Letterhead of Hong Kong Waste Management Association

Waste Reduction Framework Plan
Views of the Hong Kong Waste Management Association


The Hong Kong Waste Management Association (HKWMA) comprises waste management professionals, academics, students and interested industry and commerce representatives. Its objectives are centred around furthering the standards and development of effective waste management in the SAR.

The Association is grateful for the opportunity to comment on the Waste Reduction Framework Plan (WRFP). Over 140 members have been asked for their views on the plan.

General View

The Association supports fully the objectives of the WRFP and endorses the view that the true costs of waste management must be identified. Realisation of previously hidden costs will promote the implementation of both improved management and new and economically viable initiatives to reduce wastes for disposal.

The objectives of the WRFP are laudable and must be promoted through the media and constant updates given of the progress of the various initiatives. The plan must have momentum which can be seen by the public and industry at large.

The Association has a number of views relating to some of the detail of the plan which the Administration may care to consider in its further development.

Waste Minimisation

The Association recognises that the achievement of all objectives within the plan will require considerable support from the public, from industry and from commerce. Education of the public and businesses of the financial and environmental costs of waste management and how change must occur, is central to gaining support and thus the outcome of much of the plan. Where possible, the Association is willing to assist the Administration in this challenging task.

However, the early implementation of an equitable charging policy is likely to produce rapid results without the immediate need to change long held views and waste generation practices. Direct financial impact on waste producers is more likely to concentrate efforts to reduce waste arisings as experience in other countries demonstrates. In parallel with other environmental policing requirements (such as enforceable and heavy penalties for littering, smoky vehicles, illegal discharges etc.) legal instruments and enforcement resources must be provided to control illegal dumping effectively.

Assistance to the Waste Recovery Industry

The WRFP included a land allocation policy and the intent to set up material recovery facilities in Hong Kong to boost the recycling rate. Findings of a survey carried out by the Civil & Structural Engineering Department of the Hong Kong Polytechnic University indicate that the major problems confronting the waste recovery industry of Hong Kong were the low value of scrap and high transport cost (Chung & Poon, 1998).

The land allocation policy and the setting up of MRFs can increase processing economies and provide affordable operation space for the industry. However, they do not tackle the major causes leading to the contraction of the industry. In the Draft Waste Reduction Plan, granting of recycling credits was one of the proposed measures. The Hong Kong Polytechnic University survey showed that recycling credits was considered the most useful measure to assist the contracting waste recovery industry of Hong Kong, as it gives immediate financial relief to the waste recoverers. The WRFP does not mention these measures, which are considered key to raising future waste recycling rates in Hong Kong, particularly given the lack of outlets for sorted recyclables.

Reference :

Chung S. S. & Poon, C. S., 1998, "The Waste Recovery Industry of Hong Kong and the Impact of the Legislative and Policy Measure of Hong Kong SAR & Mainland China on This Sector".

In Proc. on Hong Kong - Guangzhou Waste Reduction Workshop, 9 - 11th September, Guangzhou (in Chinese).

Demand Side Measures

In addition to the granting of recycling credits, the waste recovery industry can be revitalised by the use of market mechanisms which increase the demand for local recyclables. The recent closure of one of the major paper waste reprocessors in Hong Kong, Concordia Paper Ltd, is indicative that the major causes of the decline of the recycling industry in Hong Kong is a lack of demand side measures. These measures can be achieved through several means:

    - giving procurement preference to products containing locally sourced recycled materials;

    - by offering financial incentives to industries using local recyclables as feedstock and thus encouraging their establishment in Hong Kong;

    - an cco-labelling system where recycled products, especially those made with local recyclables, can be easily identified by consumers; and

    - changing engineering specifications to allow utilisation of civil engineering products made from or including recycled materials.


The WRFP presents a number of facts relating to the composting of organic wastes. The Shaling plant processes unmixed livestock manure only, the resulting fertiliser being sold to landscape contractors. There is a limited market for this product in Hong Kong.

However, as previous Hong Kong experience has demonstrated, there are shortcomings in the composting of domestic wastes. The shortcomings remain; even if a high success rate were achieved for separation measures, the feedstock from MSW contains non-organic materials which would present a costly challenge to remove, either at source or post collection. Plastic bags, glass and batteries are unwelcome contaminants and impossible to remove. Direct collection from markets, restaurants and hotels may yield a better feedstock with a reduced contaminant level, but at additional cost.

Furthermore, there is no evidence that the market for compost in Hong Kong will increase from the existing equilibrium.

Waste to Energy Incineration

Incineration appears the most practical solution for the volume reduction of the remaining wastes. However, in line with establishing the "true costs" of waste disposal, thorough consideration should be given to the fuel source of the incinerator, i.e. the waste stream.

Hong Kong waste has a high moisture content, particularly during the summer months. The moisture content may reduce as the result of improved collection methods. The energy required to remove the moisture from the waste may significantly affect the energy balance of the process and reduce the not available energy for electricity production. The heating value of the waste will also be affected by the separation of waste paper and other recyclable materials.

Detailed investigation of the waste stream, present and potential future, would assist in providing a more accurate prediction of the energy balance. In turn the potential for energy sales, or conversely energy input, would be established. Either outcome may affect the siting of an incinerator scheme.

Offsetting Costs

The plan notes the potential energy available from a waste to energy scheme and significantly, the sale of that energy. It is presumed that a change to the present scheme of control for electricity supply will be forthcoming. Whilst not directly related to the WRFP, there is potential for an effect on the cost of disposal to landfill were the sale of electricity generated by landfill gas permitted. Energy sales resulting from landfill gas production and utilisation rather than destruction in enclosed flares would help offset landfill costs and use a resource of which production is an inevitable by-product of the landfilling of MSW.

Future Planning

As the means to achieve the plan objectives, alternative disposal routes have been described for a variety of wastes in addition to the reduction in volume of many. Consideration of any particular waste stream in isolation may have significant impact on the disposal of another. The co-disposal of wastes cements the interdependency of some waste types. Therefore, a change in the balance of one waste type can significantly affect the disposal options and viability of another. More specifically:

    - the effect of reduced input to landfill on the co-disposal of sewage and other sludges;

    - the effect of incineration on landfills having reduced solid waste input;

    - the effect of potentially reduced heat value feedstock to incinerators and the need for additional energy, i.e. fuel oil, gas or landfill gas. These issues may influence the siting of incinerators; and

    - the ability of the waste management system to react to a partial or complete failure of any one of the proposed waste treatment (seperation, recycling or incineration) facilities.

The importance of landfill as a means of disposal for the residue of the reduced waste streams has been noted in the plan, as is the proposition that the search for new landfill space will start earlier than required by the succesful implementation of the WRFP. An early start to the site search is prudent; the market for re-cyclables may be unsteady, the robustness of the proposed systems has yet to be proven and some intermittent or short term reduction in capacity or effectiveness of one of the waste management routes may be expected.

The Association looks forward to a renewed integrated waste management plan which takes into account a new generation of waste residues requiring disposal and encompasses all the proposed waste management tools and their effects on each other.