Published by Global Initiative (Against Transnational Organized Crime)
NOVEMBER 2021
The report was made possible with funding provided by the government of Norway.

Table of Contents

Plastic for profit: Tracing illicit plastic waste flows, supply chains and actors
To achieve a Net-Zero future, it is essential – among other interventions – to manage and control the indiscriminate use of plastic and the way it is disposed of once it becomes waste. Confronting the trade in plastic waste is also an issue of climate justice, as the by-products aggravate health and environmental harms in lower-income countries and among communities that lack the political leverage to reject this waste.

1. Executive Summary

• Now, South East Asia has become by far the largest recipient of waste from Europe and North America as well as from Australia.
• In addition, the role of African countries as receiving destinations is growing for both the North American and European waste trade.
• Plastic waste, that once processed, becomes raw material to be sold to manufacturing companies. However, many of these receiving countries only possess basic recycling facilities and therefore are unable to process mixed or hazardous waste, which is eventually dumped or burnt.
• The populations of developing and emerging economies in Africa and Asia are the most affected, and workers in those countries have to contend with unsanitary and exploitative working conditions in sorting and recycling plants.
• Legitimate recycling companies and waste brokers have engaged in the misdeclaration of the content of containers and their origin; the concealment of illicit waste among other goods; illegal dumping and incineration; and money
  laundering and corruption to circumvent import and export bans and regulations.
• Often with stops in other parts of the world such as Turkey or eastern Europe.
• Although many European countries have advanced recycling facilities, they cannot handle all of the waste produced domestically.

2. WASTE COLONIALISM AND EXPLOITATION

However, like all other highly lucrative businesses, waste management has long attracted the attention of criminals and of legitimate business operators adopting fraudulent practices such as misdeclaring the content of containers, money laundering, financial crime and corruption to maximize their profits.

The impact of the COVID-19 pandemic

• The COVID-19 pandemic has prompted a sharp rise in the consumption of single-use plastic, from medical equipment to takeaway food packaging, which has not been matched by increased recycling capacity.
• In 2020, the US produced a year’s worth of plastic waste in just two months. And in Thailand, generation of plastic waste jumped by 50% following the outbreak, with food-delivery packaging representing a sizeable share.
• Meanwhile, as the pandemic took hold, the recycling sector was affected by disruptions, staff shortages and a deprioritization of recycling.
• The world registered a 280% increase in illegal plastic-waste disposal in 2020. UK seeing a 300% increase in so-called fly-tipping (illegal dumping)

3. LEGAL FRAMEWORK

Two types of illegal activities related to waste: illegal trade,
which violates import or export bans; and illegal treatment, in the forms of illegal disposal, incineration or recycling.

International conventions

• The Basel Convention was adopted in 1989 in response to developing regions being used as dumping grounds for foreign waste in the 1980s.
• To date, 187 countries and the European Union (EU) are parties to it; notably, the US is not among them.
• European Commission adopted a new set of rules in December 2020. EU countries can now only export to non-OECD destinations ‘clean plastic waste’ for recycling and are banned from shipping hazardous or hard-to-recycle plastic waste to non-OECD countries.
• Export activities considered illegal in Europe are compliant with US legislation.

Illegal traffic under the Basel Convention

China’s ‘National Sword’ policy

As a result of the ban, countries such as Malaysia, Indonesia and the Philippines, along with many others, became the new recycling destinations for most North American and European plastic waste, despite the fact they often lacked adequate disposal facilities and sufficient law enforcement capacity.

Other national-level bans and the trend in U-turns

For example, in July 2021, largely compelled by a Greenpeace investigation that uncovered that most imported plastic waste was not recycled, Turkey introduced a ban on the imports of PET, HDPE and LDPE plastics. However, in less than two weeks, PET was removed from the list of banned imports. The move was symptomatic of the tensions between the country’s ministry of environment wanting a total ban and the ministry of trade advocating for openness, and is the by-product of the narrative that, at times of financial crisis, waste management and processing are needed to generate revenue.

