The impact of post-consumer plastics export ban on Victoria
This Recycling Victoria report was prepared by Blue Environment, September 2022
The Australian Harmonised Export Commodity Classification (AHECC) is the product classification used to identify goods being exported from Australia.
Since July 2021, additional details have become available on the export of unprocessed scrap plastics. The number of AHECC codes relating to scrap plastics has more than doubled from 4 to 9, under chapter 3915 of the AHECC codes. The list of 3915 codes current from 1 July 2021 are available via the Department of Climate Change, Energy, the Environment and Water's website.
These new details allow for a new analysis to be undertaken on the unprocessed single polymer plastics which have been exported over 10 months in the 2020–21 financial year. This also allows for the opportunity to compare these exported quantities to the local reprocessing capacity that is available to process this material from July 2022.
Exporters can still apply for temporary exemptions to export unprocessed single polymer scrap plastics (post July 2022), however these are granted on a case by case basis.
The 3915 codes do not apply to reprocessed plastics that have been transformed into primary forms. This means that recovered single polymer plastics that have been processed into clean flake or pellets are considered primary resins and are exported under the same codes as virgin plastics, which are across chapters 3901–3914 of the AHECC.
This is due to processed recycled polymer often being considered a virgin equivalent, or close to, when properly sorted, cleaned, and flaked or pelletised. However, this change may have the negative impact of hiding data on the international trade of recycled plastics from July 2022, as it is now able to be combined with the trade of virgin plastics.
Table 1 summarises Victorian and national exports from 2021–22 by polymer type and data on committed new reprocessing capacity nationally. The national scrap exports total is available, but not the polymer level splits, so the Victorian polymer export ratios have been used to approximate national exports by polymer type.
Table 1: Exports of unprocessed single polymer scrap plastics in 2021–22.*
| Polymer type | Vic kerbside generation | Vic export (tonnes) | National exports** (tonnes) | New capacity in Australia*** (tonnes) | Capacity shortfall | Comments |
|---|---|---|---|---|---|---|
PET (1) | 18,000 | 15,900 | 57,500 | ~80,000 | None | Some new capacity won’t be in operation until late 2023. |
HDPE (2) | 22,000 | 10,600 | 38,300 | ~30,000 | Probably minimal | Some new capacity won’t be in operation until late 2023. This HDPE is not all kerbside material, however the kerbside versus non-kerbside split is unknown. |
PVC (3) | 0 | 0 | 0 | 0 | Phase-out | Negligible exports. |
LDPE (4) | ~0 | 18,400 | 66,500 | <30,000 | Large | This is C&I material, not kerbside. Capacity estimate is uncertain. |
PP (5) | 17,000 | 400 | 1,400 | ~20,000 | Probably minimal | Some new capacity won’t be in operation until late 2023. |
PS (6) | 3,000 | 200 | 700 | 0 | Phase-out | Negligible exports. |
Total | 60,000 | 45,600 | 164,900 | ~160,000 | - |
Source: ABS and IndustryEdge (2022) and Blue Environment.
* Data is for July 2021 to April 2022 (10 months), scaled to 12 months.
** National scrap export total split using Victorian polymer ratios.
*** New capacity data drawn from Table 3 In Plastics Report. Rough approximations only.
PET
There appears to be plenty of new capacity in the pipeline to absorb the PET exported in 2021–22. In addition, the new capacity will target rigid PET packaging that is currently not recycled locally or overseas, and likely growth in rigid PET packaging use.
HDPE
New capacity for HDPE packaging recycling is consistent with current exports. It is also likely that existing capacity will be able to be expanded to reprocess more rigid HDPE packaging, which is highly sought after.
PVC
Minimal exports and no new planned reprocessing capacity identified. Phaseout in the use of rigid plastic packaging is progressing.
LDPE
LDPE film exports, which are entirely film from C&I sources, for example pallet wrap, are large and the identified new reprocessing capacity appears to be significantly less than exports.
