INF/TE/IDP/RD/66* 
 
27 October 2022  
(22-8090)  Page: 1/4 
 Original: English /anglaise/ inglés  
 
  
UNOFFICIAL ROOM DOCUMENT1 
 
INFORMAL DIALOGUE ON PLASTICS POLLUTION  
AND ENVIRONMENTALLY SUSTAINABLE PLASTICS TRADE  
CIEL’S WRITTEN STATEMENT  
Pre-plenary meetings 19 -20 September 2022  
 
DOCUMENT DE SÉANCE NON OFFICIEL1 
 
INFORMAL DIALOGUE ON PLASTICS POLLUTION  
AND ENVIRONMENTALLY SUSTAINABLE PLASTICS TRADE  
CIEL’S WRITTEN STATEMENT  
Pre-plenary meetings 19 -20 September 2022  
 
DOCUMENTO DE SALA NO OF ICIAL1 
 
INFORMAL DIALOGUE ON PLASTICS POLLUTION  
AND ENVIRONMENTALLY SUSTAINABLE PLASTICS TRADE  
 
CIEL’S WRITTEN STATEMENT  
Pre-plenary meetings 19 -20 September 2022   
 
_______________  
 
1 In Original language only/En langue originale seulement/En el idioma original solamente.  
1 Documents issued in the RD series are not official WTO documents. They usually appear in their 
language of submission and will not be translated systematically into the working languages of the WTO. They 
are intended for use in WTO meeting rooms and are a ttributed an unofficial symbol for archiving purposes only.  
Les documents de la série RD ne sont pas des documents officiels de l 'OMC. Ils ne paraissent 
généralement que dans la langue dans laquelle ils ont été communiqués et ne seront pas systématiquemen t 
traduits dans les langues de travail de l'OMC. Ils sont destinés aux salles de réunion de l'OMC et une cote non 
officielle leur est attribuée à des fins d'archivage.  
Los documentos de la serie RD no son documentos oficiales de la OMC. Por lo general se d istribuyen en 
el idioma en que han sido presentados y no se traducen sistemáticamente a los idiomas de trabajo de la 
Organización. Se distribuyen para su uso en las salas de reunión de la OMC y se les asigna una signatura no 
oficial a efectos de archivo ún icamente.  INF/TE/IDP/RD/66  
 
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  WTO Informal Dialogue on Plastics  
 
CIEL’s Written Statement  
 
19th and 20th of September 2022  
 
STATEMENT FOR DISTRIBUTION  
 
 
 
Your excellencies ,  
Ladies and gentlemen,  
Distinguished members of the WTO,  
 
Thank you for your kind invitation to this pre -Plenary Meeting of the Informal Dialogue  on Plastics, 
which demonstrates once again the welcome willingness of some WTO Members to open the doors 
of the WTO to Civil Society Organizations (CSO) and environmental experts.  
 
The Center for International Environmental Law (CIEL) has been coordinati ng CSO’s engagement 
over the past 5 years in the UNEA process related to plastics, and is a founding member of the 
Geneva Environment Network #Beat Plastic Pollution Group.2 CIEL has also been leveraging an 
active and direct engagement in processes such as the BRS Conventions, the WTO, UNEP, and other 
international fora to build bridges between the various actors to ensure that the negotiated 
international legally binding ins trument that aims to end plastic pollution (Plastics Treaty)3 is 
Efficient , Ambitious  and Fair. 
WORKSTREAM NO. 1: REDUCTION TO TACKLE PLASTIC POLLUTION AND CIRCULAR 
ECONOMY FOR PLASTICS  
We highly welcome the inclusion of discussions on reduction of plasti cs into the circular economy 
workstream, and the ambitious and diligent work of the delegations of Colombia and Ecuador.  
 
The inclusion of reduction of resource production and use of plastics into discussions on circular 
economy will help ground the IDP’s  work and lead the way to fully address the complexities and 
harms caused by plastics and plastic pollution.  
 
As we mentioned in our Statement of the 18th of March4, if the world is to prioritize the foundational 
principles of the circular economy, there can be no role for the continued toxic over -production and 
use of plastics. The harms from plastics run contrary to widely understood principles of circularity. 
Additionally, simply recycling plastics will never be truly circular nor sustain able.5 
 
On chemical recycling, there is no evidence that chemical recycling is ‘environmentally sound’. All 
evidence is to the contrary, the environmental impact is huge. Chemical recycling has also high 
energy consumption costs and a high carbon footprin t. The International Pollutants Elimination 
Network (IPEN) published a report called Plastic Waste Management Hazards: Waste to Energy, 
 
2 See Geneva Beat Plastic Pollution website at 
https://www.genevaenvironmentnetwork.org/resources/updates/geneva -beat-plastic -pollution -dialogues/ .  
3 United Nations Environment Assembly resolution 5/14, End plastic pollution: Towards an international legally 
binding instrument, UNEP/E A.5/Res.14 (2 March 2022) , accessible at 
https://wedocs.unep.org/bitstream/handle/20. 500.11822/39764/END%20PLASTIC%20POLLUTION%20 -
%20TOWARDS%20AN%20INTERNATIONAL%20LEGALLY%20BINDING%20INSTRUMENT%20 -
%20English.pdf?sequence=1&isAllowed=y .   
4 Statement by the Center for International Environmental Law, IDP Workstreams Meeting, 18 March 2022,  
INF/TE/IDP/RD/24, accessible at 
https://docs.wto.org/dol2fe/Pages/SS/directdoc.aspx?filename=q:/INF/TEIDP/RD24.pdf&Open=True .  
5 See GAIA recyc ling reports; See also: Reuters, The Recycling Myth: Big Oil’s Solution For Plastic Waste Littered 
With Failure, accessible at https://www.reuters.com /investigates/special -report/environment -plastic -oil-
recycling/ .  INF/TE/IDP/RD/66  
 
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  chemicals and recycling and plastics fuels.6 This report examines the current and emerging methods 
by which plastic was te is managed globally and questions whether any of them present a solution 
to the rapidly accelerating generation of plastic waste. The short answer is that recycling at the 
margins cannot provide a solution to plastic pollution when plastic production is  set to grow 
exponentially. Other ‘recovery’ waste management techniques such as incineration, plastic to fossil 
fuel, and downcycling to incorporate plastic waste in roads, will simply generate more pollution. The 
only long -term answer to plastic pollutio n is to produce less plastic.  
 