In Thailand, plans to ban imports of plastic waste by September 2020 were postponed by five years, with critics arguing that this was aimed at securing a steady flow of waste needed to feed Thailand’s recycling industry, driven by an ever-growing number of Chinese companies.

Following a 2019 ban on all waste imports, Indonesia also softened its stance. The year after, the government allowed the imports of plastic (and paper) waste with contamination levels of up to 2%. This particular case highlights the role of one particular set of actors: trade associations. The US Institute of Scrap Recycling Industries (ISRI) openly lobbied for the continuation of imports of a number of waste materials.

If these requests are met, Kenya – which has the strictest ban on single-use plastics in the world34 – could become the main hub for the distribution of US-made plastic in the continent.

4. HUMAN AND ENVIRONMENTAL HARM

• Much of the waste that is exported for recycling to South East Asia is often burned or dumped.
• The degree to which the illicit trade in plastic waste severely undermines both the natural environment and human health and safety is alarming.
• All this waste eventually feeds the five infamous garbage patches that float in our oceans, of which the so-called Great Pacific Garbage Patch is the largest.
• Aside from dumping, it has become common practice to burn illicit waste as a method of disposal in Indonesia or Malaysia, causing air pollution, respiratory problems, and food health problems (ashes).

Burning is also used as a method of illicit waste disposal in some European countries such as Italy and the UK, as well as in Turkey. In October 2021, Italian authorities arrested the owners of a recycling plant who, in 2017, set ablaze tonnes of mixed hazardous waste as a way of clearing their premises at no cost.

In Turkey, an average of two suspicious incinerations per week take place at recycling plants.

The exploitation of vulnerable workers has also been documented in Indonesia, where some companies systematically employ women to sort waste (with no concerns for any resulting health problems).

Ghana’s Environmental Protection Agency told the GI-TOC that most recycling facilities in the country (primarily owned by Chinese entrepreneurs) have unsanitary working conditions. A similar picture emerged in Zambia, where Chinese companies appear to underpay their workers.

In Indonesia and the Philippines, waste pickers and workers in collection and aggregation facilities generally do not have formal employment contracts with the owners of the facilities and thus lack access to basic benefits, training and protections vital to their safety. Most waste pickers also do not have identification documents, a prerequisite for accessing government health-insurance schemes.

THE GREAT PACIFIC GARBAGE PATCH

46% of the total mass is made of discarded fishing gear.

5. TRACING THE FLOWS

• Illicit plastic waste is transported around the world along multiple routes from North America and Europe to South East Asia, other parts of Asia and Africa.
• Turkey has become a key node for the trade in European plastic waste owing to its permissive environment, an appetite for receiving and processing foreign waste to generate revenue and the presence of criminal groups.
• Underlying drivers：1. the US and the EU simply do not have sufficient capacity to recycle domestically；2. The cost of exporting waste abroad is dramatically lower than the cost of setting up new facilities.
• More compelling economic consideration is that producing virgin plastic is often more affordable than its recycled equivalent. (the global plastics-recycling market is going to struggle to be competitive in the face of cheaper and often better-quality raw plastic.)

Crucially, the shale gas boom in the US is driving the cheap production of fossil fuels, including gases such as ethylene and propylene, which are the two most important plastic feedstocks.

• Where next? Eastern Europe (specifically Romania and Bulgaria) could be a potential destination. Laos or Myanmar, where there have already been some detections, should be ones to watch. Looking further into the future, flows towards African countries (Zambia) are likely to increase.

According to Romanian authorities, organized crime groups are involved in the illicit trade of hazardous and unrecyclable plastics. Poland also receives waste from EU countries and the UK that is misdeclared as ‘recyclable’ (already sorted plastic that is, in fact, mixed with banned waste) and ends up being illegally dumped or burnt.

