“Ali,” a man in his mid-20's, started working in plastic recycling in Adana, a city in the south of Turkey, when he was 13 years old. He worked 13 hours per day in a recycling facility sorting, shredding, and melting plastic into small pellets. Five years ago, Ali quit his job because he had trouble breathing that he thought was linked to air pollution in the recycling facility. “There’s a strong smell of gas,” he explained.
Ali’s story is not unique. While often touted as a positive, environmentally friendly practice, plastic recycling can pose significant threats to human rights and the environment. Plastic products contain toxic chemical additives that can cause serious health problems. Plastic recycling releases those toxins into the local environment, threatening the health of those working in the industry and living nearby recycling facilities.
This report documents the health impacts of plastic recycling on facility workers and residents living near facilities in Adana and Istanbul, Turkey, a major destination for the European Union’s plastic waste. For decades, many countries in the Global North exported their plastic waste to China for recycling. But in 2018, the Chinese government banned plastic waste imports, leaving exporting countries scrambling to find new destinations for their waste. Turkey’s geographic proximity to and strong trade relations with the European Union (EU), and its status as an OECD member have made it a key destination for EU plastic waste exports since the Chinese government ban. In 2020, Turkey was the single largest recipient of EU plastic, importing nearly 450,000 tonnes. The recent influx of EU plastic waste imports contributed to the growth of the plastic recycling sector in Turkey.
Human Rights Watch research found that plastic recycling facility workers and nearby residents can be exposed to harmful chemicals when they inhale toxic dust or fumes emitted during the recycling process, which threatens their right to health. This exposure to air pollution puts workers and residents at the risk of developing significant life-long health conditions, including cancer and reproductive system harms.
The plastics industry has championed recycling as a way to manage waste from their products, while making few efforts to minimize the amount of plastic in their products or design products that can easily be recycled. Many plastic products are designed to be used once, difficult to recycle, and remain in the environment for decades or centuries.
Plastic production, use, and disposal generates harmful effects for human health and the environment. Governments’ human rights obligations require them to address these harms and to protect the rights to health and to a healthy environment. Plastics are produced from oil and gas and then mixed with chemical additives. Plastic production transforms fossil fuels and chemical additives into plastic and, in the process, releases toxic chemicals that are harmful to human health. Plastic recycling and disposal, including dumping, landfilling, and burning, are also linked to negative health and environmental impacts and can emit greenhouse gases. Historically, it is estimated that only nine percent of all plastic ever produced has been recycled, while most plastic waste accumulates in landfills, dumps, the natural environment, or is burned, releasing harmful toxins and greenhouse gases.
Throughout their lifecycle, plastics contribute to climate change. Ninety-nine percent of plastics are made from fossil fuels, including oil and gas. In 2019, global production, disposal, and incineration of plastic emitted 850 million metric tons of greenhouse gases (CO2e), which is the equivalent to the emissions of nearly 190 medium-sized coal power plants. If plastic use continues its current growth trajectory, by 2050 the GHG emissions from its production and incineration will reach 15 percent of the global carbon budget, effectively making global climate goals very difficult, if not outright impossible, to reach.
For the small percentage of plastic waste that makes it to a recycling facility, recycling can pose significant threats to the rights of workers and nearby communities. In order to be recycled, used plastic is sorted, shredded into small pieces, melted, then reformed into pellets that can be used to make new plastic products. This process can have serious consequences for the health of workers and people living near facilities.
Scientific studies have found that localized air pollution and the release of toxins during plastic shredding and melting pose risks to human health. These include exposure to fine particles, dioxins, volatile organic compounds, and other harmful chemical additives in plastics, and have been linked to asthma, respiratory illnesses, cancer, and reproductive system harms.
Adana, a city of two million, is located near the Mediterranean port of Mersin, the destination for nearly 50 percent of Turkey’s plastic waste imports. For decades, Adana’s official industrial area, as well as the nearby neighborhoods of Şakirpaşa, Ova, Onur, and Uçak in Seyhan district, have been the center of plastic recycling in the country. As of April 2022, official figures show there were 167 licensed plastic recycling facilities in Adana and 232 licensed plastic recycling facilities in Istanbul, many of which are located near residences, medical clinics, schools, and parks.
Human Rights Watch interviewed more than two dozen plastic recycling facility workers from December 2021 to March 2022. These workers often come from some of the most marginalized populations in Turkey, including child workers, refugees, and undocumented migrants.
In Turkey, some of the plastic recycling facility workers and residents told Human Rights Watch that they experienced respiratory problems, severe headaches, skin ailments, worked without protective equipment, and had little to no access to medical treatment for occupational illnesses. Human Rights Watch found that licensed facilities in Adana and Istanbul are often located dangerously close to homes in contravention of Turkish law, which requires recycling facilities to be a “healthy” setback from settlements, which include residences, schools, and hospitals, so facilities do not cause any harms to the health or quality of life to those residing nearby. The close proximity of facilities to homes is threatening the health of nearby residents. In addition to health problems, local residents say intense odors and pollution from plastic recycling prevent them from sleeping, opening their windows, and spending time outside.
Children as young as 9 years old work in plastic recycling facilities in Turkey, despite legal protections prohibiting them from working in such hazardous conditions. Under international and Turkish law, work that is likely to harm the health of children is considered hazardous child labor and prohibited. Of the 26 workers interviewed by Human Rights Watch, nine began working in recycling facilities as children, including five who were children at the time of the interview. Workers in plastic recycling across Turkey told Human Rights Watch they earn wages significantly below Turkey’s minimum wage and work on average 12-hours per day, six-days per week. Fear over losing their jobs made workers wary about raising concerns with their employers over harmful working conditions, including working without access to personal protective equipment. Some facilities do not register their employees in the social security system, which provides access to public healthcare, as required by Turkish law, and some recycling facility workers said they do not have access to any medical services if they get sick or injured in the workplace.
Residents, current and former recycling facility workers, medical providers, and facility owners said they did not have information about risks from toxic exposure from recycling facilities or how to mitigate those risks. Despite legal obligations for official government sources and employers to share information on the impacts of air pollution and toxic exposure, workers and residents reported being in the dark about the impacts of plastic recycling on their health and how they could protect themselves. Human Rights Watch co-submitted 22 information requests with the nongovernmental organization Citizens Assembly to relevant ministries and municipalities, seeking information and data on the specific environmental and health impacts of the plastic recycling facilities in Turkey. Only two responses were received within the legal mandated timeframe.
Inadequate enforcement of laws is making the situation worse. In Adana and the Bayrampaşa district in Istanbul, interviewees told Human Rights Watch that they were aware of some plastic recycling facilities operate without licenses from the relevant authorities, although Human Rights Watch did not have the capacity to follow up and identify the facilities operating without a license. A license, if enforced, would require them to uphold higher environmental standards. Plastic recycling facility workers told Human Rights Watch that environmental, occupational health, and labor inspections often do not occur on a regular basis or inspectors do not adequately inspect environmental and health conditions.
The Turkish government’s ineffective response to the health and environmental impacts of plastic recycling and its lack of adequate air quality monitoring violates Turkey’s obligations under domestic and international law, including the government’s duties to respect and protect the rights to health and a healthy environment.
As the impacts of climate change and environmental pollution worsen, there is an increased need for a more circular economy, where products are reused, repaired, and refurbished instead of discarded, in order to reduce the consumption of raw materials and energy required to produce new goods. Viewing recycling as the main solution to plastics use is a false solution. Rather, reducing the production of new materials, like plastic, is essential in the circular economy. Without reducing the amount of plastic being produced, the production of plastics from fossil fuels will continue to exacerbate the climate crisis, a global threat to human rights. If plastic use continues to grow as projected, by 2050 the greenhouse gas emissions from plastic production and incineration will reach 15 percent of the global carbon budget.
To address the human rights harms associated with the business of plastic recycling in Turkey, the Turkish government should ensure that any unlicensed plastic facilities are identified, and required to cease operations and promptly apply for licenses, in line with the Regulation on Environmental Permits and Licenses. The Ministry of Environment, Urbanization and Climate Change should carry out effective and regular unannounced inspections of facilities to ensure compliance with environmental regulations, close or relocate facilities located near homes and schools in contravention of laws, and make information about the risks from air pollution readily available and accessible. The Ministry of Health should carry out health impact studies in neighborhoods near plastic recycling facilities and make community health data accessible and available. The Ministry of Labor and Social Security should carry out regular and thorough occupational health examinations for workers in recycling facilities, ensure that employers are providing adequate protective equipment, and ensure effective enforcement of the ban on child labor.
To protect the right to health for recycling facility workers and nearby residents, the Turkish government should implement existing laws and regulations to prevent human rights harms from the plastic recycling industry. Exporting countries, including those in the EU, should take steps to manage their waste domestically, rather than shipping their waste to other countries. And because the growing rates of plastic production and consumption will continue to contribute to human rights harms, countries should reduce production and consumption of plastic products in order to prevent future human rights impacts associated with plastic recycling and disposal.
Exporters of plastic waste to Turkey, including EU member states, should take steps to ensure that their plastic waste exports are not contributing to human rights harms in Turkey and other importing countries. The European Parliament and the European Council should ensure that the revised Waste Shipment Regulation, which is currently under consideration, puts an end to plastic waste exports to non-European Union or European Free Trade Association countries and extends protections to all countries, regardless of OECD status.
As most plastics are made of fossil fuels, do not biodegrade, and can take centuries to breakdown, it is imperative that the Turkish government take the urgent steps outlined in this report’s recommendations. Plastic created today will continue to be a problem for future generations, making the plastic crisis a significant multigenerational harm.
To the Government of Turkey
- Strengthen laws and regulations to minimize the impacts of recycling on human health and decrease single-use plastic consumption.
- Ensure that authorities in the relevant ministries and municipalities engage and collaborate effectively with local communities, civil society organizations, and universities on data collection, monitoring, planning, and implementation of measures to minimize the impacts of plastic waste recycling on people and the environment.
- Consider the climate impacts of the domestic plastic sector, including by developing emission reduction scenarios for plastic recycling facilities in Turkey’s updated Nationally Determined Contribution to the Paris Agreement, in line with Turkey’s 2053 net zero target.
- Promote policies and practices that increase transparency about chemical additives in materials and limit the addition of harmful chemical additives in plastic products.
To Turkey’s Ministry of Environment, Urbanization and Climate Change
- Due to the negative impacts on health and the environment, reinstate the ban on plastic waste imports to Turkey.
- In coordination with the Ministry of Health, conduct assessments to determine appropriate distances between plastic recycling facilities and residential areas, schools, parks, or medical facilities, and, if necessary, close or relocate all recycling facilities located at too close proximity, in line with the amended Regulation on Licenses for the Opening and Running of Businesses, (no. 25902).
- Require all unlicensed plastic recycling facilities within the Istanbul and Adana Metropolitan areas to cease operation and apply for a license in line with the Regulation on Environmental Permits and Licenses.
- Ensure unlicensed plastic recycling facilities promptly apply for licenses, as required by the Regulation on Environmental Permits and Licenses.
- Conduct regular, independent inspections without prior advance notice, to ensure compliance with regulations, as required by the Regulation on Environmental Audits.
- Increase transparency around the inspection of plastic recycling facilities by making inspection reports, including information on air and water quality, publicly available and accessible.
- Increase air and water quality monitoring in industrial areas and nearby neighborhoods, and make data publicly available and accessible.
- Ensure that data on plastic waste imports, including amount of plastic imported, origin, point of entry, and customs inspections, is up to date and publicly available.
- Strengthen laws and regulations to decrease single-use plastic consumption.
- Due to the significant impacts of PM2.5 on health, adopt a PM2.5 limit standard in line with the EU annual general limit value of 2.5 micrograms per cubic meter.
To Turkey’s Ministry of Commerce
- Work in collaboration with the Ministry of Environment, Urbanization and Climate Change to ensure that plastic waste imports do not contribute to health and environmental harms.
- Increase capacity of customs officials to identify non-recyclable imported plastic, including plastic waste that exceeds the one percent contamination threshold set by the Ministry of Environment, Urbanization and Climate Change.
To Turkey’s Ministry of Health
- In coordination with the Ministry of Environment, Urbanization and Climate Change, as required by the amended Regulation on Licenses for the Opening and Running of Businesses (no. 25902), undertake thorough risk assessments following objective criteria to determine appropriate setbacks (health protection strips) between plastic recycling facilities currently in operation or applying for licenses to operate, and other land uses, including residences, schools, parks, and medical facilities.
- Implement comprehensive inspections to ensure that plastic recycling facilities do not harm the health and quality of life of nearby communities, as required by the amended Regulation on Licenses for the Opening and Running of Businesses (no. 25902).
- Classify plastic recycling as a form of work that may result in occupational illness, as defined by the Regulation on the Rate of Loss of Earning Work Capacity in the Labor Force and Professions, and authorize public hospitals in cities with high numbers of plastic recycling facilities, including Adana, to diagnose occupational illnesses.
- Carry out community health impact studies on neighborhoods with existing plastic recycling facilities, including in Adana and Istanbul.
- Make community health data available and accessible, including neighborhood-level information on disease rates connected with exposure to pollution.
- Educate medical providers on the impacts of air and water pollution on health, including steps they can recommend patients take to reduce exposure to pollutants.
- Improve public education about health impacts of air and water pollution, toxics and how to minimize those risks.
- Increase access to medical services for migrants and refugees in Turkey, regardless of immigration status.