Capping Plastic production  (i.e. reduction) and limiting single -use application of plastics (i.e. 
reuse) are core policies for achieving the ﬁrst pillar of a circular economy, as they provide key 
pathways toward conservation of resources.  
 
Removing toxic additives  in plastics production, increasing transparency in production processes, 
and  requiring that plastics manufacturers be responsible for the harmful impacts and climate 
emissions replete throughout the plastics life cy cle are central to the second pillar of a circular 
economy, eliminating externalities  
 
We hope the IDP will continue to put efforts to prioritize innovations that reduce the resource 
extraction inherent in the production and use of plastics, centering effo rts on  reuse, reﬁll, repair, 
and eliminating  unnecessary plastic before considering waste management options.  
 
 
WORKSTREAM NO. 2: PROMOTING TRADE TO TACKLE PLASTIC POLLUTION  
Many of the discussions and presentations under this workstream have focused on alternatives and 
substitutes to plastics.  
As of today, there is no definition of ‘alternatives’ or ‘substitutes’ to plastics. We do not know either 
what an environmentally sustainably sound alternative or substitute is. This will be a task that 
negotiators of the Plastics Treaty will have to look at in the incoming months.  
However, there are a few key elements to take into consolidation when discussing alternatives and 
substitutes to plastics:  
- Any discussion on replacing plastic use with alternatives must consider this question in a 
systematic wa y and include work on alternative distribution systems, and systemic change. 
If the focus of the discussion is only on replacing a plastic single use item, with another 
alternative material single use item, this will be a major loss of opportunities to hav e a real 
impact on the plastic crisis. This means that we must not only eliminate the production 
and use of plastics when possible  but also avoid replacing it with alternatives and 
substitutes that will also generate waste . 
 
- In circumstances where alternat ives and substitutes are strictly needed, it will be important 
to ensure that those alternatives and substitutes are truly circular by definition, and ensure 
that they will be toxic free .  
We hope the IDP will continue to put efforts to move away from sing le-use, and towards reuse and 
refill as much as possible. We thank the delegations of Australia and the Philippines for their initiative 
and leadership and UNCTAD for their work on this important issue.  
  
 
6 See IPEN, Plastic Waste Management Hazards: Waste -to-Energy, Chemical Recycling, and Plastic Fuels, 
accessible at https://ipen.dev.clerestory.com/documents/plastic -waste -management -hazards -waste -energy -
chemical -recycling -and-plastic -fuels.  INF/TE/IDP/RD/66  
 
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WORKSTREAM NO. 3: CROSSCUTTING ISSUES  
We welcome the initiative and work to ensure a presence of UNEP and the BRS Secretariats at the 
IDP and of the WTO Secretariat at the INCs. And we thank the leaderships of the delegations of Fiji, 
the UK and China on this important workstream.  
From the very i nception of the idea of a possible global instrument on plastic, CSO’s engagement in 
the negotiations of the Plastics Treaty has been consistent, in depth, and instrumental in the 
adoption of the mandate for negotiation at the last UNEA meeting.  
In other words, CIEL is not the only relevant environmental stakeholder that has technical expertise 
in plastics pollution and that has been at the forefront of the battle against the plastic crisis.  
We believe that what has been achieved at the IDP in terms of CS O participation is unprecedented 
at the WTO. It is the living demonstration that the WTO is evolving and moving to a new era. We 
thank you for your leadership and commitment and we urge you to share your experience with other 
WTO processes and showcase our  success.  
Additionally, considering the openness that the IDP has demonstrated, it could be helpful to think 
and consider how the IDP process could further align with the one of the Plastics Treaty in terms of 
public participation and in the long term cro ss fertilize its work to other streams of work of the WTO.  
This would ensure further coordination with negotiations ongoing at the INC and ensure that the 
work of the IDP is environmentally grounded and accepted outside of the WTO.  
CIEL recently published  a legal brief on meaningful and effective stakeholder involvement in 
intergovernmental environme ntal negotiations .7 This piece focuses on the legal aspects of public 
participation and examines the rules governing intergovernmental negotiation processes with 
lessons that can be extrapolated to other processes, such as the IDP, and more largely at the  WTO.  
Thank you very much for your time, we look forward to supporting the IDP’s work and collaborating 
with other stakeholders.  
 
Please accept, Excellencies and colleagues, the assurances of our highest consideration.  
 
 
Helionor de Anzizu  
Staff Attorney, Center for International Environmental Law  
hdeanzizu@ciel.org  
 
 
Pre-plenary meetings 19 -20 September 2022  
 
 
 
 
__________  
 
7 See CIEL’s publication ‘Towards a Global Treaty to End Pl astic Pollution: Ensuring Meaningful and Effective 
Stakeholder Involvement in the Intergovernmental Environmental Negotiations’, accessible at 
https://www.ciel.org/wp -content/uploads/2022/05/Toward -a-New-Instrument -Addressing -the-Full-Life-Cycle-
of-Plastics_Public -Participation.pdf .