EIA Submission to Basel Convention Secretariat – Plastic Waste
Submission by the EIA in response to the Basel Convention Secretariat’s request for comments on the plastic waste amendments and possible further activities that could be conducted on plastic waste.
The Environmental Investigation Agency (EIA) welcomes the opportunity to contribute to the Basel Convention’s consideration of further action on the transboundary movement and management of plastic waste.
EIA is a non-governmental organisation with more than 40 years of experience investigating environmental crime and supporting effective policy development and implementation at international, regional and national levels, including the Basel Convention and the European Union (EU) Waste Shipment Regulation (WSR).
For years, EIA’s work has uncovered systemic weaknesses in global waste governance, documenting how loopholes, misclassification and poor enforcement enable harmful and illegal waste trade. Drawing on our investigations, we have developed significant expertise in the review and interpretation of customs data, shipping records and field evidence to identify patterns of misdeclaration, regulatory avoidance and enforcement gaps.
The 2019 plastic waste amendments to the Basel Convention marked a vital first step toward bringing the majority of plastic waste under internationally agreed control mechanisms by expanding Annex II (Y48), Annex VIII (A3210) and Annex IX (B3011). These changes were intended to enhance transparency, ensure prior informed consent (PIC) for difficult-to-recycle streams and close longstanding avenues for waste dumping.
However, implementation experience, enforcement data and recent global modelling demonstrate that significant structural loopholes remain. Annual primary plastic production is projected to rise by 52 per cent from 450 Mt in 2025 to 680 Mt in 2040, while waste management capacity expands far more slowly, with annual costs to collect and dispose of plastic projected to rise by 30 per cent to approximately $140 billion, increasing fiscal pressure on governments and financial risk for businesses.
These projections reaffirm that existing controls are insufficient and underscore the need to fully utilise, clarify and strengthen the Convention’s legal architecture to address contemporary realities of plastic waste.