To Turkey’s Ministry of Education
- In coordination with the Ministry of Environment, Urbanization and Climate Change and the Ministry of Health, incorporate awareness for the environmental and health implications of plastics, air pollution, and toxic exposure in school curricula.
- Advocate with the Ministry of Environment, Urbanization and Climate Change and local municipalities to ensure that facilities are located a safe distance away from schools.
- Educate students on steps they can take to reduce exposure to air and water pollution, including pollution from recycling facilities and other industrial sources.
- Provide schools with guidance on reducing students’ exposure to hazardous air pollution while at school, including by installing air filtration systems and providing face masks.
To Turkey’s Ministry of Labor and Social Security
- Conduct regular, independent, and thorough inspections to ensure compliance with regulations, without prior advance notice, as required by the Occupational Health and Safety Law.
- Enforce the prohibition on child labor in plastic recycling facilities through regular inspections, including unannounced inspections.
- Ensure that agencies responsible for child labor inspections, including the Presidency of Guidance and Inspection, have a sufficient number of trained labor inspectors with resources to conduct meaningful inspections.
- Enforce the requirement for employers to provide personal protective equipment, including masks, goggles, gloves, and uniforms, for workers in plastic recycling facilities, as required by the Occupational Health and Safety Law.
- Conduct regular and thorough health inspections for workers at plastic recycling facilities, as obliged by the Occupational Health and Safety Law.
- Require employers to provide workers with full education on toxic exposure, mandatory use of personal protective equipment, and occupational health, as required by the Occupational Health and Safety Regulation.
To Municipalities with High Numbers of Plastic Recycling Facilities
- Respond promptly to citizen complaints as legally obligated by Turkey Municipality Law, No. 5393.
- Require all unlicensed plastic recycling facilities to cease operation and apply for a license from the local municipality.
- Ensure that plastic recycling facilities are located a safe distance from houses, schools, parks, and hospitals before approving licenses as required by legislation.
To Plastic Recycling Companies in Turkey
- Take steps to mitigate exposure to air pollution and toxins, including by improving air circulation and air filtration systems in recycling facilities.
- Ensure workers have access to – and are trained how to properly wear – protective equipment, including masks, gloves, uniforms, and goggles.
To the European Union and its Member States
- Ensure that the revised Waste Shipment Regulation, currently being considered by the European Parliament and the European Council, puts an end to plastic waste exports to non-European Union or European Free Trade Association countries and extends protections to all countries, regardless of OECD status.
- The European Commission through the European Anti-Fraud Office (OLAF) and EU member states should conduct inspections of EU plastic waste exports to ensure they are “almost free from contamination,” as required by the Basel Convention, and prevent the export of such wastes.
- Promote policies and practices that increase transparency about chemical additives in materials and limit the addition of harmful chemical additives in plastic products.
- Take steps to decrease production of plastic and improve waste management practices in line with EU Circular Economy Action Plan.
This report examines impacts of plastic recycling on the health of workers in recycling facilities and those living near such facilities in Adana and Istanbul, Turkey. There are facilities in other cities in Turkey, though Human Rights Watch did not visit these. It documents the harmful effects of plastic recycling on health and the environment, the failure of the Turkish government to protect people’s rights to health and to a healthy environment from such harm, or to respect and fulfil people’s right of access to information. It focuses on the shredding, melting, and pelletizing of plastic in small-scale facilities. Small-scale plastic recycling facilities are dependent on physical labor for most operations, typically have 20 or fewer employees, and have one or few machines to shred, melt, and pelletize plastic. Often, each stage of plastic recycling, including shredding and melting, is done in separate facilities.
Human Rights Watch chose to conduct this research in Turkey because it is a major importer of plastic waste. The Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal, a United Nations treaty that entered into force in 1992, and the proposed EU Waste Shipment regulation offer protections for non-Organisation for Economic Co-operation and Development (OECD) member states that import plastic waste in order to protect less developed countries from environmental and human health harms associated with the global waste trade. As an OECD member, these international protections for non-OECD countries do not apply to Turkey, making it a key destination for plastic waste from nearby European countries, which speaks to the importance of researching plastic recycling in the country.
This report is based on information collected during field research conducted in Turkey in December 2021 and March 2022. Human Rights Watch representatives visited Adana and Istanbul neighborhoods with large numbers of plastic recycling facilities. In the course of this research, Human Rights Watch also visited Izmir, Manisa, Muradiye, Silivri, and Çorlu, but plastic sorting facilities visited in those locations are not central to this research.
Human Rights Watch interviewed 64 people for this report, including 26 people who currently work, or previously worked, in plastic recycling facilities and 21 who live near plastic recycling facilities. Interviews were conducted in Turkish or Farsi, with translation support by Human Rights Watch staff, a consultant, and/or an interpreter. Of the 26 workers interviewed, 16 were in Adana and 10 were in Istanbul. Twenty-two of the 26 workers were male and four were female. Three girls and two boys were under age 18 at the time of the interview, and one woman and three men were adults who began working in a plastic recycling facility as children. Of the 21 residents interviewed, 15 lived in Adana, two lived in Istanbul, and four lived in other parts of Turkey, including Manisa, Menemen, and Çorlu.
All interviewees provided verbal informed consent to participate and were assured that they could end the interview at any time or decline to answer any questions. Some interviewees have been given pseudonyms and other identifying information withheld to protect confidentiality over fears of retaliation. Pseudonyms are used for all children who were interviewed.
In addition to workers and nearby residents, Human Rights Watch also spoke to dozens of people familiar with the plastics recycling industry in Turkey and globally, including waste pickers, healthcare professionals, staff of nongovernmental organizations (NGOs), staff of international organizations, academic researchers, journalists, local elected officials, public school officials, and municipal workers.
Human Rights Watch interviewed seven recycling facility owners in Adana and Istanbul. A 2021 crackdown by the Ministry of Environment, Urbanization and Climate Change on plastic recycling facilities operating without proper licenses made plastic recycling facility owners and some workers hesitant to speak with Human Rights Watch.
Human Rights Watch also reviewed secondary sources, including academic research, project reports, and media reports, to corroborate information from residents or plastic recycling facility workers. Turkish laws and regulations were also reviewed.
Human Rights Watch mapped the location of licensed plastic recycling facilities in Adana’s Şakirpaşa, Ova, and Onur neighborhoods and Istanbul’s Bayrampaşa district using address data available on the Ministry of Environment, Urbanization and Climate Change website. Of the 34 facilities in the three neighborhoods in Adana, we were able to confirm the addresses and map 32 facilities. We mapped 25 licensed facilities in three neighborhoods in Bayrampaşa: Terazidere, Vatan, and Muratpaşa. Open-source online maps and, when available, recent Google Street View data were also used to validate the location of these facilities. Human Rights Watch used open-source online maps to identify schools, health facilities, parks, and residential areas located approximately 250 meters from licensed plastic recycling facilities. Because data on the location of recycling facilities, schools, health facilities, and parks is accessed from multiple sources, our results are approximate and not comprehensive.
This report defines unlicensed facilities as facilities that do not hold all the relevant licenses and permits from the Ministry of Environment, Urbanization and Climate Change and the local municipality.
In May 2022, Human Rights Watch co-submitted 22 information requests with Citizens Assembly, a civil society organization in Turkey, to the Ministry of Environment, Urbanization and Climate Change; Ministry of Education; Ministry of Health; Ministry of Labor and Social Security; Ministry of Commerce; Adana Metropolitan Municipality; and Adana Seyhan Municipality. A description of these information requests is included at Annex 2. Thirteen responses, from three directorates of the Ministry of Environment, Urbanization and Climate Change; the Adana Directorate of the Ministry of Environment, Urbanization and Climate Change; the Ministry of Health; the Adana Directorate of the Ministry of Health; the Adana Directorate of the Ministry of Education; the Ministry of Commerce; the Adana Directorate of the Ministry of Commerce; the Ministry of Labor and Social Security; the Adana Metropolitan Municipality Environment Division; the Seyhan Municipality Permits Division; and the Seyhan Municipality Environmental Protection Department were received at time of writing. Detailed responses to the information requests from the Ministry of Environment, Urbanization and Climate Change General Directorate of Environmental Impact Assessment, Permitting and Inspection and the Ministry of Labor and Social Security are attached in Annex 2.
In June 2022, Human Rights Watch submitted letters to the Ministry of Environment, Urbanization and Climate Change; Ministry of Health; Ministry of Labor and Social Security; Ministry of Commerce; and the Turkish plastic recycling industry trade group (Türk Plastik Sanayicileri Araştırma Geliştirme ve Eğitim Vakfı Geri Dönüşüm İktisadi İşletmesi, PAGÇEV), to request follow up information on the information requests and to solicit response to the issues documented in the report. At the time of writing, Human Rights Watch had only received responses from the Ministry of Labor and Social Security and PAGÇEV. This correspondence is attached at Annex 1.
What are Plastics?
Scale of the Problem
The world is drowning in plastic. We are eating, drinking, and breathing plastic, and plastic particles have been found in human blood, lungs, and placentas.  Scientists have documented microplastics, or plastic particles smaller than five millimeters in diameter, from the top of Mount Everest to the bottom of the Mariana Trench, in 94 percent of tap water in the United States, and suspended in the air in some of the most remote places on Earth. While often framed as a strictly environmental pollution issue, plastics have significant impacts on human rights throughout their lifecycle, and the problem is increasing.
Plastic is not a single material but rather a term to describe a large group of plastic polymers that are made up of a variety of natural and human-made products and chemicals. Most plastic products are thermoplastics, meaning their chemical structure is fluid when heated and becomes solid when cooled to room temperature. Most plastic packaging is labeled with a plastic resin identification code to identify its plastic type, which makes for easier sorting. Although plastics are categorized as one of seven resin codes, there are thousands of unique plastics, each with their own chemical makeup, structure, and material characteristics.
Since the 1950s, plastic has evolved from a less common, multi-use material to a ubiquitous material in modern equipment, packaging, textiles, and other common goods. Global annual plastic production has soared from two million metric tons in 1950 to 380 million metric tons in 2015 – a 190-fold increase.
Not only has plastic use increased over recent decades, plastic production is projected to triple from 2015 to 2060. Plans to scale up the plastic industry are largely driven by the world’s largest oil and gas producing companies, alongside fast moving consumer goods companies. As countries around the world transition from oil and gas as energy in attempts to prevent the most catastrophic effects of climate change, fossil fuel producing companies are increasing investments in plastic and petrochemical production, as well as increasing capacity to make plastic. Most plastics are made of fossil fuels, do not biodegrade, and can take centuries to breakdown. Plastic created today will continue to be a problem for future generations, making the plastic crisis a significant multigenerational harm.
Plastic Lifecycle and Human Rights
Throughout their lifecycle, plastics’ production, use, and disposal generates harmful effects to human health and the environment, including contributing to climate change. Consequently, governments have obligations to address those harms and protect the rights to health and to a healthy environment. Ninety-nine percent of plastics are made from fossil fuels, including oil and gas. In 2019, global production, disposal and/or incineration of plastic emitted 850 million metric tons of greenhouse gases (CO2e), which is the equivalent of nearly 190 medium-sized coal power plants. If plastic use continues to grow as projected, by 2050 the GHG emissions from plastic production and incineration will reach 15 percent of the global carbon budget, thus making global climate goals extremely difficult to reach, if not outright impossible.
Plastics are primarily made of oil and gas. Oil and gas production can emit toxic chemicals through drilling operations, mechanical equipment, storage tanks, and transportation of fuels. Hydraulic fracturing, or fracking, is a method of fossil gas extraction that pumps fracking fluids into underground fossil fuel reserves to enable more efficient production of fossil gas reserves. Fracking produces large volumes of ethane, a cheap-to-produce gas that can be turned into ethylene, a plastic polymer, making it particularly relevant for plastics production. After fracking fluids are pumped into drilling wells, they can pollute underground and surface water sources that people depend on for drinking and agriculture, threatening their rights to water and food. Methane, a potent GHG, is emitted during fracking.  According to Beyond Plastics, a nongovernmental organization, the methane emitted in the US alone while fracking for gas that is used to make plastics is responsible for 36 million tons of CO2e emissions each year, roughly the annual greenhouse gas emissions of Uruguay.
Plastic production turns fossil fuels and chemical additives into plastic that can be used to make packaging and consumer products. Plastic and petrochemical production emits harmful pollutants to air and water. Making matters worse, refineries and plastic production facilities are often located in low-income, marginalized neighborhoods where minorities, such as ethnic minorities, or communities of color, disproportionately live. Documentation indicates that these communities already experience more or more severe adverse impacts from pollution and environmental harms.
Consumer use of plastic poses is also a health issue. Toxic additives in plastic food and beverage packaging can leach into foods that are ingested by consumers.  Although the science of the human health impacts of ingesting microplastics and chemical additives is still developing, studies have linked ingested plastic particles with impacts on cell function, chronic inflammation, and disruptions to the endocrine system. Currently, plastic producers around the world are not required to identify chemical additives in their products, so consumers are not able to access information about the chemical makeup of plastics and their potential impacts on health.
Finally, the disposal of plastic can pose harms to people and the environment. Most plastic produced is dumped, landfilled, incinerated, or litters the environment. Of all plastic produced, 79 percent has accumulated in landfills, informal dumpsites, or the natural environment, 12 percent incinerated, and 9 percent recycled. When plastic is dumped or landfilled, it naturally breaks down into smaller microplastics, less than five millimeters in diameter, polluting the soil, water, air, wildlife, and human bodies. Methods to dispose plastic waste, including burning and incineration, contribute to short-term and long-term health impacts, as harmful chemicals and particulate matter is released into the air.
