Waste plastic export licence applications

Evidence to provide with your application

• Information about how your importers intend to use the processed plastic overseas, including:
  • if the importer will remanufacture the plastic into pellets or into new products
  • the specific products the plastic will be manufactured into (if known), or the types of products the plastic is suitable for.
• If your importer is a trader – information about who they sell to and how their buyers use the plastic.

Understanding the criteria

The intended use is the end-use of the plastic. If the plastic is versatile, such as PET and HDPE, you can describe the intended use broadly. For example:

• Manufacturing into consumer products and packaging (for example, picture frames, toys, consumer packaging).
• Manufacturing into food-grade packaging.
• Manufacturing into industrial products (for example, pipes, drums, automotive parts).

Some plastic is only suitable for limited applications. In this case, you may need to describe the intended use in more detail. For example:

• Manufacturing into picture frames and decorative mouldings.
• Manufacturing into car bumper bars.

Some importers remanufacture the plastic into pellets to sell to plastic manufacturers. In these cases, you must outline the types of products they are suitable for.

Evidence to provide with your application

• A copy of your specification (unless you nominate a listed specification). It must include the details we are required to consider. 
  A plastic specification template is available: Plastic specification template (DOCX 113 KB)
• Information about the source of your plastic waste. For example, post-consumer kerbside waste, unused manufacturing rejects or leftovers.

Understanding the criteria

A ‘specification’ is a written industry specification or standard under the Plastic Rules. It relates to the manufacture, processing or supply of waste plastic.

A specification needs to include certain fundamental details about your waste plastic (set out in the Plastic Specification template). However, it does not need to include all the details of your waste plastic that you may negotiate with your importers from time to time.

Listed specifications

You can nominate one of the following ‘listed’ specifications. These are specifications the agency has already determined appropriate for use:

• APCO – Natural HDPE flake for food grade applications - V2.0 (DOCX)
• APCO – Coloured HDPE flake - V2.0 (DOCX)
• APCO – PET hot washed flake - V2.0 (DOCX)
• APCO – Coloured PET cold washed flake - V2.0 (DOCX)
• APCO – Cold washed coloured recycled PP flake - V2.0 (DOCX)
• Expanded Polystyrene Australia – Export Densified EPS: Model Specifications (PDF).

Unlisted specifications

You can also nominate your own specification. It must include the following details of your processed plastic:

• single polymer or resin type
• contaminant thresholds
• physical form of the processed plastic
• any colour requirements, if you wish to specify this
• any packaging requirements, if you wish to specify this.

Applications that nominate listed specifications are usually quicker to assess.

Single polymer or resin

If your plastic is not a single polymer or resin, you may require an export permit instead of a waste export licence. This is under the Hazardous Waste (Regulation of Exports and Imports) Act 1989 (the Hazardous Waste Act).

Polymers

Polymers are compounds made of:

• chains of repeating molecular units (monomers), or
• several different monomers.

The term ‘single polymer’ covers:

• homopolymers, which are chains of a single type of repeating monomer
• copolymers, which are chains of more than one type of repeating monomer.

Plastics that are not considered to be single polymers include:

• polymer blends, which are plastics that are a mixture of multiple homopolymers or copolymers
• multilayer plastics, which comprise fused layers of different polymers.

Plastics are typically embossed with the globally-used polymer identification codes (PDF). These group plastics into 7 categories:

• numbers 1 to 6 relate to individual polymers (PET, HDPE, PVC, LDPE / LLDPE, PP and PS)
• number 7 is a catch-all ‘Other’ category that covers multiple polymers.

Resins

Resins are cured plastics which cannot be melted and reshaped. They are also referred to as thermosetting plastics and can be used to make adhesives and coatings as well as moulded products. Examples include phenol formaldehyde and epoxy resins.

The term ‘resin’ is also sometimes used by industry to refer to plastic that is in the form of a pellet. This is not the meaning of the term as it is used in the Plastic Rules.

Contaminants

If your waste plastic is not almost free of contamination, you may require an export permit instead of a waste export licence. This is under the Hazardous Waste Act.

Contamination generally means material that can be mechanically or chemically removed via sorting and cleaning. Common contaminants are other plastics, labels, dirt, metal, wood, food, and other residues.

Substances that are not contaminants include:

• moisture
• those inherent in the waste plastic, such as dyes, plasticisers and stabilisers.