The in-betweens

Origin	Destination	Transit	Notes
Canada	Indonesia		Indonesia has returned waste to Canada
Canada	Malaysia		Butterworth, Canada’s second-largest port, has been identified as a main departure hub for illegal plastic waste from the country to South East Asia. Malaysia has been returning illegal waste to Canada.
Canada	The Philippines		The illegal shipping of plastic waste from Canada to the Philippines has long been a source of diplomatic tensions between the two countries, including around the repatriation of unwanted cargo and responsibility for covering associated costs.
United States	India	Indonesia	India has been used as an alternative destination for unwanted US waste that Indonesia intended to return to origin.
United States	Indonesia	Hong Kong	Despite the lack of official data, it is believed that ‘lots’ of US plastic is illicitly shipped to Indonesia and, starting in 2019, the latter has become more vocal with its complaints and determined to repatriate unwanted waste.70 Large amounts of re-exported waste are diverted to third countries.
United States	Malaysia	Hong Kong	There is no official comprehensive US data recording the new destinations of US plastic waste following the introduction of the Chinese ban.72 However, the state of California accounts for nearly a third of all US exports to non-OECD countries and this is the main origin of illicit waste into Malaysia (which became number one destination after the introduction of the import ban in China).
United States	Thailand		Thailand saw the largest increase of imports immediately following the introduction of China’s import ban. 90% of plastics transit through the deep-water port of Laem Chabang.
United States	The Philippines		In the post-National Sword era, exports to the Philippines grew exponentially, especially from Japan and the US.
United States	Cambodia		Multiple seizures of illegal plastic waste were recorded at Sihanoukville port in 2019. A Cambodia-based Chinese company was deemed responsible for importing the cargoes from the US and Canada.
Canada, United States, Europe	Ghana		The ports of Tema and Accra and the inland city of Kumasi are hubs for illicit plastic waste. Ghana has long been a recipient of e-waste and there are suspicions that illicit plastic waste is exported to Ghana mixed with e-waste.77
North America, Europe	Pakistan		Pakistan is a net importer as local plastic production is limited to meeting national demand. It has become common for shipments to South East Asian countries to be redirected to Pakistan.
Europe	Myanmar		Most plastic waste arrives at Yangon port. Myanmar then exports mainly PET flakes and some HDPE/PP resins to neighbouring countries. Recycled HDPE and PP are mainly consumed locally.
Belgium	Malaysia	Hong Kong	Reports indicate the shipping of illegal waste from Belgium to Malaysia that had been disguised as exports from Hong Kong, a widely used transit hub.
France	Malaysia		The shipping of illicit plastic waste to Malaysia came to the fore when a French brokerage firm received a heavy fine – the first instance of this kind in France.
Germany	Turkey	Belgium	As of June 2021, over 100 illicit containers that had reached Turkey from Germany via the port of Antwerp were sitting in Turkey waiting to be sent back to Germany. They contained mixed waste contaminated with household waste.
Italy	Malaysia		The Italy–Kuala Lumpur (/ˌkwɑːləˈlʊmpʊə吉隆坡)route is believed to be a significant route for illegal shipping of waste. Companies are believed to rely on Hong Kong-based agents who would, on paper, broker shipments to Hong Kong when, in reality, illegal plastic waste would arrive directly in Malaysia.
Italy	Tunisia		Italy’s Campania region has been identified as the point of origin of hundreds of containers full of mixed municipal waste that were directed to the Port of Sousse in Tunisia in 2020.8
Spain	Malaysia		Malaysia has repatriated illegal waste back to Spain, Japan and Singapore.
Spain	South Africa		Disposal sites in KwaZulu-Natal and Cape Town are the most affected by illicit plastic waste.
United Kingdom	Malaysia	Turkey	Turkey (39%) and Malaysia (12%) are the top two destinations for illicit plastic waste from the UK. Both have limited capacity to recycle, and illegal dumping and burning are widespread.
United Kingdom	Malaysia	The Netherlands	UK-origin plastic waste is sent for recycling to the Netherlands, where it is instead mixed with Dutch waste and then shipped to countries that no longer accept British plastic. As of 2021, evidence shows continued shipping from Dutch ports to non-OECD countries.
United Kingdom	Poland		Poland is the third-largest recipient of illicit plastic waste from the UK.
United Kingdom	South Africa		South Africa has witnessed the illegal dumping of containers full of unlawful plastic waste from the UK, Spain and other European countries.
United Kingdom	Turkey		The Cilicia region of , from the Mediterranean to the Syrian border, is the main entry point for plastic waste and a highly polluted area.
Mozambique	South Africa		Truckloads of plastic mixed with e-waste enter South Africa and are suspected to then be shipped abroad.
South Africa	Portugal, Italy, Malaysia, Hong Kong and Pakistan		South Africa is both an importer and exporter of illegal plastic waste. Multiple shipments to international destinations have been recorded in 2020 and 2021.
Japan, Singapore	Malaysia		Malaysia has repatriated illegal waste back to Spain, Japan and Singapore.
Japan	The Philippines		Japan has a history of shipping toxic and hazardous waste to the Philippines, but Tokyo’s repatriation of waste containers has won it praise from the Filipino government.
South Korea	The Philippines		Investigations by Greenpeace identified large amounts of mixed and hazardous waste (declared as plastic synthetic flakes) that had reached the Philippines from South Korea. A Korean company was the consignee of the shipment.
Australia	Indonesia, Malaysia, Vietnam		Post 2017, Australian plastic waste was redirected to Vietnam, Malaysia and Indonesia. Indonesia’s East Java province has received millions of kilograms of illegal plastic and contaminated mixed waste
Unknown	Indonesia	Marshall Islands	Masked as the country of origin of illegal plastic waste, the Marshall Islands are believed to be used as transit countries for waste coming from Western countries. Owing to this misdeclaration of origin, in 2018 it appeared that Indonesia was importing double the amount of plastic waste from the Marshall Islands than it was from the US.
Unknown	Indonesia, Malaysia, the Philippines	Hong Kong	All three destination countries have speculated that illicit plastic waste arriving from Hong Kong had actually originated elsewhere.