Global Waste Flows
Countries in the Global North, including the US, Canada, Japan, United Kingdom, and European Union member states, have routinely exported their plastic waste as “recycling” to countries with weak or non-existent environmental regulations, low labor costs, and little government oversight on environmental and labor rights violations. In many cases, this plastic is not actually recyclable due to product design or a lack of recycling capacity in importing countries and leads to environmental pollution in recipient countries. Most countries in the Global North export their waste because they currently lack the physical infrastructure to recycle it domestically, and profits can be made by selling it to companies in other countries for processing. At the same time, countries in the Global North are able to externalize the health, environmental, and economic costs of their high consumption economies by exporting their waste instead of reducing levels of consumption or investing in waste management.
For decades, China was the world's single largest importer of plastic waste, importing approximately 45 percent of global plastic waste from 1992 to 2016. Due to the high environmental impacts of plastic waste, the Chinese government implemented its National Sword Policy in January 2018, which banned the import of most plastic waste. Since this ban went into effect, exporting countries have searched for new places to send their waste, and Malaysia, Indonesia, Vietnam, and Turkey have recently become key destinations for the world’s plastic waste exports. As countries, particularly in Southeast Asia, have become new destinations for plastic from the Global North, many have introduced new regulations on the quality of waste imports, while other countries have banned plastic waste imports completely due to the environmental and human health impacts. Recent plastic import bans by the Chinese government and other countries are leading to less plastic waste being recycled. For example, plastic recycling rate in the US dropped from 8.7 percent in 2018 to between five and six percent in 2021 due, in part, to decreased waste exports. Globally, plastic waste exports have been decreasing since 2017, as importing countries impose stricter regulations.
How Plastic is Recycled
Recycling plastic is not done at the consumer level, rather it is a multistep process. When plastic is deposited into a bin labeled for recycling, that plastic waste is being sorted, the first step in the mechanical recycling process. While individuals may separate their plastic waste from other materials, the actual process of recycling plastic occurs in industrial facilities.
The following description of mechanical plastic recycling details the process for small plastic recyclers in Turkey. It does not describe the practices at larger, warehouse-sized facilities or facilities reliant largely on modern technology for operations, although mechanical recycling follows the same process regardless of facility size. Turkey is home to both small-scale and larger, modern recycling facilities.
In Turkey, most recyclables are sorted at waste depots, where waste pickers, municipal collectors, or waste brokers bring mixed waste. Most Turkish plastic recycling facilities rely on workers to manually separate materials like scrap metal, paper, cardboard, and distinct types of plastic, as little waste is separated at the household-level. On the contrary, in modern plastic recycling facilities, plastic waste is sorted by resin code using sink-float sorting methods, which sort plastic by buoyancy in water, or air classifiers, which identify plastic using infrared sensors then sort plastic by resin code using an air jet. Plastic products must be sorted into specific resin types with similar characteristics and properties. For example, black plastic bags are separated from white plastic buckets and clear polyethylene terephthalate (PET) beverage bottles. The processes to recycle these materials are different because of their different chemical composition. Many types of plastic that are collected or imported cannot be recycled because they are contaminated with waste, made up of multiple materials, or of low quality. Materials that are unable to be recycled are either burned, incinerated, dumped, or landfilled.
Once plastic is sorted, it is sold to a facility where it is shredded and washed. The plastic materials are shoveled onto a conveyor belt and carried to a large shredding machine that breaks the plastic into small, centimeter-sized pieces. Plastic bags are also shredded into smaller pieces. After the plastic is shredded, those plastic shreds are washed to remove food particles or chemical residue. Many of the plastic recycling facilities in Turkey are small and only have space for one or two shredding machines.
Then, the shredded plastic is sold to a separate facility where it is heated, melted, and reformed into small lentil-sized pellets, in a process also referred to as extrusion. In this process, plastic is dried, and metal impurities are removed by passing the materials in front of a magnet. The dried plastic shreds are then melted at temperatures ranging from 200 to 275°C, cooled, then formed into pellets. Heating and melting of plastic films and bags involves a slightly different process, known as agglomeration, where the plastic is heated with water in a large, cauldron-like machine. For all types of recycled plastic, once it is melted, it is then cooled and pelletized. In some cases, recyclers add tire dust, paint, or calcite to dye plastic granules different colors. Finally, plastic granules are sold to be used as a raw material for a recycled plastic product.
Waste Collection in Turkey
Up to 80 percent of recyclable material in Turkey is collected by individual waste pickers. There are roughly 500,000 self-employed waste pickers in Turkey, who walk or bike through streets pulling carts that support large sacks to collect waste that can be resold. Waste pickers fill heavy bags with plastic, paper, scrap metal, and other materials that they sell to depots, where the materials are sorted. Among those working as waste pickers are many recent migrants who the work because they do not qualify for legal employment. Many are also Syrian refugees with temporary protection status in Turkey. Collecting waste is classified as a hazardous job under Turkey’s Occupational Health and Safety Law. Waste pickers are exposed to extreme weather conditions and physical hazards, including exposure to hazardous medical waste, needles, and broken glass. Crackdowns in September and October 2021 by the Istanbul municipal police on waste picking resulted in the short-term detention of hundreds of waste pickers and the risk of potential deportation for Afghan migrants working as waste pickers.
There is a growing awareness around household sorting of waste in Turkey. In 2017, Emine Erdoğan, the wife of President Recep Tayyip Erdoğan, launched Turkey’s Zero Waste Program, which intends to decrease waste in the country through a reduction in waste generation and improved reuse, recycling, and recovery of waste. The program aims to increase the country’s recycling rate for all materials to 35 percent by 2023 and led to consumers paying a fee for single-use plastic bags that has decreased the amount of plastic bags consumed by 65 percent. Schools, apartment buildings, and offices in Turkey are now encouraged to provide separate waste collection bins for recyclables and biodegradable waste for composting.
The program has increased the recycling rate of recyclable materials in the country, from 13 percent in 2017 to 25 percent in 2021. It is unclear whether this increase is from increased recycling of plastics or other materials like metal and paper. While this is positive, increased investment in waste sorting and collection through the Zero Waste Program is also negatively impacting waste pickers. Sadik, a waste picker in Adana, told Human Rights Watch that the program is “taking work from poor people like me,” as it is now more difficult to find materials to collect. In addition, beyond the reduction in single-use plastic bag consumption, it is unclear how the Zero Waste Program has contributed to a reduction in waste in Turkey.
Plastic and Health
Although plastic is ubiquitous globally, many of its constituent chemicals are harmful and can pose serious risks to health. Globally, there is limited scientific assessment and monitoring about the impacts of new chemicals on human health and the environment. Of the 350,000 chemicals in use, only a small number have been fully assessed for safety. In addition, there has been limited research on the impacts of exposure to the mixture of multiple chemicals in plastics and other common products. Chemical additives in plastic products can pose significant threats to health, particularly when plastic’s structure is altered during the recycling process.
Burning and incinerating plastic waste contributes to both short-term and long-term health impacts, as harmful chemicals and particulate matter is released into the air. Exposure to air pollution and toxins can pose disproportionate impacts on children, women, pregnant people, and older people due to biological factors. Even in healthy individuals, particulate matter can cause irritation of the airways, coughing, and difficulty breathing. For individuals with preexisting cardiovascular or respiratory issues, short-term exposure to particulate matter can aggravate asthma and cause heart attacks. Air pollution, including particulate matter emitted when plastic is burned, was responsible for 6.7 million deaths in 2019. Long-term health impacts, including the development of chronic obstructive pulmonary disease (COPD) and cancer, may take years to present after exposure to pollutants, so people may not know that they are exposed until diseases develop, potentially decades later. Dioxins are of particular concern. Commonly found in plastic products, they are released as air pollutants when plastic is burned or melted and can lead to long-term damage to the immune, nervous, endocrine, and reproductive systems. Dioxins are targeted by the Stockholm Convention on persistent organic pollutants (POPs) for elimination due to their adverse effects on human health and
Toxic Chemical Additives in Plastics and Health Impacts
Plastic products contain chemical additives that pose threats to human health and make it more difficult to recycle plastic products. Chemical additives are added to plastics during production to change or enhance performance, functionality, or other properties of the plastic product and include: 1) functional additives, like stabilizers, lubricants, and biocides; 2) colorants, including pigments; 3) fillers, like mica, clay, and talc; and 4) reinforcements, including carbon and glass fibers. While chemical additives give plastic products qualities that make them useful, they can also be toxic environmental pollutants and harmful to human health. Plastic producers are not required to disclose additives in their products, so consumers purchasing products with plastic packaging and workers handling plastic waste have no way of knowing if they are exposed to materials that could pose health threats.
Phthalates, bisphenol A (BPA), and per- and polyfluoroalkyl substances (PFAS) are common chemical additives in plastic that harm human health. Phthalates are a group of additives commonly found in polyvinyl chloride (PVC), which is used to make pipes, wire insulation, and window frames. Phthalates are endocrine disrupting chemicals that are linked to early menopause in women, low birth rates, and higher rates of miscarriage. BPA is an additive found in plastic electronics, baby bottles, and many food containers. Exposure can lead to increased risk of cancer, cardiovascular disease, and liver problems. PVC incineration releases phosgene, an asphyxiant gas that was used as a chemical weapon during World War I.
The EU has listed BPA as a substance of high concern due to its impacts on the endocrine systems of humans and animals, requiring companies that supply BPA in the EU to label the substance.  BPA has also been banned in the EU and in the US for use in baby bottles. PFAS are a group of persistent chemicals known as forever chemicals due to their long lifespan. PFAS can be found in some plastic food packaging and can accumulate in the human body over time and contribute to serious health impacts, particularly for pregnant people and children. Exposure to PFAS is linked with decreased fertility, low birth weight, reduced immune system response, increased risk of cancer, and developmental delays. The EU and some localities in the US have taken steps to ban PFAS in firefighting foams, but chemical industry groups pushed back against a widespread ban on PFAS in the EU.
Additives in plastic products enter the environment and expose people to their harmful effects throughout the plastics lifecycle. Some hazardous chemicals can leach from plastic packaging to food products consumed by people. Incinerating and burning plastic generates toxic gases that pose threats to human health.
Recycling and Exposure to Toxins
The mechanical recycling process accelerates the release of additives into the environment through emissions, releases, and leaching. In particular, the shredding and extrusion phases emit toxins into the local environment that pose significant risks to health.
Particulate matter released when plastic is shredded is harmful to short-term respiratory and cardiovascular health when inhaled and can lead to asthma, wheezing, and decline in lung function. PM2.5 is particulate matter with a diameter of 2.5 micrometers, about the size of 1/30th of a strand of human hair, is easily inhaled into the deepest parts of the lungs, and can move into the bloodstream impacting both respiratory and cardiovascular health. Although Turkey does not currently have a PM2.5 standard, the Directive of the European Parliament and of the Council on ambient air quality and clean air for Europe establish an annual maximum of 25 micrograms of PM2.5 per cubic meter, in line with public health best practices. Other toxins can be released during plastic recycling, including polybrominated diphenyl ethers (PBDEs), a group of flame-retardant chemicals that are carcinogenic and pose threats to the endocrine system. High levels of PBDEs have been found in the air and dust of recycling facilities.
As plastic is heated at high temperatures, melted, and reformed into small pellets, it emits toxic chemicals and particulate matter, including volatile gases and fly ash, into the air, which pose threats to health and the local environment. When plastic is recycled into pellets for future use, its toxic chemical additives are carried over to the new products. Recycled plastic pellets are often contaminated with harmful chemicals, including endocrine disrupting chemicals, that are present in virgin plastic products that are not filtered during recycling, thus transferred into recycled plastic. In addition, the recycling process can generate new toxic chemicals, like dioxins, if plastics are not heated high enough. Plastic extrusion also emits greenhouse gases that contribute to climate change.
Plastic recycling is linked with local environmental contamination. Untreated wastewater from recycling facilities are likely contaminated with toxic pollutants that can harm people and biodiversity. Plastic melting facilities emit volatile organic compounds (VOCs), harmful polycyclic aromatic hydrocarbons (PAH) , and odorants into the air, which have been found in residential areas downwind of recycling facilities. Toxic chemicals, including carcinogens and VOCs, pollute air both inside facilities and in areas near recycling facilities. Because plastic recycling is done in a similar process around the world, it is reasonable to expect similar emissions from recycling facilities, regardless of their country of operation.
Disproportionate Health Outcomes
Exposure to toxic chemicals in plastics impacts groups in different ways. Employment in hazardous industries and biological factors influence the impact of toxic exposure on health.
For most adults, the greatest time spent out of the home is at the workplace. Occupational factors are responsible for roughly 18 percent of adult-onset asthma, and between two and eight percent of cancer cases can be attributed to workplace exposure. Because of the long hours spent in close proximity to hazardous processes, workers in plastic recycling facilities are highly exposed to toxic chemicals emitted during plastic recycling, unless they wear adequate protective equipment and machinery has effective filtration systems. Occupational exposure to toxic chemicals is a harm to the right to health of workers, even if illnesses or diseases take years or decades to develop.
