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(Washington, DC) – The Institute of Scrap Recycling Industries (ISRI) submitted comments to the Office of the U.S. Trade Representative (USTR) for inclusion in the annual China World Trade Organization (WTO) Compliance report.

While ReMA is appreciative to the USTR for their comprehensive overviews in the annual report of the major trade barriers affecting the recycling industry, the comments submitted this week express concern as China has failed to notify the WTO of rounds of import bans, overly-strict product standards, challenging licensing requirements and non-transparent quota issuances. 

Excerpts from ReMA comments are as follows (full text of comments):

… China has been phasing in prohibitions and non-tariff restrictions on imports of scrap materials since 2018 (which the Chinese Government inexpertly lumps in with other non-value waste streams and ambiguously refers to all of it as “solid waste”). The first set of prohibitions implemented in early 2018 had been notified to the WTO, but subsequent rounds of import bans, overly-strict product standards, challenging licensing requirements and non-transparent quota issuances were not notified. Furthermore, it is our general understanding that the Chinese Government intends to ban all “solid waste” by 2021, but there has been no transparency on such a policy, leading to great uncertainty in the marketplace. …

… Since 2017, there has been general talk in the marketplace about the possibility of the Chinese Government implementing a blanket import ban on all “solid waste” (including scrap commodities) by 2021. However, no official law or regulation has been developed, discussed or implemented to fulfill this intention, and instead, we have seen non-tariff barriers applied to imports of scrap commodities that have impacted trade in scrap commodities with China. …

… Recognizing that Chinese manufacturers are still in great need of these materials, the Chinese Government announced in early 2020 the intent to implement a new set of standards on imports of aluminum, brass and copper “recycled raw materials.” What makes these standards distinct from the overly strict standards on “solid waste” and scrap that were implemented in 2018 is that material entering the Chinese market under the new “recycled raw materials” standards would be in a form that is immediately ready for the smelter. This is the first major indication – after many years of advocacy by ReMA and our members – that the Chinese Government understands that scrap is not waste but valuable raw material inputs for manufacturing. …

… ISRI is grateful for all the hard work and sustained advocacy by the Office of the U.S. Trade Representative, the U.S. Department of Commerce and the U.S. Department of State at the WTO and in bilateral engagements with the Chinese Government. We have not found the Chinese Government to be receptive to dialogue on these measures, as we are sure members of the Trade Policy Staff Committee have encountered. But we support the use of the WTO Compliance report as an avenue to keep legislators and the public informed of the health of U.S. industries impacted by Chinese Government trade policy actions. …

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