July 16 2021
Dear Sirs
The Japan Machinery Center for Trade and Investment (“JMC”) is a nonprofit organization with the character of a public-interest corporation. It wasestablished in December 1952 in accordance with the Japanese Export andImport Trade Law under the authorization of the Minister of Economy, Tradeand Industry of Japan. The objective of JMC is to engage in activities thatenhance the common benefit of member companies and promote the sounddevelopment of international trade and investment by the machineryindustry. JMC comprises member companies engaged in machinery andsystems-related exports and foreign investments such as machinery
manufacturers, trading houses and engineering companies. At present, thetotal number of JMC member companies is about 240.
Our committee handles environmental and product safety issues overproducts for trade and is strongly concerned with overseas environment andproduct safety related regulations on product. From this standpoint, wewould like to send the attached comment Australia National Plastic Plan 2021.
If you have any questions, please feel free to contact our secretariat (Mr.
Chiaki Morikawa, E-mail: morikawa@jmcti.or.jp).
Sincerely yours,

KANNO Yasuhiko
Chairman
Environment Law CommitteeOur comment on Australia National Plastic Plan 2021
As for “Phase out expanded polystyrene (EPS) in moulded consumer packaging (July2022)” in National Plastic Plan 2021, we would like you to consider the electric andelectronic equipment (EEE) as exemption according to the following reasons.
1. In order to reduce the environmental impact of EPS (Expanded Polystyrene), Japanese
EEE manufacturers have been working for many years to develop alternative
materials for EPS throughout its lifecycle, from design, manufacture andtransportation to disposal. However, EPS is still an indispensable material for thefollowing reasons.
(1) There is no alternative to EPS by means of current technologies. In order to sell
EEE in Australia, it is necessary to transport them with EPS packaging so as toguarantee the quality of EEE products, which include many precision instruments
for long-term transportation through long supply chain from the place of production.
In the development process of EEE, cushioning materials are carefully designed
after undergoing rigorous vibration and drop tests etc. and then EPS is the mostsuitable materials for them. If alternative materials of EPS reduce the quality oftransportation, this will lead to a worsening of the environmental impact, such asby product disposal.
(2) Cushioning materials, such as pulp mold and laminated corrugated cardboard, canbe considered as alternatives of EPS, while there are the following problems.
1) Due to their inferior cushioning properties, if any other cushioning materials thanEPS are applied to guarantee the equivalent performance, more materials than theamount of the EPS are needed. This will result in much higher environmental
impact than EPS. The increase in the amount used also leads to an increase inpackaging volume, which will lead to an increase in GHG emissions due to thedeterioration of transportation efficiency.
2) As one of example: the flat display is heavy and the weight is uneven. Therefore,
it is difficult to use paper packaging material to absorb this uneven local load.
EPS is necessary because the flat display is very delicate. When the panel isdelivered, it is strictly packed in EPS to protect it against damage from impact. Ifthe use of EPS is banned in the absence of sufficient packaging technology toreplace it, this will lead to product damage during transport, resulting in massive
waste and environmental impact.
3) As another example, air conditioner unit and printer are so heavy, which makepaper an unviable alternative due to poor durability against weight and low
impact performance, resulting in inferior shock absorbing capacity. Hence it is
not a viable alternative to EPS.

24) Pulp and paper moulds and laminated corrugated board can damage products
where EPS can avoid damage according to the following reasons.
a) Once the product has been deformed by an impact, it will not return to its
original shape, so the next weak impact will damage the product.
b) When wet, the impact resistance is significantly reduced.
(3) As other alternatives, such as polypropylene (PP) and polyethylene (PE) are being
considered, but their GHG emissions at the production stage are higher than thoseof EPS, which poses a problem in terms of reducing environmental impact.
(4) The EPS packaging for electronics does not need to be cleaned and is easy to berecycled. It should be treated separately from food packaging that is difficult toremove stains (see * 1) . Therefore, the EPS used for electronics packaging should not
be subject to "hard-to-recycle plastics".
(*1)
LIFE EPS SURE project of EU (See Page 1)：
https://ec.europa.eu/environment/life/project/Projects/index.cfm?fuseaction=search.dspPag
e&n_proj_id=6184&docType=pdf

2. Most of the sources of plastic waste are packaging for food, personal care, andhealthcare products etc., and the EPS used for these categories should be regarded as
the first priorities of scope (see * 2) :(*2)
See Q&A pdf version which is issued together with EU Plastic Strategies (SeePage 3, 2nd paragraph of “What are single-use plastics and how are you tacklingthem? ”)
https://ec.europa.eu/commission/presscorner/detail/en/MEMO_18_6

3. On October 2020, Ministry of the environment in New Zealand government issued areport called, “Reducing the impact of plastic on our environment” that designates
later by January 2025: “A ban on all expanded polystyrene (EPS) packaging forproducts. For this proposal, we sent comment and obtained a feedback recently froma person in charge of Ministry of the environment as follows.
Expanded polystyrene
We heard through the consultation process that phasing out expanded polystyrene
will be challenging where it is used to transport cold items like seafood or protect
large homeware items across long supply chains. We will work with sector experts
to identify possible solutions and areas where alternatives could be used.
WebsitePhasing out hard-to-recycle and single-use plastics | Ministry for the Environment
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