For women and pregnant people, toxic exposure can contribute to serious, lifelong health problems. Women generally have a higher proportion of body fat, making them more likely to store lipophilic, toxic chemicals in their tissues. Women who are exposed to endocrine disrupting chemicals, including BPA, are at increased risk of polycystic ovarian syndrome and recurrent miscarriages. Environmental toxins in air, water, food, and cosmetics have been linked with female infertility. Exposure of girls and women to endocrine disrupting chemicals prior to and during childbearing years can result in increased likelihood of children being born with disabilities, making this is a significant intergenerational issue. Exposure to air pollution for pregnant people can result in the translocation of pollutant nanoparticles in placental tissue. Endocrine-disrupting phthalates have been found to cross the placental barrier from blood and amniotic fluid, exposing the fetus to toxins that increase the likelihood of premature birth, children born with disabilities, and development of disabilities later in childhood.
Children, when exposed to the same levels of air pollution as adults, are at risk for developing more acute health impacts from that exposure due to their rapid development. Babies can be exposed to harmful chemicals in plastics through breast milk, infant formula, and inhalation. Children are particularly vulnerable to toxic exposure because the chemicals interfere with brain development, the function of hormones, and other processes necessary for children to grow into healthy adults. Children have developing lungs, high respiratory rates, and commonly breathe through their mouths, which may contribute to greater air pollution exposure than adults.
School children who grow up in areas with high levels of industrial air pollution are likely to have reduced lung function. Because of the nature of many toxins in plastics, exposure to those chemicals may lead to harmful effects that do not present until puberty or adulthood. In addition, young children’s developing metabolic system can prolong exposure to endocrine disrupting materials, as it takes their bodies longer to excrete toxic contaminants.
Older people are also disproportionately affected by the harmful impacts of toxic chemicals emitted during the plastic recycling process. As the human body ages, changes in organ functioning may lead to biological challenges processing environmental pollutants, including toxins emitted during plastic recycling. A slower metabolism, coupled with early-life exposures, can lead pollutants to remain in older peoples’ bodies for a longer period than younger adults, thus increasing their exposure to toxins. In addition, higher incidence of apnea and other chronic respiratory diseases can contribute to greater effects of air pollutants on the respiratory system of older people.
Plastic Recycling Practices in Turkey
Adana is the heart of Turkey’s plastic recycling sector. Its proximity to Mersin port, relatively inexpensive land prices, available water resources, a large workforce and immigrant population, and history as an industrial hub has allowed the plastics recycling industry to flourish. As of April 25, 2022, Turkey’s Ministry of Environment, Urbanization and Climate Change (MoE) lists 167 plastic recycling facilities (9.1 percent of the country’s 1,831 plastic recycling facilities) in Adana. There is no available data on the number of unlicensed plastic recycling facilities operating in Adana. While many Adana plastic recyclers are located in the official industrial zone on the outskirts of the city, dozens of facilities are located in the Şakirpaşa, Onur, Ova, and Uçak neighborhoods in Seyhan district.
Mersin port on the Mediterranean Sea is the destination for nearly 50 percent of foreign plastic waste exports to Turkey. Once the plastic waste arrives in Mersin, it is transported to Adana by truck, then delivered to sorting depots or recycling facilities. In 2021, a series of reports, including a groundbreaking report by Greenpeace, about illegal dumping and burning of imported plastic waste in Adana led to a crackdown on unlicensed facilities and facilities without import licenses that were handling imported plastic. The MoE inspected 133 plastic recycling facilities in Adana, found that 26 facilities were operating without proper licenses, and levied a total of 7 million lira in fines on companies that did not hold proper licenses. One plastic recycling facility owner told Human Rights Watch that facilities without proper import licenses received fines between 500,000 and 1 million liras (EUR€48,685 to €97,371) from the MoE starting in May 2021. The MoE also conducted additional inspections of recycling facilities in Adana to inspect permits and determine whether facilities were “deliberating polluting the environment” by dumping unrecyclable imported plastic waste.
As of April 25, 2022, the MoE lists 232 plastic recycling facilities (12.7 percent of Turkey’s 1,831 plastic recycling facilities) in the Istanbul Metropolitan Municipality. In Istanbul, plastic recycling occurs in multiple districts, including Bayrampaşa, Sultangazi, Esenyurt, Başakşehir, Silivri, and Tuzla. Human Rights Watch only visited Istanbul’s Bayrampaşa, Sultangazi, and Silivri districts. We did not seek to visit plastic recycling facilities in all districts in Istanbul, but we consider the neighborhoods visited to be representative of other Istanbul neighborhoods with large numbers of plastic recycling facilities.
Turkish authorities do not publish data on the number of workers in plastic recycling facilities. Human Rights Watch is also not aware of any scientific studies that measure air, soil, or water pollution from plastic recycling facilities in Turkey. Human Rights Watch and Citizens Assembly requested information from the MoE on air and water quality data collected by plastic recycling facilities, but this information was not shared.
The plastic recycling industry is lucrative. Plastic recycling facility owners, workers, and nearby residents told Human Rights Watch that visible economic wealth garnered from the industry has led more individuals to open facilities. A local elected official, or muhtar, in Adana’s Ova neighborhood, described how the open flaunting of wealth drives people to invest in the industry:
My brother and I have owned a shop for 10 years and finally were able to save enough money to buy a house. These facility owners have fancy cars and a lot of money. We all see this wealth, which incentivizes people to join the business.
Of the 16 workers who reported their wages to Human Rights Watch, two earned the minimum wage and 14 earned less than the minimum wage. All child workers who shared information about their wages earned less than the minimum wage. No worker interviewed by Human Rights Watch reported earning more than the minimum wage.
As opposed to recycling practices in the US and many European countries, the recycling process in facilities that Human Rights Watch visited relied on manual labor instead of technological solutions to recycling plastic waste. Relying on manual labor without providing adequate protection increases the number of people exposed to toxic chemicals released during plastic recycling. Modern machinery was not in use in any facility that Human Rights Watch visited or described by any workers interviewed, possibly because modern machinery is cost prohibitive for small-scale companies.
Human Rights Watch visited an extrusion facility on the outskirts of Adana where shredded plastic was dried, melted, and pelletized. The facility did not have a ventilation system or windows, so the facility was filled with dense smoke and the floors were covered in black, oily dust. In one corner near the drying machine, there was a one-meter-tall pile of ash and dust, likely contaminated with toxic chemical additives. None of the four workers or the facility owner wore any type of protective equipment to prevent toxic exposure or limit the inhalation of air pollutants.
Salim owns a plastic recycling facility in Bayrampaşa, Istanbul, where plastic is shredded and melted into pellets. Salim and his wife, Meryem, have been in the plastic recycling business for 30 years and have owned the facility visited by Human Rights Watch for 10 years. To identify and sort plastic before it’s shredded, Salim lights a piece of plastic on fire to identify the resin type based on the smell, smoke color, and melting characteristics. Salim demonstrated this method when Human Rights Watch interviewed him. By inhaling fumes from burning plastic, Salim is directly exposing himself to toxic chemicals in plastics. This method of identifying resin type also demonstrates a lack of understanding about the potential health consequences of exposure to toxins in plastics.
The growing, lucrative, and small-scale plastic recycling sector provides space for rampant abuses of workers and concerning toxic exposure for people who live near facilities.
Wastewater and Water Pollution
Plastic recycling is a water intensive process, particularly in the washing and extrusion phases. Approximately two to three cubic meters of water is used to clean each tonne of plastic, and more water is used to cool plastic once it is melted and formed into pellets. Industrial facilities, including plastic recycling facilities, are not permitted to discharge wastewater into sewers or canals without a permit from the Ministry of Environment, Urbanization and Climate Change and discharged wastewater must not harm human health under Turkish law. It is unclear whether water quality downstream from plastic recycling facilities is being monitored by the MoE’s Department of Water and Soil Management because that information is not publicly available.
“Ahmet,” a plastic recycling facility worker in Adana, described to Human Rights Watch how wastewater from the recycling facility directly polluted the environment:
There’s a dirty water channel next to the machine, that’s where the water goes, goes through pipes from the machine to the canal. I haven’t seen any filtering systems. The filtering isn’t in the facilities.
Human Rights Watch visited a canal in Adana that received wastewater from plastic recycling facilities. The canal runs alongside agricultural lands from Adana to the Mediterranean Sea, just east of Mersin. Alongside the canal, there was illegally dumped European and Canadian plastic waste which was identified by labels on packaging, medical waste, construction waste, as well as ashes where waste had been burned. The canal was not lined with concrete, and there was no visible indication that the authorities had taken measures to prevent pollutants in wastewater from potentially leaching into nearby agricultural soils or being inadvertently used for irrigation of agricultural fields.
Migrants and Refugees in the Recycling Sector in Adana and Istanbul
Migrants and refugees make up a disproportionately high number of workers in recycling facilities because those jobs are available to people who don’t speak Turkish, have low barriers to entry, and are often part of the informal economy that is open to individuals without legal authorization to work in Turkey or facing barriers to finding work in other sectors.
Kurds from Turkey are also highly represented among the workforce in recycling facilities. The bulk of people employed in plastic recycling in Adana are Kurds or Syrian refugees, according to workers, residents, and facility owners interviewed by Human Rights Watch in Adana.
Kurds living in Adana are mostly the children of victims of forcible displacement, or are themselves victims, who came to Turkey from villages and towns in southeast Turkey in the early 1990s when the Turkish military adopted a policy of evacuating or burning down thousands of villages. This was in the course of the conflict with the armed Kurdistan Workers’ Party (PKK). Many Kurds in Adana have faced economic hardship and took unskilled manual work including in the waste sector.
Turkey is the world’s largest host country for refugees, hosting approximately 3.6 million Syrians. Approximately 254,000 Syrian refugees are registered in the Adana province. As the Syrian refugee population in Adana has grown, Syrians have displaced some of the Kurdish workforce in the plastic recycling sector. Sadik, a Kurdish waste picker in Adana, told Human Rights Watch that the recent increase in the Syrian population has made waste collecting more competitive, negatively impacting his work because the increase in waste pickers has made it more difficult to find materials to collect.
In Istanbul, a municipal police officer estimated that approximately 80 percent of people working in recycling facilities are migrants or refugees. Of the 10 Afghan workers Human Rights Watch interviewed in Istanbul, all were men under age 45 and none had legal immigration status. Recycling facility workers told Human Rights Watch that migrants from other countries, including Pakistan, and Iraq, as well as Syrians, commonly worked in recycling facilities in Istanbul.
Health Harms and Risks
Plastic recycling facility workers and nearby residents in Adana and Istanbul are suffering from significant short-term health impacts associated with exposure to pollutants from plastic recycling. In addition, exposure to toxics released during plastic recycling threaten long-term health of workers and residents. While other factors and sources of pollution, including pollutants emitted from other facilities in the vicinity, may contribute to health harms, the types and frequency of health impacts Human Rights Watch documented among plastic recycling facility workers and nearby residents, and the existing scientific research connecting air pollution and toxic exposure to health harms, suggest a strong relationship between plastic recycling and negative heath impacts.
Workers in plastic recycling facilities have direct exposure to toxic pollutants released during plastic recycling. Fourteen of the 20 workers who reported on occupational health told Human Rights Watch that they developed illnesses due to their work, including chronic respiratory conditions such as having trouble breathing, severe headaches, chest tightness, and asthma. Some workers also developed rashes and suffered from eye irritation. Many of those who agreed to be interviewed by Human Rights Watch are former recycling facility workers because many current workers expressed concern over retaliation for speaking out against their employer.
Ibrahim, 32, worked in a shredding and granule-making facility in Adana for between three and four years but stopped working in the facilities in 2019 due to the health impacts:
I got ill so I stopped. My lungs were injured…My doctor told me not to work there. I didn’t get any medicine. They didn’t look at my lungs or do an x-ray. I had an awful dry cough.
“Ahmet,” 20, has switched between working in plastic recycling facilities and as a waste picker for the past five years in Adana. He said:
I used to have health problems when working at the facilities. I had shortness of breath and my back hurt when working in the place that made [pellets]. That was from the fumes from melting. There’s a huge cauldron where they’re cooking the material, they keep adding water which comes back up as steam. When I inhaled that, it would feel like my lungs were squeezed and under pressure...I stopped working there two months ago, but I still have a problem with breathing.
Nasrat, 18, came to Turkey in 2020 from Kabul, Afghanistan and began working at an extrusion facility in Istanbul where he hand-fed plastic bags into a machine that melted the plastic so it could be reformed into pellets. Without legal status, he is unable to access the Turkish healthcare system. After working in the facility for just three and a half months, Nasrat said he developed a chronic cough:
It was very stinky and dusty. It would hurt your nose. It was an ugly smell. I had a cough and my bones ached. I’d buy medicine with my own money…I stopped working in the facility because it had a very harsh smell and I did not earn enough money.
Human Rights Watch interviewed a medical doctor who said he could smell the fumes from plastic recycling facilities from his clinic in Bayrampaşa, Istanbul. He said workers from the nearby plastic recycling facilities often seek medical treatment for respiratory illnesses, take extended periods of time to recover from illnesses, and have higher than expected levels of heavy metals in their blood.
Human Rights Watch also interviewed seven male waste pickers who formerly worked in plastic recycling facilities in Adana and Istanbul. Because income is dependent on the weight of materials collected, waste pickers do not have a steady, reliable income, and their livelihoods depend on how much they work. Although working in recycling facilities provided a reliable income, multiple people reported that they decided to leave their stable job because of the impact of recycling on their health and poor working conditions.
