INF/TE/IDP/W/9  
 
17 May 2023  
(23-3436) Page: 1/3 
  Original: English  
 
 
 
DIALOGUE ON PLASTIC POLLUTION AND ENVIRONMENTALLY SUSTAINABLE PLASTICS 
TRADE ( DPP) 
COORDINATORS LETTER  TO THE WORLD CUSTOMS ORGANIZATION (WCO) WITH REGARD TO THE 
2027 H ARMONIZED SYSTEM (HS)  AMENDMENT CYCLE  
The following communication, dated 17 May 2023 , is being circulated at the request of the 
delegations of Australia, Barbados, China, Ecuador, Fiji and Morocco (DPP Coordinators).   
 
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1. The Coordinators of the DPP sent a letter to the WCO  Secretariat  on 8 May reflecting on 
discussions regarding transparency of trade flows in plastic and plastic containing products and the 
current 2027 HS amendment cycle.  
2. The text of the letter is below, for your reference:   
We recall the communication from  the Dialogue on Plastic Pollution and Environmentally Sustainable 
Plastics Trade ( DPP) to the World Customs Organization of 8  June 2022 and we are pleased to note 
that collaboration has deepened between the WTO and the WCO.  
We are now writing to seek the WCO Secretariat advice and assistance regarding the potential for 
HS amendments related to the international community’s shared commitment to tackling plastic 
pollution.  
Throughout our discussions at the WTO Dialogue on Plastic Pollution (which is now supported by 76 
co-sponsors) we have dedicated considerable discussion to how improvements to transparency and 
understanding trade flows related to plastic is critical in responding to the challenges of plastic 
pollution.  
We also recogni ze similar discussi ons that have occurred in the context of the Intergovernmental 
Negotiating Committee (INC) established to develop an international legally binding instrument on 
plastic pollution under the UNEA.  
We note that in both contexts, there is interest from governm ents to improve the transparency and 
regulation of trade flows across the life cycle of plastics, including possibly through restrictions or 
bans on trade in certain plastic products, items, feedstocks, additives, and precursors, as well as 
improving the t ransparency of the material composition of plastic products that cross international 
borders.  
In the 2021 Ministerial Statement launching the WTO Dialogue on Plastic Pollution, for instance, co -
sponsors recogni zed the need to:  
- Improve the understanding o f global trade in plastics, including flows of plastics embedded 
in internationally traded goods or associated with them (such as plastic packaging) ; 
- Identify "actions needed to improve gathering of data on trade flows and supply chains, 
including by utili zing the Harmonized Commodity Description and Coding System (HS 
Convention) of the WCO or other trade instruments or standards…and [to improve] the flow 
of information about the chemical and material characteristics of plastic products traded 
international ly."  
 
Importantly, we note that WCO members have already recogni zed the role the WCO and customs 
authorities have to play in supporting action on plastic pollution, such as the recent HS discussions INF/TE/IDP/W/9  
 
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  on the amendment to support implementation of the Basel Convention 's "plastic waste 
amendments. "  
In order to advance this work more concretely in the HS amendment process, a number of Members 
have expressed to us an interest in exploring options for HS amendments that could support their 
domestic regulation an d international cooperation.  
More granular HS codes would help governments design and implement policies designed to:  
- Control (restrict or ban) trade in materials and products that contribute to plastic pollution;  
- Monitor and regulate trade in primary pla stics and by plastic polymer type;  
- Improve transparency of the material composition of plastic products that cross international 
borders;  
- Promote trade in goods & services that can help reduce plastic pollution (non -plastic 
substitutes, recycled/recyclable  products, environmentally sound management of goods & 
services); and  
- Implement effective circular economy policies, including related to:  
o plastic recycling and use of recycled content; and  
o standards and labelling requirements for imports and exports.  
 
Among the specific areas for potential amendments to be explored, we have heard from WTO 
Members interest in the following as particularly relevant and would be pleased to discuss specific 
examples of potential amendments with the WCO Secretariat : 
- Greater dif ferentiation of primary plastics by polymer type and by feedstock (e.g. 
differentiating conventional feedstocks and recycled feedstocks, such as for recycled PET).  
- Greater differentiation of HS codes for Persistent Organic Pollutants and other harmful 
chem ical additives found in plastics (including but not limited to those already individually 
regulated by the Rotterdam and Stockholm Conventions).  
- Greater differentiation of specific single -use and other plastics (such as PVC products) of 
high environmental concern and widely regulated by governments.  
- Greater differentiation of some of the most highly -trade and highly  unnecessary or harmful 
plastic products and waste according to their material composition, including by polymer 
types and mixtures, share of recycled content, and the presence of harmful chemical 
substances of high environmental and health concern.  
- Greater differentiation of the share and types of plastics embedded in products, focusing on 
products of high environmental concern, such as fishing nets and equipment.  
- Consideration of HS codes to provide information on the share and type of plastic packaging 
that is an integral part of traded products highly associated with plastic pollution (e.g., 
packaging associated with beverages, pre -packaged foods and personal care products). This 
could include a focus on share of recycled plastic in packaging; mono -layer, mono -material 
packaging versus multi -layer, multi -material packaging; and non -plastic packaging.  
 
We recogni ze the many factors to co nsider in advancing recommendations and look forward to the 
WCO Secretariat guidance on this. In some areas, there is regrettably not yet a broad international 
consensus in the form of international definitions or standards, though we are optimistic that t his 
WTO process and the I NC will be effective in building that consensus. In the shorter term, we are 
confident there are a number of straightforward issues that could be addressed to improve 
traceability and transparency.  
We are ready to prepare some pot ential amendments proposals, including in cooperation with some 
other governments, but would welcome as a first step a conversation with the WCO Secretariat to 
explore initial ideas.  
As a complement, two further steps for consideration could be to:  
- Foster an exchange of experiences and practices among customs authorities on action with 
respect to plastics and plastic pollution, including at the 8 and 10 -digit level as this may 
yield some specific examples of areas for coordination alongside an HS amendment  process; 
and 
- Explore with customs authorities and plastic pollution experts other trade instruments, 
technologies and practices at the border that could help to support transparency of trade 
flows relevant to plastics pollution, including potentially expe rience from other sectors.  
 
Finally, we would also encourage the commencement of this discussion with our respective 
representatives to the WCO. This letter is a reflection from the DPP but is without prejudice to the INF/TE/IDP/W/9  
 
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  contribution of our delegations to the  WCO. Please do feel free to reach -out to us as well to support 
these discussions and we would also be happy to include our colleagues working on the INC Treaty 
Process.  
 
 
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