
123 PEW presentation ( INF/TE/IDP/RD/76 ) referring to the Breaking the Plastic Wave study , 17 
November 2022 Pre -Plenary Session.  
124 INBAR presentation ( INF/TE/IDP/RD/73 ), 17 November 2022 Pre -Plenary Session.  
125 Aide Memoire (upcoming), 17 November 2022 Pre -Plenary Session.  
126 Aide Memoire (upcoming), 17 November 2022 Pre -Plenary Session.  INF/TE/IDP/RD/88  
 
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  Table 7: Criteria for lifecycle analysis  
LCA CRITERIA  ELEMENTS  TO CONSIDER  
Cost-effectiveness  • Availability and affordability  
Design / technology  • Type of feedstocks . 
• Material.  
• Air permeability; Water permeability; Water solubility; Tensile 
strength; Colour fastness; UV fastness . 
Recyclability, Reusability, 
Compostability, 
Biodegradability  • Recyclability/Compostability: Especially important for naturally 
biodegradable feedstock materials.  
• Reusability: Especially important in the case of reusable 
plastics.  
• Natural break down 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 captur ed at end of life ; costs associated with 
end of life . 
• Different  costs and processes in different regions . 
• Existing or emerging Extended Producer Responsibility 
regimes . 
• Industry certifications .  
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 co st. 
• 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 l ead 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 eutrop hication . 
• Energy use of production processes.  
• 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 and 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 indus trial 
opportunities . INF/TE/IDP/RD/88  
 
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  Supply chain resiliency 
and redundancy  • Climate change risk (important when considering 
biomaterials ): when, where, and what is grown 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 imp acts 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 radically change material availability and cost.  
• Accessibility : a preference for indigenous and/or 
localized/regional supply chains for material substitutes . 
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  
 
 
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