Aydın, 25, started in the waste sector at age 12 as a waste picker. In his early 20’s, he worked in a shredding facility in Adana for between one and two years. Aydın said he left his job at the shredding facilities to collect waste from the streets due to health impacts:
Whether you like it or not, you inhale that smoke… The smoke dries and burns your throat. I did wear a kind of mask, but it didn’t help. It burns the eyes as well… There were days I wouldn’t go to the facility. I didn’t have the energy. I went from 87 to 80 kilograms. I lost my appetite, lost weight, and was coughing.
While Turkish regulations are sufficient to minimize harms from recycling of such toxic substances, insufficient personal protection equipment, lack of health care for workers, and poor working conditions exacerbate risks that workers face.
In many small-scale plastic recycling facilities, working conditions were primitive and exploitative. For example, Human Rights Watch visited an extrusion facility near Adana where shredded plastic was dried, melted, and pelletized. The facility did not have a ventilation system or windows, so the facility was filled with dense smoke and the floors were covered in black, oily dust. There was a 1-meter-tall pile of ash and dust, likely contaminated with toxic chemical additives, in one corner of the facility.
Working conditions were a serious concern for many of the workers who spoke with Human Rights Watch.
“Elin,” 17, is a Syrian child worker who sorts waste with her sisters at a plastic shredding facility in Adana. She told Human Rights Watch that her employer frequently yelled at her, denied her breaks, and forbade her from using the bathroom. Elin told Human Rights Watch that the facilities at work are not adequate for change of menstrual pads, so she must go home, which is a five-minute walk from the facility, to manage her menstruation:
I ask to go to the bathroom and sometimes they don’t let me. We’ll [have to] come home for 5 minutes to change our pad when we’re menstruating.
Insufficient Protective Equipment
Personal protective equipment (PPE), including face masks, gloves, uniforms, and goggles, are key to limit occupational exposure to toxic chemicals in plastic recycling facilities. Turkey’s Occupational Health and Safety Law requires that employers identify and provide protective equipment to workers based on a risk assessment of potential harms in
Yet, 16 workers reported inadequate access to employer-provided PPE, while only four were provided with both masks and gloves by their employer. In some cases, employers provided gloves, in some cases masks. Often, the PPE provided was not adequate to fully protect workers from exposure. None of the workers who spoke with Human Rights Watch reported wearing uniforms. Toxic dust on clothes can expose workers’ family members to toxins emitted during plastic recycling if they enter their homes wearing the same clothes that they work in.
“Çiçek,” 20, and her family are refugees from Syria who arrived in Adana in 2016. Shortly after arriving in Adana, she began working in a shredding facility with two of her sisters, “Elin” and “Zeynep." For the last six years, the three sisters have been hand sorting plastic waste by color. They are not provided with masks, and the gloves provided by the employer do not provide enough protection because the materials they encounter are often dirty:
[Our employer] gives us 12 gloves per month, but it’s not sufficient because the waste is so dirty. So sometimes we wear two at a time. 12 is enough for one or two weeks. We purchase more gloves with our own money.
When we met Çiçek, the skin on her cheeks was irritated and red, and her arms had rashes, which she scratched during the interview. Çiçek told Human Rights Watch that her skin feels as if it’s burning.
In a letter to Human Rights Watch, the Ministry of Labor and Social Security noted that employers that do not provide compliant personal protective equipment are subject to an administrative fine based on the number of employees that do not receive necessary protective equipment. We are unaware of whether any plastic recycling companies have been fined.
Lack of Medical Treatment
Many of the workers who spoke with Human Rights Watch noted that they had limited or no access to medical treatment for occupational illnesses despite a legal requirement for employers to provide this.
“Zeynep,” a 17-year-old child worker, was sorting through plastic waste when a piece of glass gashed her arm and she required stitches at the hospital. Because her employer did not provide Zeynep with social security despite being obligated to do so, she was left to pay for her treatment because Turkey’s social security system provides access to public healthcare.
None of the 10 Afghan recycling facility workers who spoke with Human Rights Watch had legal immigration status in Turkey, which made it difficult for them to access the Turkish healthcare system because they are not registered through the social security system. Specifically, the fear of deportation dissuaded them from seeking medical treatment for occupational illnesses and injuries. For example, Saber, 19, arrived in Istanbul from Afghanistan in May 2021 and immediately began working in an extrusion facility. He lives in a one-bedroom apartment provided by his employer with 15 other Afghan men who work together in the facility. Saber does not have legal status in Turkey, so he is unable to go to a public health clinic and cannot afford to pay for a private doctor or purchase medicine from a Turkish pharmacy for the frequent chest pain and flu-like conditions he suffers.
While beyond the scope of this report, many workers also reported insufficient medical treatment when serious injuries or accidents occurred at the workplace. People interviewed described frequent accidents given the risky nature of the work involving lifting heavy bales of plastic on forklifts, shredding plastic in machines with sharp blades, and melting plastic at high temperatures. Nine workers said they witnessed serious injuries in the workplace, including co-workers’ fingers or arms amputated in the machinery. “Abdul,” from Afghanistan, who currently works in a facility in Istanbul where he sorts waste, told Human Rights Watch:
A year ago, I saw a man get his hand caught in a machine. His fingers were broken, but he didn’t have papers so he couldn’t go to the hospital to get his hand fixed. So his fingers didn’t heal properly and he could no longer work, so he had to go back to Afghanistan.
It comes as a black smoke. It comes into the house. It’s as if they’re poisoning us.
– Gönül, Adana resident, December 2021
Plastic recycling facilities in Adana and Istanbul are located dangerously close to houses, schools, and medical facilities in contravention of Turkish legislation, putting people at risk of health effects from exposure to toxins and pollutants.
Ten residents living in low-income, densely packed neighborhoods with a large number of plastic recycling facilities reported an array of health problems, including asthma, trouble breathing, rashes, eye irritation, and cancer, while only three said they did not have any health problems. It is difficult to attribute individual cases directly to the recycling facility in part because many factors play a part in these harms. There are a variety of industrial, and likely polluting, businesses in the surrounding area in addition to plastic recycling facilities, which may contribute to negative health outcomes for local residents. Adana has poor air quality due to various sources of industrial emissions, and PM10 measurements in the Adana city center exceeded the national PM10 daily limit on 236 days in 2019. However, the existing scientific base connecting air pollution and toxic exposure to health harms suggests a strong relationship between plastic recycling pollution and health conditions like those described by residents.
Sedat, 35, and his family live in Ova, a neighborhood in Adana’s Seyhan district just north of the airport, where many plastic recycling facilities are located around his family home, with the closest facility no more than 20 meters away. Four of Sedat’s close family members have died of cancer, and he believes that living near recycling facilities for three decades contributed to these fatal diseases.
If you stay so long in a place, you get sick. My 27-year-old sister died of colon cancer, this was 10 years ago. My brother died at 34 years of lung cancer four years ago. I believe it is the effect of the recycling plants…My relative ran a [extrusion facility] and he died of lung cancer. He was 55 years old.
Gönül, 42, has lived in Ova for 26 years. She wants to move farther away from the facilities, but a lack of economic resources prevents her family from relocating. She was repeatedly coughing during her interview with Human Rights Watch. She said:
I’ve had health problems for 12 years, when I developed asthma and bronchitis. I now have hypertension. I can’t stop coughing. I think it’s the plastic. I often go to the hospital, and they just give me serum and an inhaler.
My kids are 21 and 23 and have asthma as well. When they were small, I would take them to the hospital. My son has rashes on his hands. I’m worried about my children.
Health conditions reported to Human Rights Watch from people living near plastic recycling facilities are in line with what medical professionals said they expect to see in an area with high levels of pollution from plastic recycling. A medical doctor in Bayrampaşa, Istanbul, a district with a high number of recycling facilities, told Human Rights Watch he was seeing extremely high levels of heavy metals in the blood of his patients, which include recycling facility workers and people living near facilities. Human Rights Watch requested community level health data from the Ministry of Health in May 2022 on air pollution and toxic exposure related illnesses, but the Ministry did not provide this information in response to our request. A medical doctor in Adana told Human Rights Watch that he had difficulty accessing community level health data from the Ministry of Health.
Improper Location of Recycling Facilities
Of course, recycling would only be in the ghettos. This would never be in a rich neighborhood
— Faruk, recycling facility owner March 2022
Waste treatment facilities, including plastic recycling facilities, in Turkey are required to be located at an appropriate setback from settlements, which include residences, schools, and hospitals, to ensure that facilities do not cause harms to the health or quality of life of people residing nearby, according to the Regulation on Licenses for the Opening and Running of Businesses. The regulation requires the relevant Ministry of Health Provincial Directorate to conduct a risk assessment to determine the appropriate distance before issuing a license to the facility. Based on the risk assessment framework, plastic recycling facilities may be permitted to be between 40 to 325 meters from residences.
In addition, according to the Regulation on the Storage of Waste, facilities that store plastic waste are legally required to be at least 250 meters from residences.
Hanife, 64, and her husband, children, and grandchildren moved to Çorlu, near Istanbul, 12 years ago, where they built a house on inherited farmland. Five years ago, plastic recycling facilities began opening near her home, the closest only 35 meters from Hanife’s front door. “The municipality shouldn’t have allowed us or them to build. It’s either or, not both.” Hanife believed that some of the facilities were unlicensed and said they had been temporarily shut down for two months. At the time Human Rights Watch visited, the facilities were in operation again. Hanife said she could smell burning plastic and hear machines in operation from inside her home. Hanife told Human Rights Watch that her 12-year-old grandson often asked her, “Why did you build this house in the depths of hell?”
Based on Human Rights Watch’s spatial analysis, it is common for plastic recycling facilities in Adana and Istanbul to be located close to residences and other incompatible land uses. The improper locating of plastic recycling facilities too close to housing increases risks to the health of local residents.
Human Rights Watch mapped 32 MoE licensed plastic recycling facilities within Adana’s Şakirpaşa, Onur, and Ova neighborhoods. We used spatial analysis to schools, parks, and medical facilities within 250 meters of plastic recycling facilities, based on the setback defined in the Regulation on the Storage of Waste. Based on our spatial analysis, roughly half of the plastic recycling facilities in Şakirpaşa, Onur and Ova are located within 250 meters of schools, and three facilities are within 250 meters of parks, where children play. Dense residential areas are located next to licensed plastic recycling facilities, and dozens of residential buildings are located within 250 meters. Human Rights Watch interviewed multiple people who lived within 250 meters of plastic recycling facilities in this area.
Human Rights Watch visited a high school and a kindergarten that are part of a large educational complex and located just 25 meters, directly across the street, Şakirpaşa Caddesi, from four plastic recycling facilities. Machinery in operation at one of the recycling facilities was audible from the headteacher’s office in one school. Multiple Adana residents expressed concern over the close proximity of plastic recycling facilities to schools.
In Bayrampaşa, Istanbul, Human Rights Watch mapped 25 licensed plastic recycling facilities from MoE data. These facilities are concentrated in three neighborhoods: Terazidere, Vatan, and Muratpaşa. Based on our spatial analysis, facilities in Bayrampaşa are concentrated with other industrial activities. Sixty percent of the mapped facilities are closer than 250 meters from parks, despite the heightened health risks for children playing in those parks.
Dozens of residential buildings in the three neighborhoods in Bayrampaşa are located less than 250 meters from MoE licensed plastic recycling facilities. Based on Human Rights Watch’s spatial analysis, 70 percent of Vatan’s residential area is located within 250 meters of recycling facilities. Three facilities are located within 250 meters of an elementary school in Bayrampaşa’s Vatan neighborhood. In Bayrampaşa’s Terazidere neighborhood, one school and the Bayrampaşa Kolan Private Hospital are located slightly beyond250 meters from plastic recycling facilities.
In Bayrampaşa, most workers reported living in employer-provided apartments, often with 15 to 30 men living in a one- or two-bedroom apartment. These housing arrangements were commonly in an apartment directly above the plastic recycling facility, or next door to the facility. In these cases, workers are exposed to toxic pollution at work and at home.
Quality of Life
Seventeen of 21 residents reported that living close to plastic recycling facilities has negatively impacted their quality of life. They told Human Rights Watch that intense odors and pollution from plastic recycling prevented them from sleeping, opening their windows, and spending time outside. Six people said that they wanted to move away from the facilities but did not have the financial means to relocate their families.
Cihan, 55, lives near multiple plastic recycling facilities and an empty lot where unrecyclable waste is illegally dumped and burned. She said:
The [recycling] factories work at night too, and they’re very loud. It wakes me up. I hear workers fighting, machines, generators. It sounds like “tack tack tack.” There’s always noise. My [mental health] is affected by this. I get so angry and have to go to a psychologist.
Osman owns a barber shop located around the corner from multiple plastic recycling facilities, some of which run 24 hours per day. Osman told Human Rights Watch that the facilities impacted his ability to sleep, particularly in the last four or five years when more facilities have opened. "Sometimes I wake up in the middle of the night because of the smell."
Adana is known for its extremely high temperatures and humidity in summer, with an average August temperature of 34 ͦC (93.2 ͦF). Multiple residents said that they could not open their windows during the summer because of odors from the recycling facilities. Based on Human Rights Watch field research, most residents living near recycling facilities in Adana are low-income and do not have access to air conditioning, so not being able to cool down their homes at night could increase risk of heat-related illnesses.
