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, - Posted on October 16, 2020

Open letter: A coalition of NGOs call on the European Union to fully transpose the Basel Convention’s plastic amendments for intra-European waste trade

An open letter to Virginijus Sinkevičius, Commissioner for Environment, Oceans and Fisheries

Estelle Eonnet

Virginijus Sinkevičius
Commissioner for Environment, Oceans and Fisheries, 

CC: Mrs Florika Fink-Hooijer, Director-General of DG ENVI (Environment); and Kęstutis Sadauskas, Director for Circular Economy and Green Growth

Dear Mr Sinkevičius,

In May 2019, the 14th Meeting of the Conference of Parties to the Basel Convention adopted groundbreaking new amendments to impose stricter controls on the trade of the most problematic plastic waste. Not only did the European Union (EU) vote in favor of this change but it also co-sponsored the amendments that were originally proposed by Norway. 

However, the European Commission, through a draft Delegated Regulation, has confirmed that it does not intend to transpose the new controls for plastic waste shipments happening within the EU. As it is, such a decision would have two main detrimental effects:

  1. It would completely undermine a legislative milestone adopted by 187 parties to the Basel Convention by sending a “do as I say, not as I do” message to the rest of the world;
  2. It would allow certain types of potentially hazardous plastics to be freely traded for incineration with energy recovery across Europe.

At a time when the EU is showing unprecedented environmental leadership, taking such a decision would weaken the EU’s environmental leadership, while showing the rest of the world that double standards are in fact acceptable.

Furthermore, in a context where European plastic waste trade is increasing, with an alarming rise in  illegal plastic waste trade, the time is not for less control and monitoring. On the contrary, the EU has to step up, with clear regulations on this issue.

A coalition of NGOs have already issued a set of recommendations to fix the current legislation. We would like to reiterate our demands once again. 

A simple reference to the Council Decision (EU) 2019/638  - a decision adopted before the new Circular Economy Action Plan and its objective to create a “toxic-free environment” - is not enough. 

Furthermore, article 11 of the Basel Convention only allows alternative agreements provided “they not derogate from the environmentally sound management of hazardous and other wastes as required by this Convention”. Allowing potentially hazardous plastic waste to be freely traded, not only for recycling but also for energy recovery, cannot be understood as a similar level of protection. 

In a moment when the EU is showing bold environmental leadership for a circular economy, sending such contradictory messages would only have a negative effect. We therefore call on the EU not only to live up to the expectations it itself has created, but to continue to lead on these issues in the years to come. 

Yours sincerely,

Jim Puckett
Executive Director
Basel Action Network

Von Hernandez
Global Coordinator
Break Free From Plastic

David Azoulay
Geneva office Managing attorney
Center for International Environmental Law

Jaka Kranjc
Secretary General
Društvo Ekologi brez meja

Tim Grabiel
Senior Lawyer
Environmental Investigation Agency

Stéphane Arditi
Policy Manager for Circular Economy, Products & Waste
European Environmental Bureau

Antoinette Vermilye
Gallifrey Foundation

Lena Steger
GLOBAL 2000 / Friends of the Earth Austria

Sirine Rached
Global Policy Advocate
Global Alliance for Incinerator Alternatives

Louise Edge
Global Corporate Campaigner

Arianna Gamba
Circular Healthcare Programme Manager
Health Care Without Harm (HCWH) Europe

György Szabó
Zero Waste Program Manager
Humusz Szövetség

Muriel Papin
Déléguée Générale
No Plastic In My Sea

Merijn Tinga
Plastic Soup Surfer

Ana Gutiérrez Dewar
Policy Officer

Delphine Levi Alvares
The Rethink Plastic alliance

Mindy O’Brien
VOICE of Irish Concern for the Environment

Susana Fonseca
Member of the Board
ZERO - Association for the Sustainability of the Earth System

Joan Marc Simon
Executive Director
Zero Waste Europe

Moïra Tourneur
Advocacy Manager
Zero Waste France

Jim Keys
Vice Chair
Zero Waste North West

Elena Raste
Zero Waste Romania

Rethink Plastic, part of the Break Free From Plastic movement, is an alliance of leading European NGOs working towards ambitious EU policies on plastics. It brings together the Center for International Environmental Law (CIEL), ClientEarth, Environmental Investigation Agency (EIA), European Environmental Bureau (EEB), European Environmental Citizen’s Organisation for Standardisation (ECOS), Greenpeace , Seas At Risk, Surfrider Foundation Europe, and Zero Waste Europe. Together they represent thousands of active groups, supporters and citizens in every EU Member State working towards a future free from plastic pollution. 

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