We would like to thank the Taiwanese government for its continued engagement with our Committee over issues of concern. We look forward to seeing these efforts bear fruit soon.

Given the scale and the importance of Taiwan’s retail and electronics industries, the Committee would especially like to focus on addressing their recycling needs. In this regard, we wish to promote more usage of recycled materials as well as more R&D on biodegradable products. Such efforts would boost the government’s circular economy plan, part of the “5+2 Innovative Industries” program aimed at encouraging the re-use – rather than mere disposal – of waste materials.

We also encourage the government to implement carbon reduction strategies and enforce other carbon-tax-related regulations to make Taiwan’s greenhouse-gas reduction efforts clear to the world.

Suggestion 1. Implement carbon reduction strategies and enforce carbon tax and other related regulations.

We recommend that the Taiwanese government put a price/value on carbon emissions to incentivize businesses and consumers to adopt more energy-efficient practices and reduce their carbon emissions. Some Asian countries have already taken actions in this regard, including South Korea, Japan, and Singapore. Imposition of a carbon tax can be a critical tool to accelerate the deployment of low-carbon technologies, products, services, and infrastructure, as well as to promote the green energy market. We strongly urge the government to implement carbon reduction strategies and enforce other carbon-tax-related regulations.

Suggestion 2: Expand the scope of usage of recycled materials.

Under Article 2 of the Sanitation Standard for Utensils, Containers, and Packages, plastic food containers and packages are not allowed to be “reused.” Unlike the sanitation and food safety hazards posed when plastic food containers are “reused,” the hazards are substantially eliminated and controllable when the plastic containers are “re-manufactured.” In the interest of sustainability and given the plastic recycling methods now available, we therefore suggest that the Taiwan Food and Drug Administration (TFDA) should start conducting a risk-assessment study and explore the related feasibility of manufacturing plastic food containers using recycled plastic materials.

In the U.S., the Food and Drug Administration (FDA) considers each proposed use of recycled plastic on a case-by-case basis and issues advice as to whether the recycling process can be expected to produce plastic suitable for food-contact applications. The U.S. FDA also has prepared a document with guidance for industry on the use of recycled plastics in food packaging.

We urge the TFDA to adopt regulations that set proper standards and review processes such as “bottle-to-bottle” to allow recycled plastic materials to be used to produce food containers.

Suggestion 3: Better promote the circular economy by encouraging R&D on biodegradable products and enhancing the recycling process.

From the beginning of 2020, the Taiwan Environmental Protection Administration (TEPA) has implemented a series of restrictions on the use of disposable containers and utensils made from all types of material. The policy was made with the good intention of reducing the volume of waste, but it did not foresee the consequences for other sustainability issues such as increased water usage and energy consumption. While most countries prohibit only the use of “plastics” but encourage the use of alternative decomposable materials, Taiwan goes further by imposing a more comprehensive ban.

In fact, materials used to make disposable utensils can still be environmentally friendly, including some resources usually discarded as waste (such as cane bagasse, which can be used to make drinking straws and recycled materials). New technologies and the use of biodegradable materials can significantly decrease the harm to the environment without sacrificing convenience or harming public health.

Besides, the use of biodegradable materials also brings business opportunities and economic benefits, especially if local industries are motivated to develop eco-friendly products not only for the domestic market but also to cater to the growing global market demand for sustainable products. This objective supports the Taiwan government’s goal of creating a circular economy as one of the key national development strategies for promoting industrial upgrading and innovation.

Therefore, instead of banning the use of all disposable food containers and utensils, the government should encourage the use of – and research and development on –biodegradable products. It should also strengthen the current recycling process to enable more recyclable materials to get into the sustainable cycle and create real economic value.

Suggestion 4: Provide more incentives for private-sector use of high-quality recycled building materials.

Since 2017 when the Committee first raised this issue in the White Paper, we have appreciated the Taiwanese government’s efforts to promote the use of recycled building materials in the public sector. While we applaud the progress made, we believe more can be done by providing additional incentives to the private sector. For example, a higher building capacity ratio could be granted to developers who use high-quality recycled building materials.

By “high quality,” we mean building materials made not from the likes of furnace slag, but better-quality materials recycled from products such as solar panels, printed circuit boards, and filters used in semiconductor manufacturing. The goal is to recycle materials used by the green energy and electronic industries that are key to the future of the Taiwanese economy, while also contributing to the government’s circular-economy initiatives.