Fires at plastic recycling facilities pose significant threats to the health and lives of nearby residents. Researchers with the Microplastics Research Group have documented more than 100 fires at plastic recycling facilities in Turkey in the past two years. While it is not clear why recycling facilities are at risk of so many fires, some experts, activists, and local residents told Human Rights Watch that they believe fires are purposely lit in order to get rid of unrecyclable materials, including unrecyclable plastic packaging. Human Rights could not confirm this allegation. The prevalence of fires at plastic recycling facilities increases health risks to those with preexisting respiratory illnesses from air pollution, as well as threats from the fire itself, particularly for those living nearby.
Child Labor and Plastic Recycling
Human Rights Watch found that children work in plastic recycling facilities in Turkey, despite legal protections prohibiting them from working in such dangerous conditions. While child labor isn’t exclusive to the plastic recycling industry in Turkey, Human Rights Watch documented nine cases of child labor in plastic recycling facilities. Hazardous work, including at plastic recycling facilities, harms children’s health and safety, and is prohibited under international and Turkish law.
Human Rights Watch interviewed three girls and two boys working in plastic recycling facilities, starting as young as 9-years-old. One woman and three men interviewed by Human Rights Watch began working in plastic recycling facilities as children, starting as young as 13-years-old.
Child labor also interferes with children’s education. None of the child workers interviewed by Human Rights Watch attended school, despite legal requirements for children to attend primary school and four years of secondary school. The loss of an education has significant impacts both for individual children and society as a whole because education can break generational cycles of poverty and enables children to be full and active participants in society.
“Yusuf,” now 16, started working in a plastic shredding facility in Adana when he was just nine years old. At the facility, he was responsible for loading plastic onto a conveyer belt, feeding materials into the shredding machine, and unloading trucks with plastic waste deliveries. After working in the facility for four years, Yusuf’s father stopped him from continuing to work there due to working conditions. Yusuf said:
We worked intensely and long hours. We would get five minutes to sit, then a truck would come, and we’d unload it. We started working at 8 a.m. and went until 8 p.m. Sometimes we’d work until 3 a.m.
Globally, migrant and refugee children are at increased risk into being forced to work. Six of the nine child workers Human Rights Watch interviewed were migrants or refugees. Some children working in plastic recycling facilities and as waste pickers told Human Rights Watch that they were forced to work by their parents to support their families. “Çiçek,” who began working in a plastic recycling facility at age 15, told Human Rights Watch: “My dad is forcing [my sisters and me] to work there. If he didn’t force us to go, then I wouldn’t work there.”
“Mohammed,” 15, came to Adana with his family in December 2021 from Syria and had worked as a waste picker for one month at the time Human Rights Watch interviewed him. His father told him to find work, so he began collecting waste in the streets. Mohammed dislikes collecting waste and he told Human Rights Watch that the smell of garbage makes him want to vomit, but he cannot find other work because he does not speak Turkish.
Children may also be at greater risk of exploitation in the workplace than adults. “Karim,” now 16, left Afghanistan when he was 14 years old. After arriving in Istanbul, he began working in a plastic shredding facility, where he was the youngest worker. After one and a half months of working at the facility, Karim quit because the employer did not pay his wages.
Turkey has ratified the Convention of the Rights of the Child and the International Labor Organization’s Worst Forms of Child Labor Convention, which obligates states to protect children from work that may harm children. Turkey’s Regulation on Heavy and Dangerous Work lists types of work that children ages 16 to 18 may not be employed in, including work in plastic manufacturing, machine repair and cleaning, and other work involving waste disposal. In a letter to Human Rights Watch, the Ministry of Labor and Social Security reported that children cannot be employed, “in jobs that require working with hazardous substances which cause occupational diseases.”
European Imports in Turkey
I see imports. It’s clear they come with big bales, 4 or 5 huge trucks with mixed plastic; you can tell it’s coming from abroad. They buy for one price cheap overseas, then sort it, then can increase the price. It’s much more profitable than domestic waste.
– “Adnan” Adana resident, March 2022.
Since the Chinese government implemented its National Sword Policy in 2018, Turkey has become the largest importer of European plastic waste, including imports from EU member states and the UK. In 2016, Turkey imported 33,804 tonnes of plastic waste from European Union countries. By 2020, that figure increased by more than 1,200 percent to 447,432 tonnes. Since withdrawing from the EU in January 2020, the UK has exported vast amounts of plastic waste to EU members and Turkey. While more than half of the UK’s plastic waste was exported to EU countries in 2021, the UK shipped 122,898,385 kilograms of plastic waste, or 27 percent of its plastic waste exports, to Turkey.
Although the UK exported plastic waste under the guise it would be recycled, Greenpeace, a global environment non-governmental organization, documented that in practice actors in Turkey illegally dumped, burned, or landfilled much of the plastic waste because it was too low quality to be recycled or contaminated with other waste.
Turkey’s geographic proximity to the European Union and its status as an OECD member make it a key destination for EU plastic waste exports because the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal and the proposed EU Waste Shipment regulation offer protections for non-OECD members that import plastic waste. There are no EU policies dictating that plastic waste should be shipped to Turkey by EU members. The EU and Turkey have strong trade relations, dating from the 1963 Association Agreement and the 1995 Customs Union agreement. Turkey is the sixth biggest trading partner for the EU, while the EU is Turkey’s largest import and export partner. The global plastic waste trade involves many actors, including waste brokers and dealers, waste carriers, shipping agents, and port authorities, and the legal plastic waste trade was valued at $2 billion globally in 2020. The global plastic waste trade has also been linked with organized crime and waste trafficking.
After a series of international media reports, including a report by Greenpeace released in May 2021, about illegally dumped and burned imported plastic waste to Turkey, the Ministry of Environment and Urbanization banned imports of two common types of plastic waste effective July 2, 2021.  Nine days after the import ban went into effect, Turkey’s Ministry of Commerce announced the ban had been rescinded.  Activists in Turkey believe the ban was rescinded due to pressure put on the government by Turkey’s plastics sector. Although the plastic waste import ban was short-lived, EU plastic waste exports to Turkey decreased to almost zero after the ban was announced but have steadily risen to pre-ban levels since fall 2021.
Based on interviews with plastic recycling facility owners, workers, and nearby residents, it is evident that the rise in European plastic waste imports over the past few years has contributed to an increase in recycling facilities.
Increase in Recycling Facilities
From 2018 to 2020, EU plastic waste exports to Turkey skyrocketed from 38,804 to 446,432 tonnes – a 1200 percent increase. Five of the seven recycling facility owners Human Rights Watch interviewed were recent to the plastic recycling sector. Notably, there is lack of official data on the number of plastic recycling facilities in operation in Turkey before and after the 2018 increase of imports, so there is no way of knowing how many plastic recycling facilities in Turkey opened in direct response to increased European imports. However, some residents and workers at plastic recycling facilities noted that imported plastic waste was a relatively new phenomenon, which they believed had resulted in a growth of the sector.
Velat, a recycling facility worker in Adana, has been working in the waste sector for 20 years as a waste picker and now in a recycling facility explained:
For the last [few] years, the plastic recycling sector has expanded. We think this is because of imported plastic. We never heard of waste from other countries before seven years ago. 
The growth of the plastics sector has had a profound impact on Adana. Osman, an Adana resident, told Human Rights Watch: “Before there were facilities, there were fields and women were collecting and growing food…[The facilities have] grown a lot in the last four or five years.”
While Human Rights Watch did not see imported waste in the facilities we visited, workers interviewed said they saw imported waste at work and were able to identify imported plastic waste by the languages on plastic packaging.
Quality of Imports
Turkish waste is typically not sorted and thus requires more cleaning than imported European waste, providing recycling facility operators with a financial incentive to recycle foreign waste rather than domestically consumed plastic that is mixed with other materials. Roughly 90 percent of Turkey’s municipal solid waste, including plastics, ends in landfills. Despite growing efforts to increase the sorting of recyclable materials from waste through the Zero Waste Program, most household and industrial waste remains unsorted and so plastic waste is often contaminated, requiring substantial and costly manual labor to sort and clean.
Cognizant of the dire impact that European imports could have on processing of Turkish waste, plastic recyclers in Turkey that process imports are required to recycle at least 50 percent domestic waste. They are also obligated to report their recycling capacity to the MoE in order to receive an import permit. Recycling capacity data is not made public, so it is unclear if facilities are reporting this information and if it is being inspected by the MoE. A new regulation, adopted in July 2021, requires plastic waste imports to be less than one percent contaminated, GPS tracking devices to accompany the waste from port of entry to recycling facility, and facilities to pay a bank guarantee to the Ministry before importing. As plastic waste continues to be exported to Turkey in substantial quantities, it is unclear if these measures are effective.
Responding to an information request filed by Human Rights Watch and Citizens Assembly, the MoE reported that waste can be imported at 27 specialized border customs in 17 provinces. It remains unclear what inspection measures are taken to ensure imports meet the one percent contamination limit and other legal requirements.
While European imports are reportedly cleaner and less contaminated than domestic plastic waste, Human Rights Watch observed dumped imported waste, including plastic food packaging, that was mixed with non-recyclables and unable to be recycled. Because we did not observe imported plastic in the recycling facilities visited during the course of research, we cannot confirm the quality of plastic waste imports that are processed in recycling facilities.
Failure of Government to Address Human Rights Impacts of Plastic Recycling
Everything is perfect on paper, but in practice it fails.
– Dr. Sadun Bölükbaşı , Chair of Adana Environment and Consumer Protection Agency,
For the last 27 years, no one from the media, municipality, any other public institution, or governmental authorities have come to this neighborhood and conducted a survey about health, inspections, or social and socioeconomic research. They have never done this.
– Anonymous Adana resident, March 2022.
Turkey has environmental and occupational safety laws that are in line with EU standards. Yet, those regulations are often not enforced, which threatens the rights of people
Facility inspections are a critical mechanism to ensure that plastic recycling facilities are operating in compliance with permit requirements, including that workers have access to protective equipment, and facilities are monitoring emissions. Inspections of facilities is split between national and local government, namely the MoE and the local municipality.
One licensed facility owner told Human Rights Watch that the process of getting a license is complicated, expensive, and requires navigating multiple levels of bureaucracy. For recycling facilities, including waste collection facilities, the company must obtain a license from the MoE, as well as a permit or license from the municipality where the facility is located. The MoE is responsible for establishing recycling capacities, monitoring facility air and wastewater emissions, and monitoring imported plastic recycling, while the municipality is responsible for ensuring that the company is registered and follows local laws and regulations.
1) Ministry of Environment, Urbanization and Climate Change
2) Local Municipality
The MoE must also license plastic recycling facilities. Once facilities are licensed, the MoE is required to conduct annual environmental audits and inspections, including unplanned inspections, of facilities through the Regulation on Environmental Audits. Environmental inspections should review the impact of a business’ activities on the environment and health, including air, water, and soil pollution.
Under Turkey’s Municipality Law, municipal government are granted authority to, “issue permits for, and inspect, polluting businesses...” Local municipal police officers (zabita) provide business permits and carry out inspections. They also inspect buildings to ensure they are following building codes for physical safety and are in line with fire safety standards as required by the Regulation on Fire Protection of Buildings; these standards are not unique to plastic recycling facilities. In order to be granted a business license, the Ministry of Health Provincial Directorate is required first to conduct a health risk assessment to determine a healthy setback to ensure the facility does not harm the health and quality of life of nearby residents.
Under Turkey’s Occupational Health and Safety Law, the Ministry of Labor and Social Security is responsible for monitoring and inspecting occupational health and safety in the workplace, including through workplace inspections, examinations, and research. The Ministry has authority to shut down workplaces whose working methods or equipment are hazardous to workers.
In a letter responding to questions posed by Human Rights Watch, the Turkish plastic recycling industry trade group (Türk Plastik Sanayicileri Araştırma Geliştirme ve Eğitim Vakfı Geri Dönüşüm İktisadi İşletmesi, PAGÇEV) said that all of its members have the appropriate licenses from the MoE and other relevant ministries.
While it is mandatory for all plastic recycling facilities to acquire the relevant licenses and permits from the MoE and the local municipality, it is unclear exactly how many in Adana and Istanbul conform with this requirement and how many flout the regulations and operate as unlicensed facilities. Basic data on the number of unlicensed facilities is not available. Interviews with facility owners, workers, and nearby residents raise the concern that the number may be high, with interviewees offering estimates ranging from 50 to 90 percent of facilities in operation being unlicensed.
Because they are not monitored or inspected, it is impossible to confirm whether unlicensed facilities comply with regulations intended to protect human health, including air quality monitoring, providing workers with protective equipment, or sharing information with workers about risks of air pollution and toxic exposure. Interviews with plastic recycling facility workers in both licensed and unlicensed facilities suggest that working conditions in unlicensed facilities may pose greater threats to human health because there are not official inspections or other enforcement mechanisms to ensure that facilities follow regulations to protect people or the environment.
In Bayrampaşa, an Istanbul district, a municipal police officer provided Human Rights Watch with data on the number of recycling facilities in the Vatan and Terazidere neighborhoods. Officers documented 2001 industrial facilities (not exclusive to plastic recycling); 628 were fully licensed, 799 had no licenses, and the remainder had some licenses or were in the license application process. Plastic shredding and extrusion facilities were the most common industry-type of the facilities classified with the municipal police, with 204 individual facilities, or nearly the number of recycling facilities that the MoE lists for the entire Istanbul region. This supports the concern that many unlicensed facilities not in the MoE’s records may currently be operating in districts like Bayrampaşa. Human Rights Watch does not have access to the equivalent data for other districts in Istanbul or Adana with plastic recycling, as it is not public information. We filed an information request with the MoE for more data on plastic recycling facilities, but the Ministry did not provide this information in response to our request.