PP
Exports are minimal as a sorted single polymer bale and there is plenty of planned new capacity that will target PP from both rigid packaging and non-packaging PP products.
Significant growth in the use of rigid PP packaging is likely as PVC and PS use is phased out, and through general growth in the use of rigid PP packaging.
The new capacity is, in part, targeting the sorted PP streams which are being generated by an increasing number of MRFs. It is a relatively new development that MRFs are moving towards positively sorting a single polymer PP stream.
PS
Minimal exports and no new planned reprocessing capacity identified. Phaseout in the use of rigid plastic packaging is progressing.
Summary
In summary, after 2023 there does not appear to be an ongoing exposure to the upcoming unprocessed single polymer export bans for rigid packaging from kerbside sources. However, LDPE film from C&I sources does appear to have a local reprocessing shortfall for the foreseeable future. Although local reprocessors may pivot to reprocessing this internationally sought after material sufficiently to avoid the export bans, it will take time.
There is a delay between the export bans and the availability of all the new kerbside PET, HDPE and PP reprocessing capacity. This may lead to the increased stockpiling of these unprocessed bales until the reprocessing capacity is available unless temporary export exemptions are granted.
The future of kerbside recycling
This Recycling Victoria report was prepared by Sustainable Resource Use, September 2022
Kerbside recycling is the central pillar of Australia’s recycling effort. Each year more than 2 million tonnes nationally are diverted from waste through this recycling pathway. Many changes have occurred since kerbside recycling was introduced. These changes encompass system operation, types of products plus range and ratio of materials produced by households. As technology, packaging and behaviour continues to change, kerbside systems will need to evolve to remain effective.
Over time, the kerbside service has been upgraded and extended from using a recycling bag plus tied and bundled paper, to recycling crates into a multiple bin collection.
The range of products collected has also changed. Steel packaging has been added and rigid plastic containers extended from individual polymers to all rigid plastic packaging. Alongside mixed recycling, food and garden organics, kerbside recycling has expanded diversion options. Most recently, a separate glass recycling bin has been introduced successfully in some areas and is set for wider rollout.
The range and ratio of materials generated by households has also been changing and kerbside systems need to evolve to reflect this in order to stay relevant and effective. Over the past 2 decades products such as newspapers and magazines have declined, and phone books have disappeared. Over this same period, the forms of packaging have changed markedly.
Rigid plastic packaging is now very common across many product lines and is largely limited to PET/HDPE/PP. We anticipate the full elimination of PVC/PS from consumer packaging soon.
The biggest change in packaging has been the surge in soft (flexible) plastic packaging. Dominated by PE and PP, the total quantity of soft plastics is now over 400,000 tonnes nationally. With a very low recycling rate, an increasing focus is on incorporating this material into kerbside mixed recycling. To align with the function of MRFs, consumers would be required to present soft plastics in a bag as occurs with supermarket drop off and kerbside trials.
Kerbside systems also need to focus on the growing quantity of packaging material from increased online sales. Fibre based online packaging should be readily incorporated into existing collection systems. Degradable plastic options are problematic to overall plastic recycling. The uncertain markets outcomes for liquid paperboard cartons remain unresolved.
Alongside soft plastics, a further product addition to kerbside collection could be plant pots. Almost entirely PP and with a strong local recycling market, kerbside collections could be a method to aggregate the 8,000 tonnes that is spread across households.
All recycling systems work best if structured to be:
- clear – what can I recycle and what I cannot
- consistent – the same approach wherever I live
- convenient – it is as easy to recycle as not.
A key component of this is support systems with regular consumer education, including feedback on what our collective effort is achieving such as carbon reduction. This is particularly crucial in multi-unit developments (MUDs) where it can be more challenging to separate materials. Local recycling innovators, Reground have teamed with local government and site managers to make big gains in delivering success at these sites.
Kerbside recycling will continue to play a big role in waste reduction as it evolves and will lead to a dramatic cutback in residual waste quantity and allow reduction in landfill waste bin sizes and the frequency of collection.
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