6. METHODS AND ACTORS ALONG THE SUPPLY CHAIN

Actors: waste producers (both local authorities and businesses) and commercial actors (such as recycling companies and waste brokers).

• Broker: Arranging banned waste products to be sent to, and disposed of, in countries that do not have the ability to process such waste, and they play a role in misdeclaring the destination of shipments.
• Shipping and logistic companies: Transporting containers along maritime routes, which constitute the largest method of transport for waste.
• Customs authorities at ports: Corruption; lack the necessary training to identify different types of plastic (Zambia)

Misdeclaration: 1. Mislabelling to be compliant with the Basel Convention (disguising imports under a different customs code as customs officers can only inspect a fraction of containers going through ports each day); 2. Recycling companies sometimes misdeclare their operating capacity, inflating their ability to recycle plastic waste in order to be allowed to import it (Malaysia and Vietnam).

Concealment: Hiding plastic waste in the middle of other waste products such as paper and e-waste that are not subject to the same level of scrutiny (legal loophole).

• Recycling and other companies: Chinese companies found new homes in Indonesia, Malaysia, Ghana (lacked adequate machinery for recycling which raises suspicion that waste would be dumped in the country) and Zambia (competition among the ever-growing companies is fierce, which increases the prices of plastic waste)

![image](https://user-images.githubusercontent.com/65668613/152691379-274ca41c-0250-4f42-ac47-91c8a411f7a6.png

Eastern Europe as the next tile to fall in the domino effect of the ‘National Sword’ policy.

• The ‘professional’ criminals: Turkey and eastern Europe.

7. CONCLUSIONS AND RECOMMENDATION

Legitimate business operators and organized crime groups alike can be expected to continue their illicit practices to maximize revenues.

• the traditional cat-and-mouse dynamic as enforcement tightens its grip, criminals look for new ways and places to carry out their activities.

1. Create a networked or taskforce approach to effectively tackle this form
   of criminality and associated risks at the national and international level.

• A national multi-agency group in UK– the Joint Unit for Waste Crime – to tackle the threat of organized crime within the waste industry.
• INTERPOL’s Environmental Security Unit and the Pollution Crime Working Group.

2. Support the private sector and build international capacity to work with
   relevant private-sector groups.
3. Improve digitalization of waste collection and management.
4. Collaborate with non-governmental actors.