ASBG prepared a submission on the Council of Australian Government’s (COAG) Consultation Regulation Impact Statement Phasing out certain waste exports (RIS). This is the second submission and one that focus on the RIS document.
ASBG considers the RIS is non-compliant with COAG's Best Practice Regulation: A Guide for Ministerial Councils and National Standard Setting Bodies. Specifically this consultation RIS provides no economic nor risk assessment which can be reviewed nor does it show how the Waste Export Ban benefits Australia. Consequently, ASBG recommends an economic and risk assessment be undertaken and the RIS redone with public consultation.
ASBG identified costs associated with WEB placed on paper exports which resulted in a net loss of $275 million p.a. Australia simply does not have the paper recycling mills to accept many paper and cardboard types which can only be served by overseas mills. Also Australia has neither the supply nor the required approximately $1b CAPX to build specialised paper mills which can operate commercially selling its excess into the export market. Note Australia simply does not have the manufacturing base to absorb the quantities of recyclates which a large proportion is sourced from our imports.
ASBG recommends a third option be included in the RIS: Use a gate keeper (Basel Convention) approach to screen recyclates for export. This should cover the issue of prevention of environmental and health harm caused by exported Australian recyclates. This additional option should be included in the redo of the RIS.
 ASBG's Submission on the Waste Export Ban RIS 2020 | 1082 kB |