A plastic recycling facility owner in Sultangazi, Istanbul reported that his facility is licensed by the Ministry of Environment, Urbanization and Climate Change, which reviews his waste purchases, facility ventilation, building safety, and worker access to PPE. The owner also noted that it was uncommon for recycling facilities in Sultangazi to have the proper permits. “There are probably two facilities in this neighborhood with licenses. Only nice ones like ours.”
Residents and workers in Adana were uncertain of the number of unlicensed facilities. Because there is no official data on the number of unlicensed facilities and the MoE did not provide this information in response to our information request, Human Rights Watch was not able to confirm the exact number of unlicensed facilities in Adana. We are not aware of any efforts by local authorities to ensure that unlicensed facilities apply for the appropriate licenses.
Under the Regulation on Environmental Permit and License, businesses operating without a permit are subject to a fine and must cease operations until they have applied for and been issued a temporary operating certificate or full license. But 20 of the 21 residents Human Rights Watch interviewed said they had never heard of operators in their neighborhood who they believe to be unlicensed being forced to suspend work.
Lack of Inspections
Inspections are a key tool to ensure that licensed facilities follow proper environmental, labor, and occupational health laws and regulations. The MoE conducts inspections to confirm if facilities are in compliance with the relevant environmental permits and licenses. The Ministry of Labor and Social Security leads inspections on work permits, child labor, social security registration, and occupational health and safety. The local municipality, including municipal police, inspects business permits.
Responding to an information request, the MoE reported that 29,932 inspections were conducted of waste disposal and recycling facilities throughout the country from 2018 to August 2022, although the ministry did not specify how many of these inspections were for facilities that recycled plastic waste. Following these inspections, more than 343 million Turkish liras in administrative fines were imposed on facilities that were in non-compliance, and 208 facilities were required to suspend operations . Again, it is unclear whether these fines were exclusive to plastic recycling facilities or for the broader waste management sector.
In response to an information request filed by Human Rights Watch and Citizens Assembly, the Ministry of Labor and Social Security noted that, from 2017 to 2021, there were 105 inspections of plastic recycling centers, of which 26 were found in violation. In a separate letter responding to inquiries Human Rights Watch made to the Ministry, the Ministry of the Labor and Social Security reported there were 280 scheduled inspections and 709 unscheduled inspections between January 1, 2013 and June 29, 2022 regarding working conditions, business conduct, and occupational health. Yet only 10 of 26 workers interviewed by Human Rights Watch reported ever witnessing any type of facility inspection. In four cases, the owners notified workers in advance of the inspection in order to clean the facility or remove unregistered workers.
Zakir, 22, started working at an extrusion facility four years ago, when he arrived in Istanbul from Afghanistan. Now a trainer of new employees, he told Human Rights Watch about the annual inspections by municipal police:
There are usually prearrangements for inspections. The municipal police will come and just see what they want. We’ll clean up the facility first. They inspect work conditions. During the inspection, we’ll just stand aside, I’ll go hide in a corner or go to the other room.
Of the 26 plastic recycling facility workers Human Rights Watch interviewed, only one person reported ever having an occupational health examination. Occupational health examinations, as required by Turkey’s Occupational Health and Safety Law, are carried out in other sectors in Turkey.
Turkey’s Ministry of Labor and Social Security is tasked with conducting labor inspections to address child labor. In a letter to Human Rights Watch, the ministry stated that it inspects child labor through both scheduled and unscheduled inspections, but the ministry did not clarify how the age of workers is checked during inspections or if any administrative fine or measures related to child labor had been levied during the 989 inspections of plastic recycling facilities between January 1, 2013 and June 29, 2022. The US Department of Labor, which monitors child labor globally, has previously identified gaps within the operations of the Ministry of Labor and Social Security and has recommended several steps to address these, including an increase in the number of labor inspectors.
Lack of Response to Complaints
Turkey’s constitution enshrines the rights of citizens and non-citizen residents to submit complaints and apply for information on matters “concerning themselves or the public.” Complaints may be filed in person, by phone, or online with the local municipality, through the Presidential Communications Center, or with the relevant ministry.
Human Rights Watch learned of at least three separate petitions that included signatures of members of the community made by local residents to the Adana Metropolitan Municipality concerning the impacts of plastic recycling facilities. For example, three women collected roughly 300 signatures and filed a petition with the Adana Metropolitan Municipality about the smell, noise, and air pollution from multiple plastic recycling facilities near their homes and told Human Rights Watch that they were threatened by the local police and one of the facility owners. The women told Human Rights Watch that the municipality has not taken any action to address the complaints.
“Selim” lives in Adana’s Ova neighborhood near multiple plastic recycling facilities. In 2020, he collected signatures from people in the neighborhood and filed a complaint with the municipality stating that recycling facilities were located too close to residences, threatened the safety of children due to air pollution, and were making people sick. Within a week of filing the complaint, the chief of the municipal police and the head of the official industrial zone came to Selim’s home and told him that they needed a few months to respond to the complaint, even though they were legally obligated to do so within 30 days.
[The head of the industrial zone] and the police chief came to my door in a car together. They said give us a few months to reply to you. I said okay as long as this is going to end. But nothing happened. Them coming to my door made me feel bad. Of course, I didn’t want to go face to face. I withdrew in a way after that car came to my door. The complaint was filed 2 years ago. They never responded.
Access to Information
People in Turkey, including both workers in plastic recycling facilities and people living nearby, have limited access to information about the impacts of air pollution and toxin exposure from plastic recycling. Basic information about the plastic recycling sector, including the sector’s environmental and health impacts, is often not made public, making it challenging for citizens, civil society actors, or experts to understand the full effects of plastic recycling and hold their governments to account, particularly when additional sources of air pollution, including from industries and nearby coal-fired power plants, also contribute to poor air quality. The impacts of air pollution and toxic exposure are rarely discussed, including by official government sources, employers, and medical professionals.
Journalists have been allegedly attacked by plastic recycling facility owners for reporting on the plastic waste trade and plastic recycling facilities in Turkey. According to a criminal complaint submitted by journalists Vedat Örüç and Elif Kurttaş to the Adana Prosecutor’s Office, the journalists visited the Kemal Deniz Geri Dönüşümcüler Sitesi on July 27, 2022, in order to investigate issues related to plastic waste imports to Turkey and to learn about plastic recycling companies in Adana. According to the complaint, the journalists interviewed an employee of a recycling company and were given verbal permission to take photographs by the employee. The journalists allege that after the interview owners of the facility verbally assaulted and detained the two for thirty minutes, and company employees confiscated their photographic equipment.
According to media reports, owners of the Akgül and Akbulut Recycling Companies have also filed a criminal complaint against Vedat Örüç and Elif Kurttaş for entering the facility without permission and for slander. On August 11, Human Rights Watch sent a letter to Kemal Deniz, the owner of the industrial area, seeking information about protocols for conducting research at the site and security footage, but we had not received a response at the time of writing. This incident is demonstrative of the challenge accessing basic information about Turkey’s plastic recycling industry.
Public Data is Insufficient and Inaccessible
Turkish medical and public health experts told Human Rights Watch there is limited public awareness about the impacts of air pollution and toxic exposure on health, which may contribute to increased exposure.
Information about air pollution and public health is often insufficient or inaccessible. Currently, the MoE is not collecting sufficient air quality data to document the impacts of plastic recycling on health, and the information that is collected is not readily accessible to people in Turkey.
In Adana, government air quality monitors are located in the Seyhan district city center, but not in the industrial zone where there are many point-sources of air pollution. Government air quality data is published online in Turkish for a general air quality index, PM10, PM2.5, carbon monoxide (CO), sulfur dioxide (SO2), and nitrogen dioxide (NO2). On the government website, hourly air quality data is shared in charts, and it is color-coded to communicate potential risks to health.
The closest monitor that publicly reports air quality measurements is roughly five kilometers away from the industrial center where plastic recycling facilities are located. There is no public, government air quality monitor located in Adana’s industrial area or in neighborhoods with large numbers of plastic recycling facilities. Air quality data taken in the city center finds that the city is already polluted, with PM10 standards exceeded 65 percent of the year, but it is possible that residents living close to the industrial center are exposed to even more harmful air quality.
Licensed plastic recycling facilities are required by the MoE to carry out air quality monitoring, but the Ministry does not make that data publicly available. Because air quality data collected by facilities is kept private, Human Rights Watch could not confirm if plastic recycling facilities had proper air quality monitoring systems in place, and we were not able to access air quality data taken at plastic recycling facilities despite requesting this information from the MoE. Without access to information about local air quality, people living near plastic recycling facilities are not able to make decisions to protect themselves from the harmful impacts of air pollution, and medical and public health experts are not able to communicate the risks of exposure.
The Turkish Statistical Institute publishes limited data on industrial air pollution, but this data is sector-based and does not provide emissions data for plastic recycling in Turkey. Emissions data is provided for water supply, sewage, waste management, and remediation activities all together, so it is unclear what emissions are from the waste management sector, or specifically from plastic recycling. This data is also not useful for workers or citizens to understand the risks associated with the plastic recycling sector because it is too general to decipher risks specific to the plastic recycling sector.
The Ministry of Health collects detailed data about public health including disease rates, children born with disabilities, cause of death, and hospitalization rates. Most of this data is aggregated on the country-level, which makes analysis on the impacts of plastic recycling on community health impossible.
Lack of Information from Employers
Employers in Turkey are legally obliged to share information about the potential impacts of workplace exposure with their employees, yet workers are not told what they are exposed to nor the potential impacts. No worker interviewed by Human Rights Watch was aware of air quality monitoring at their place of work. Interviews with plastic recycling facility owners suggest the facility managers do not have a comprehensive understanding of the potential health impacts of exposure.
Two workers told Human Rights Watch that language barriers between workers and bosses prevented them from communicating with their employers. Mahmut, a 27-year-old Syrian worker describes, “At the facility, there were bosses and foreman. They were Turkish and didn’t tell us anything. The bosses didn’t speak Arabic.” 
Lack of Information from Medical Providers
Doctors in Turkey, including doctors with senior roles in medical chambers, have been investigated and targeted by the Turkish government for speaking out on public health matters, particularly since the start of the Covid-19 pandemic. Because of this, Human Rights Watch was only able to interview two doctors for this report. At the same time, doctors in Turkey are required to see large number of patients and receive relatively low incomes, and an estimated 1,400 doctors reportedly left their positions to work abroad in 2021. One clinician who serves residents living near plastic recycling facilities told Human Rights Watch that he sees up to 80 patients per day. Based on interviews with workers and nearby residents, patients do not feel that they are provided with adequate information about the risks and impacts of air pollution and toxic exposure on their health.
Gönül receives frequent medical services for respiratory ailments that doctors tell her are related to living in Ova, Adana. Her doctor suggested that she leave the neighborhood but did not provide any information on what she could do to reduce exposure to pollution:
The doctor asks where I work, and I tell him I live in an industrial zone. He tells me to stay away, but where do I go?... There has not been a survey of health effects, not at all. We’re dead to them, we don’t exist. You’re the first to come ask these questions about health.
“Aysun,” 65, lives no more than 25 meters away from the closest plastic recycling facility. Her home is on a dirt road that has constant traffic of trucks coming and going from the facilities. Trucks drove past Aysun’s home roughly every three minutes while Human Rights Watch conducted an interview outside her home, and it smelled like rotting garbage from the facilities. Aysun was diagnosed with asthma about five years ago, but her doctor did not give her information on how to limit exposure to toxic air to minimize the impacts of asthma.
None of those Human Rights Watch interviewed reported that doctors or other medical staff shared information about exposure to toxic chemicals, like dioxins or BPA, that are emitted during plastic recycling.
Access to Information Requests and Responses
Turkish citizens and non-citizen residents in Turkey have the right to information and to
submit written requests to relevant authorities. The Law on the Right to Information implements this right and is in line with international best practices, including by setting a 15 working day timeline for response and enabling applicants to appeal if an information request is denied.
Due to the absence of basic information on air quality and health data, Human Rights Watch co-submitted information requests with the nongovernmental organization Citizens Assembly in May 2022 requesting information on plastic recycling facilities, air quality data, inspection reports, rates of illnesses related to air pollution and toxic exposure, plastic waste import data, and responses to complaints from the Ministry of Environment, Urbanization and Climate Change; Ministry of Education; Ministry of Health; Ministry of Labor and Social Security; Ministry of Commerce; Adana Metropolitan Municipality; and Adana Seyhan Municipality.
Under Turkish law, government authorities are required to respond to information requests within 30 working days. Of the 22 information requests submitted, two received responses within the legally obligated time frame of 30 working days from the MoE Spatial Planning Directorate and the Ministry of Commerce. Human Rights Watch and Citizens Assembly also received responses from the Ministry of Labor and Social Security; the Ministry of Health; the MoE General Directorate of Environmental Impact Assessment, Permitting and Inspection; the Adana Directorate of the MoE; the Adana Directorate of the Ministry of Health; the Adana Directorate of the Ministry of Education; the Adana Directorate of the Ministry of Commerce; the Adana Metropolitan Municipality Environment Division; the Seyhan Municipality Environmental Protection Department; and the Seyhan Municipality Permits Division, but those responses were outside the 30 working day time frame. Of the responses received, the responses from the MoE Spatial Planning Directorate the Ministry of Commerce; the Adana Directorate of the Ministry of Health; the Seyhan Municipality Environmental Protection Department; and the Seyhan Municipality Permits Division were incomplete in their responses and did not provide answers to the questions posed. The Ministry of Labor and Social Security provided more information, and their response is included in Annex 2 of this report. The MoE General Directorate of Environmental Impact Assessment, Permitting and Inspection also provided a detailed response, which is included in Annex 2. Basic data on air pollution, facility inspections, and plastic waste imports remain unavailable, thus making it difficult for communities to gain basic information needed to understand risks associated with plastic recycling.
