INF/TE/IDP/RD/84* 
5 December 2022  
(22-9012)  Page: 1/4 
 Original:  English/anglais/inglés  
 
  
UNOFFICIAL ROOM DOCUMENT1 
 
DIALOGUE ON PLASTICS POLLUTION  
AND ENVIRONMENTALLY SUSTAINABLE PLASTICS TRADE  
SUBMISSIONS BY FORTUNA COOLS  
Workshop 6 December 2022  
 
 
DOCUMENT DE S ÉANCE NON OFFICIEL1 
 
DIALOGUE ON PLASTICS POLLUTION  
AND ENVIRONMENTALLY SUSTAINABLE PLASTICS TRADE  
SUBMISSIONS BY FORTUNA COOLS  
Workshop 6 December 2022  
 
 
DOCUMENTO DE SALA NO OF ICIAL1 
 
DIALOGUE ON PLASTICS POLLUTION  
AND ENVIRONMENTALLY SUSTAINABLE PLASTICS TRADE  
SUBMISSIONS BY FORTUNA COOLS  
Workshop 6 December 2022  
 
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* In Original language only/En langue originale seulement/En el idioma original solamente.  
1 Documents issued in the RD series are not official WTO documents. They usually appear in their 
language of submission and will not be translated systematically into the working languages  of the WTO. They 
are intended for use in WTO meeting rooms and are attributed an unofficial symbol for archiving purposes only.  
Les documents de la série RD ne sont pas des documents officiels de l 'OMC. Ils ne paraissent 
généralement que dans la langue d ans laquelle ils ont été communiqués et ne seront pas systématiquement 
traduits dans les langues de travail de l'OMC. Ils sont destinés aux salles de réunion de l'OMC et une cote non 
officielle leur est attribuée à des fins d'archivage.  
Los documentos de l a serie RD no son documentos oficiales de la OMC. Por lo general se distribuyen en 
el idioma en que han sido presentados y no se traduce n sistemáticamente a los idiomas de trabajo de la 
Organización. Se distribuyen para su uso en las salas de reunión de la  OMC y se les asigna una signatura no 
oficial a efectos de archivo únicamente.  INF/TE/IDP/RD/84  
 
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ANNEX – Questions for written submissions by delegations and stakeholders  
 
Break -out sessions will focus on the guiding questions below. Delegations and invited stakeholders 
are kindly invited to send written answers to these questions prior to the event to idp@wto.org . 
 
1) Working definitions  
 
Q. What are the concepts for which a "working definition" could help the identification of 
"environmentally sustainable and effective substitutes and alternatives" (please sele ct all that 
apply). For each, what are the key elements that should be included in a working definition?  
 
 concept  Key elements   Potential source  
☐ plastic    
☐ microplastics    
☐ plastics substitutes    
☐ plastic alternatives    
☐ environmentally 
sustainable    
☐ 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   
☐ single use    
☐ re-usable    
☐ biodegradable    
☐ erodible    
☐ recyclable    
☐ recycled content    
☐ compostable    
☐ plastic -related emissions    
☐ waste management 
technologies    
☐ Other    
 
2) HS code identification exercise, and trade -related measures enabling substitution of 
single -use plastic products (SUPP) and other “problematic” goods by sustainable 
materials.  
 
Q. Please indicate what "environmentally sustainable and effective substitutes and alternatives" are 
already being traded – even if not perfect/ideal solutions – and their identification codes under the 
Harmonized Commodity Description and Coding System (HS) – even if those codes  currently cover 
other products.  
 
Nonwoven natural fiber insulation (to replace plastic foams including expanded PS and PE) are 
currently traded under HS Code 5702.20.10 or as a finished cooler box product 4202.92.08  
  
3) Illustrative and extended list of material substitutes and material identification 
exercise  
 
Q. Please indicate the key criteria to be considered when identifying environmentally sustainable 
and effective substitute materials. Please provide examples of such materials as well as relevant H S 
codes if available.  
 
Key identifying criteria can and likely should include:  
 
Technical characteristics:  What are the performance sacrifices and performance improvements 
compared to status quo?  INF/TE/IDP/RD/84  
 
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  ● Air permeability  
● Water permeability  
● Water solubility  
● Tensile strength  
● Color fastness  
● UV fastness  
● End of life and circularity: Can the material be recycled and/or reus ed, can economic value 
be captured at end of life, what are the costs associated with end of life, are these costs and 
processes different in different regions, countries, cities, etc., will the material be subject to 
existing or emerging Extended Producer  Responsibility regimes, does the material break 
down naturally in 30, 90, or 365 days without extra enzymes or inputs, can the material 
enter municipal recycling, waste, or compost streams and in which locations, is the material 
backyard compostable in 30  days, which industry certifications does the material hold, etc.?  
 
Resiliency characteristics and “hidden costs”:  What are the risks and benefits that are not directly 
captured in cost of goods and material performance?  
● 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 r isk, present day and 5 -25 years forward –where are the materials 
produced, where can they be produced, who produces them, how many locations total can 
the materials theoretically be produced at commercial volumes and existing cost, and what 
will this look l ike moving forward?  
● 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  
 
Social and environmental characterist ics: How do these materials affect the people and places they 
come from and interact with?  
● Local community engagement and familiarity with the materials –i.e. level of indigenous 
knowledge and indigenous support present, level of local political knowledge a nd support 
present?  
● Substitution –effect of new demand on land use and local economy  
● Water use: Is production of the material diverting or polluting potable or non -potable water?  
● Emissions: Is production, use, and disposal of the material increasing or decr easing status 
quo CO2e emissions?  
● Industrial support: Is material production creating new business opportunities or 
employment  opportunities in places with high unemployment and/or limited advanced 
industrial opportunities?  
 
Materials that meet some or a ll of these requirements include:  
● Nonwoven coconut fiber mats  
● Pulped and molded coconut fiber dust  
● Pulped and molded bagasse  
 
 
4) Minimum criteria for life cycle analysis, including other considerations such as 
tradability, non -toxicity, affordability, accessibility, and availability.  
 
Q. What are the key criteria that should be included in the life cycle analysis (and other 
considerations such as tradability, non -toxicity, affordability, accessibility, and availability) of 
plastics, their  alternatives, and substitutes.  
 
Other than the above stated considerations, supply chain resiliency and redundancy is critical, taking 
into consideration climate change, climate policy, and geopolitical risks.  
 
Climate change risk is important when consi dering 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.  
 INF/TE/IDP/RD/84  
 
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  Climate policy risk includes 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. Finally, restrictions and 
taxes on emission -intensiv e trade such as international air freight and mining can radically change 
material availability and cost.  
 
Geopolitical risk includes trade disruptions due to war or non -armed conflict as well as domestic and 
international supply chain resilience to these risks, with particular attention to component 
bottlenecks if some or all materials can only be produced in certain places and/or by certain actors. 
For example, bagasse is produced in the US as well as dozens of countries around the world with 
sugarcane re fineries, but abaca fiber is only produced by a few countries with certain agronomic 
conditions like the Philippines, and PLA can only be produced in places with existing fossil fuel 
operations.  
 
 
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