However, certain substances, such as brominated flame retardants, may be controlled under the Hazardous Waste Act. In these cases, a hazardous waste export permit is required rather than a waste export licence.

There may be other export controls that restrict how much moisture can be present in a consignment at export.

Almost free of contamination

There is no universal standard for ‘almost free from contamination’. The department assesses each nominated specification in its context. For example:

• National and international specifications can provide an indication of acceptable levels of acceptable levels of contamination.
• Generally, total contamination of up to 2% is likely to be considered almost free of contamination. There will be circumstances where higher or lower thresholds are appropriate.
• For polyolefin polymers (PP and PE), up to 5% polyolefin contamination may be acceptable because:
  • polyolefin polymers have similar properties
  • higher levels of polyolefin contamination can be present without degrading the quality and performance of the recycled plastic.

Importing countries may set their own thresholds for what they consider to be almost free from contamination. You should check this with your importers.

Form

Form refers to the shape, dimensions and in some cases the density of processed plastic. Examples include:

• for rigid plastics – flake, typically measuring between 8mm and 20mm
• for flexible plastics – shred, typically measuring between 20mm and 100mm
• for expanded plastics – compressed blocks, bricks or ingots of varying densities and sizes.

Evidence to provide with your application

Information about how your importer remanufactures your plastic. This includes any further processing steps the plastic is put through, such as:

• sorting
• cleaning
• downsizing.

Understanding the criteria

Remanufacture

Remanufacture includes remanufacture into forms for further manufacturing. For example, pellets used in place of virgin plastic in the manufacture of new plastic products.

Further processing

Processing refers to the steps that waste plastic goes through so it can be made into pellets or new products. The level of processing required depends on the source of the plastic. For example:

• post-consumer kerbside waste contaminated with residues and other types of wastes, or
• clean manufacturing off-cuts.

It will usually involve:

• sorting to remove other types of plastic and wastes,
• cleaning to remove residues and labels, and
• changing the form, such as by cutting it into small pieces or compressing it into blocks.

Evidence to provide with your application

• Information about how the waste plastic is processed to meet the specifications, including details of:
  • each processing step – for example, sorting, cleaning and downsizing
  • equipment used – for example, optical sorters, magnetic separators, wash plants, float/sink tanks, driers, shredders, granulators and extruders
  • quality assurance processes to ensure the plastic meets your specifications – for example, routine testing, auditing or inspections.
• Photographs of the equipment and the plastic before, during and after processing.
• If your plastic comes from comingled recycling or any other post-consumer source – test or audit results showing that the processed plastic is a single polymer and meets the specification’s contamination thresholds.

Understanding the criteria

Processing

The type of processing required generally depends on the condition (used or unused) and source (mixed or single stream) of the waste. The following table summarises the typical processing required according to the condition and source of waste plastic:

Condition	Source	Processing steps
Used	Mixed stream (e.g. kerbside)	Sorting (manual / optical / density) Washing and drying Size reduction (shredding / cutting / grinding)
	Single stream (e.g. container deposit scheme (CDS))	Washing and drying Size reduction (shredding / cutting / grinding)
Unused (e.g. manufacturing offcuts)	Mixed stream	Sorting (manual / optical / density) Size reduction (shredding / cutting / grinding)
	Single stream	Size reduction (shredding / cutting / grinding)

Evidence to provide with your application

• Evidence of an existing or potential relationship with your importers. in relation to purchasing processed waste plastic. This could be:
  • correspondence
  • a purchase order
  • a sales contract.
• If you don’t process the waste plastic yourself – evidence of an existing or potential relationship with your supplier in relation to sourcing processed waste plastic. This could be:
  • correspondence
  • a purchase order
  • a sales contract.

Understanding the criteria

Suppliers

Suppliers are only relevant to applicants who do not process the waste themselves. A supplier is an entity that processes your waste to your nominated specification prior to export.

Importers

An importer is the entity responsible for bringing the waste plastic into the importing country. They will generally be the party that you identify as the consignee when declaring exports to Australian Border Force. The importer will usually, but not always, be physically located in the importing country.

Understanding the criteria

Generally, licences will allow you to export to specific countries only. However, in some cases we may consider granting licences that are not limited to specific countries.

The agency grants ‘all country’ licences if you can provide detailed evidence showing how your waste plastic will:

• be processed into flake of a consistent size
• have minimal contamination and high polymer purity
• be suitable for remanufacturing into a range of plastic products.