III. Turkey’s Domestic and International Obligations
International human rights law obligates Turkey’s government to protect the rights of those within its jurisdiction from harm, including harms linked to business activities such as plastic recycling.
Right to Health
As part of the obligation to respect and fulfill the right to the highest attainable standard of health under international human rights law, governments are required to have and implement policies that protect health in the workplace and prevent and minimize environmental hazards to health. Turkey is a party to the International Covenant on Economic Social and Cultural Rights (ICESCR), and as such has specific treaty obligations with respect to the right to health, which in the word of the Committee on Economic Social and Cultural Rights (CESCR), tasked with interpreting the ICESCR, includes underlying determinants of health, such as safe and healthy working conditions and a
State parties to the ICESCR are obligated to improve “all aspects of environmental and industrial hygiene,” for example through the prevention and reduction of the population’s exposure to harmful substances such as harmful chemicals. The ICESCR requires that states take the steps necessary for “the prevention, treatment and control of…occupational and other diseases.” It also recognizes “the right of everyone to the enjoyment of just and favorable conditions of work” including “safe and healthy working conditions.” CESCR has noted that the right to health includes an obligation on states to minimize “so far as is reasonably practicable … the causes of health hazards inherent in the working environment.” Chronic exposure to toxic substances in the workplace can give rise to violent, cruel, and degrading outcomes, and are therefore violations of the rights of workers.
The Convention of the Rights of the Child (CRC) notes that children’s right to health includes, “a right to grow and develop to their full potential and live in conditions that enable them to attain the highest standard of health.” The CRC also recognizes that for children to enjoy the highest attainable standard of health, states should consider the “dangers and risks of environmental pollution” when combating disease and malnutrition.
Under Turkey’s Occupational Health and Safety Law, employers are responsible for ensuring that employees undergo health examinations relevant to the health and safety risks at the workplace.
The Convention of the Rights of the Child, ratified by Turkey on April 4, 1995, guarantees all children under eighteen the right “to be protected from economic exploitation and from performing any work that is likely to be . . . harmful to the child’s health or physical, mental, spiritual, moral or social development.” The International Labor Organization Worst Forms of Child Labor Convention (No. 182), ratified by Turkey on August 2, 2001, obligates states to protect children from work that is “likely to harm the health, safety or morals of children.” Turkey’s Regulation on Heavy and Dangerous Work lists types of work that children ages 16 to 18 may not be employed in, including work “involved in the manufacturing of plastics substances in which artificial and other synthetic fibres are used,” work involving “the lubrication, repair and cleaning of moving machinery, engines or parts and traction gear,” and work “involving garbage disposal.”
Turkey’s Occupational Health and Safety Law classifies waste collection and waste disposal as hazardous. Under Turkey’s Labor Act, it is illegal for children under fifteen years to work and for children under eighteen years to be employed in hazardous work, as defined by the Regulation on Heavy and Dangerous Work.
Rights of Migrant Workers and Their Families
As a party to the International Convention on the Protection of the Rights of All Migrant Workers and Members of their Families, which Turkey ratified in 2004, Turkey is obligated to ensure that migrant workers and their families—whether documented or undocumented—are treated no less favorably than Turkish nationals with respect to safety and health conditions of work.
Right of Access to Information
Information is a prerequisite for the exercise of various other rights, including both the rights to health and the right to a healthy environment. The Human Rights Committee, a body of independent experts tasked with monitoring the implementation of the International Covenant on Civil and Political Rights, stated that in order to, “give effect to the right of access to information, States parties should proactively put in the public domain government information of public interest,” ensuring access is easy, prompt, effective, and practical.
The right to information is the foundation for the realization of all workers’ rights regarding toxic exposures. Workers have the right to know, inter alia, the implications of exposure, the action being taken to prevent exposure and their rights in relation to such exposure. Every worker has the right to know current information about their actual and potential exposures to toxic and otherwise hazardous substances. Turkey’s Occupational Health and Safety Law obligates employers to inform employees about potential health and safety risks in the workplace, protective and prevention methods to reduce risks, and legal rights.
Right to a Healthy Environment
The right to a healthy environment is established both in domestic and international law. The United Nations General Assembly adopted a resolution on July 28, 2022, declaring access to a clean, healthy and sustainable environment, a universal human right. The Human Rights Council, an inter-governmental body within the UN responsible for the promotion and protection of human rights, “recognizes the right to a clean, healthy and sustainable environment as a human right that is important for the enjoyment of human rights.”
Article 56 of the Turkish constitution establishes, “Everyone has the right to live in a healthy and balanced environment. It is the duty of the State and citizens to improve the natural environment, to protect the environmental health and to prevent environmental pollution.”
Protecting Human Rights in the Context of Business Activity
Governments are obligated to protect their citizens from human rights abuses, including
those connected with business activity. In practical terms, a government’s obligation to protect human rights in the context of business activity “requires taking appropriate steps to prevent, investigate and redress such abuse through effective policies, legislation, regulation and adjudication.” Governments are also obligated to effectively enforce that legal framework once it is in place, to prevent abuse, and to ensure accountability and redress where abuses do occur. Companies also have a responsibility under the United Nations Guiding Principles on Business and Human Rights to respect human rights and ensure that their practices do not cause or contribute to human rights abuses.
IV. Steps Forward
While it is critical for the government and relevant authorities in Turkey to implement existing laws and regulations to prevent human rights harms from the plastic recycling industry, efforts to prevent or address the human rights impacts associated with plastic around the world cannot be addressed simply by improving conditions in recycling facilities. Without taking steps to reduce production and consumption of plastic products, greater demand for plastic recycling will likely continue to contribute to human rights harms.
Within Turkey, Europe, and around the globe, steps should be taken to address the plastics crisis and the impacts of plastic production, use, and disposal on human rights. Turkey is taking positive steps to better manage its own waste, including efforts to decrease single-use plastic consumption. In Europe, efforts are underway to update the EU’s Waste Shipment Regulation, which regulates EU plastic waste exports. And around the world, countries are taking the first steps towards negotiation of a global plastics treaty to address the impacts of plastic throughout its lifecycle.
Waste Management and Recycling in Turkey
As recycling scales up, the Turkish government and relevant ministries should ensure that recycling and waste management practices minimize harm. As is already required by Turkish law, recycling facilities should not be located alongside residences. The government of Turkey should take steps to ensure that recycling facilities currently located too close to settlements are relocated and new facilities are located a healthy setback from residences.
Plastic recycling companies in Turkey can take steps to mitigate exposure to released toxins, including by improving air circulation and air filtration systems in recycling facilities. This could include using ventilation hoods with filters above machines to remove pollutants from the air. Effective air filtration systems reduce exposure risk for both workers and people living near recycling facilities. Access to protective equipment, including masks, gloves, uniforms, and goggles, can significantly reduce worker exposure to toxins in the workplace. However, as long as toxic chemical additives are included in plastic products, the process of recycling will continue to threaten human health.
The government of Turkey should also ensure that the livelihoods of waste management workers in the informal economy, including waste pickers and unlicensed plastic recycling facility employees, are factored into new waste management strategies.
Ways Forward in the European Union
The European Union is home to many of the world’s largest plastic consuming and exporting countries. Following the bans on plastic waste imports by some receiving countries, EU members have continued to send their waste abroad to other locations with less stringent regulations, where it may lead to significant human rights and environmental harms. To address the harms associated with plastic recycling and disposal abroad, EU countries should take steps to limit exporting waste outside of the EU and should prioritize efforts to increase waste prevention, as required by the EU Circular Economy Action Plan.
In November 2021, the European Commission published its proposition to revise the Waste Shipment Regulation, which has governed waste shipments from EU countries since 2006. At this writing, the European Parliament and EU member states are still debating their respective positions in response to the Commission’s proposal. The Commission’s legislative proposal would increase protections for non-OECD countries by requiring importing countries to treat waste in “an environmentally sound manner” and is conditional on the importing country submitting an official request to an exporting country to send waste exports before waste shipments begin.
In the proposed regulation, EU exporting companies should independently audit facilities in importing countries to ensure the facility has the capacity to treat waste, follows domestic environmental regulations, operates in a “safe and environmentally sound manner,” monitors health and safety risks to workers and nearby residents, ensures traceability of all waste received to the facility, takes measures to limit GHG emissions, and can provide records of its waste management activities for the last five years. EU policy experts expect this will function as a de facto ban on exports to non-OECD countries because it requires prior-informed-consent in writing before waste shipments can be sent, essentially banning waste exports unless importing countries request to opt-in. While stronger regulations for plastic waste exports to non-OECD countries have been welcomed by NGOs, there is some concern that these proposed rules may lead to an increase in exports to OECD countries, including Turkey. For OECD countries, the regulation proposal would require importing governments to improve monitoring of recycling facilities and enforcement of trade rules. No facility visited by Human Rights Watch in the course of this research would meet the criteria described in the proposed regulation.
As documented in this report, monitoring of recycling facilities in Turkey is insufficient to enforce regulations designed to prevent human rights harms. The revision of the Waste Shipment Regulation is a significant opportunity for the EU to strengthen and extend protections to all countries, regardless of OECD status, in order to address the global impacts of European plastic waste consumption. The European Parliament and EU member states should make use of this opportunity to push for more ambitious rules in line with international and regional mandates and protect the rights to health and a healthy environment for communities around the world.
Global Opportunities to Address the Plastics Crisis
Around the world, environmental, health, and human rights advocates are pushing for stronger regulations on plastic waste exports from countries in the Global North and solutions to the global plastic crisis.
In March 2022, parties to the United Nations Environment Assembly (UNEA) agreed to establish a committee to negotiate a treaty to address the global plastics crisis. The agreed mandate paves the way for countries to establish a legally binding instrument that addresses the environmental and human rights impacts of plastics throughout their lifecycle, from oil and gas extraction to plastic production to disposal.
Experts, civil society organizations, and local activists are calling for a global plastics treaty that caps plastic production, removes harmful chemical additives from everyday plastic products, and includes the voices of plastic workers, including waste pickers, in decisions made to address the crisis. Some scientists are calling for a phaseout of virgin plastic production by 2040 in order to address the environmental, climate, and human impacts of plastic. The resolution by UNEA to begin negotiations for a global plastics treaty highlights the impacts of plastics on both people and the environment:” The high and rapidly increasing levels of plastic pollution represent a serious environmental problem on a global scale, negatively impacting the environmental, social, and economic dimensions of sustainable development.”
Noting that the plastics crisis impacts countries in the Global North and the Global South in different ways, the resolution considers national circumstances and capabilities, and acknowledges “that some legal obligations arising out of a new international legally binding instrument will require capacity-building and technical and financial assistance in order to be effectively implemented by developing countries and countries with economies in transition.”
The resolution calls on an intergovernmental negotiation committee (INC) to negotiate a legally binding instrument that takes into account the full lifecycle of plastic. The first round of negotiations by the INC will take place in November 2022, with negotiations set to conclude by the end of 2024.
As negotiations progress toward a global plastics treaty in the coming years, states should ensure that solutions address the many impacts of plastics throughout their lifecycle in a way that protects human rights.
This report was researched and written by Krista Shennum, Gruber Fellow in the Environment and Human Rights Division of Human Rights Watch. Emma Sinclair-Webb, associate director of the Europe and Central Asia Division, Deniz Bayram, a Turkish environmental lawyer, and Ceylan Akça Cupolo participated in the field research, providing expertise, legal consultation, and translation. Carolina Jorda Alvarez, senior geospatial analyst in Human Rights Watch’s Digital Investigations Lab conducted spatial analysis on the location of plastic recycling facilities.
The report was edited by Felix Horne, senior researcher of the Environment and Human Rights Division; Richard Pearshouse, director of the Environment and Human Rights Division; Katharina Rall, senior researcher of the Environment and Human Rights Division; Aisling Reidy, senior legal advisor; Babatunde Olugboji, deputy program director; Deniz Bayram; Emma Sinclair-Webb; Julia Bleckner, researcher in the health team; Jim Wormington, senior researcher in the Economic Justice and Rights Division; Juliane Kippenberg, associate director of the Children’s Rights Division; Hillary Margolis, senior researcher in the Women’s Rights Division; Philippe Dam, advocacy director of the Europe and Central Asia Division; Bill Frelick, director of the Refugee and Migrant Rights Division; Sophie Richardson, China Director; and Bridget Sleap, senior researcher in the Disability Rights Division. The report was translated into Turkish by Murat Özbank.
We would like to thank NGO colleagues, local activists, government officials, researchers, and experts who provided information for this report. Thank you to Dr. Sedat Gündoğdu of the Microplastic Research Group for providing technical expertise on the impacts of plastic waste in Adana. We would also express our appreciation to Citizens Assembly for agreeing to co-submit information requests to ministries during the research for this report. We would like to thank Nihan Temiz Ataş and colleagues at Greenpeace Mediterranean for their groundbreaking report on the mismanagement of European plastic waste imports in Turkey.
Most importantly, Human Rights Watch is deeply grateful to the many individuals who shared their knowledge and experiences with us. Without their testimony, this report would not be possible.