The economic consequences of the Basel Convention. Case study for Poland

AR G U M EN TA OECO N O M ICA No 1-2(6) • 1998 PL. ISSN 1233-5835

I. ARTICLES

Stanisław Czaja, Bogusław Fiedor, Zbigniew Jakubczyk,

Irena Rumianówska*

THE ECONOMIC CONSEQUENCES OF THE BASEL

CONVENTION. CASE STUDY FOR POLAND

A u th o rs have presented so m e eco n o m ic consequences o f th e B asel Convention for th e P o lish e co n o m y . T hey have made general characteristics o f the pro b lem o f w aste disposal and the re su lts o f ra tifica tio n o f the Basel C o n v en tio n by Poland. T hey h a v e show ed m acroeconom ic an d m icro eco n o m ic aspects o f w aste m an ag em en t and trade in P o lan d , too.

1. INTRODUCTION

In Poland, the problem o f waste disposal and dangerous waste disposal in p artic u la r is crucial. Poland is one of the largest w a ste producers in E urope. In the years 1975-1994 an average amount of industrial waste was 1 2 0 -1 8 0 m illio n tons (Fig. 1) and an average amount of m unicipal waste was about 25 0 0 0 -4 5 000 dm3.

200 T

150

-100 - ■

50

--o

+i

y

y

— i+i— i+i— i+i— i+i— L|

1975 19 8 0 1985 1990 1991 19 9 2 1993 1994

□ produced, e c o n o m ic a lly used, rendered h a rm le s s □ finally stored

F ig .l. Industrial waste harm ful to the environment in the y ears 1975-1994: generation, e co n o m ic utilization and neutralization and final storage (m illions o f tons).

Source: authors’ own elaboration on the basis o f data supplied b y G U S - Main Statistical O ffice.

* T h e Authors are based in th e In stitu te o f Econom ics, D e p a rtm e n t o f Ecological E c o n o m ic s , W ro c la w U niversity o f E conom ics.

Most o f the waste was stored on dum ping grounds. Therefore, the amount of stored waste is bigger and bigger (Fig. 2).

Fig.2. In d u stria l waste harmful to the e n v iro n m en t, accumulated in th e y ears 1975-1994 (m illio n s o f tons)

Source: a u th o rs’ ow n elaboration on the basis o f data supplied by GUS - M ain Statistical Office.

The p ro b le m refers to dangerous w a ste as well. In 1994, 3,188,000 tons of this so rt o f waste were p ro d u c ed . Their g en e ratio n is regionally diversified ( F ig .3).

3 2 %

14%

■ Legnica O K a to w ice ■ Krakow D P lo c k ■ Lublin □ W arsz a w a B o th e rs

Fig.3. S tru c tu re o f dangerous waste g en era tio n by regions, 1994 (% o f th e total amount) S o u r c e : a u th o rs ’ own e la b o ra tio n o n th e b asis o f data s u p p lie d b y G U S -

M ain S ta tis tic a l O ffice.

The pro b lem of dangerous w aste becom es an important international issue. More rigid environm ental protection regulations and the lack o f place to store bigger and b ig g er amounts of waste in developed countries h av e their reflection in an inclination to export waste, and dangerous waste in particular, to less developed countries. A basic reason w as the lower cost o f w aste storage or waste rem oval in Central and Eastern Europe. The lower cost w as connected, to some extent, w ith lower requirements as regards environm ental protection and unawareness o f the real danger.

A p a rt of “export” undertakings has been illegal. T h e countries which are in the co u rse of the system transform ation and/or countries with an u n stab le internal situation are thought to be characterized by a lower control level (c onnected with the inefficient organization o f civil service), which m akes it p o ssib le to transport and leav e the waste com pletely uncontrolled. In o rder to ch ange this difficult situation som e measures have been taken with the aim o f co n tro llin g international dangerous waste trade by appropriate international conventions. The most im portant document w hich regulates the m arket o f dan g ero u s waste is the B asel Convention.

2. GENERAL CHARACTERISTICS OF THE PROBLEM OF WASTE DISPOSAL AND THE RESULTS OF RATIFICATION

OF THE BASEL CONVENTION

T h e characteristics o f the problem of waste d isp o sal with reference to th e ratificatio n of the Basel C onvention by Poland needs pondering upon re searc h p roblem s regarding general conditions of the ratification of the Convention by P oland. Thus, it is necessary to fix a date of the ratification of the C onvention, the reasons for its ratification and, first of all, expectations concerning th e results and trade benefits connected with acceding to th e convention.

O n the other hand, the question whether a country has taken any measures to achieve the aims connected with signing the C onvention should be asked. A n im portant question is also the cost of development and transfer of process engineering connected with the implementation o f the provisions of the Convention.

A fundam ental problem is a procedure o f im plem enting the C onvention clauses into the system o f n ational law and the national w aste trade policy.

A n o th er basic problem regards the characteristics o f institutional structures and industrial and trade subjects which may be interested in the C onvention at p resen t or in the nearest future; especially the size, organizational form o r ty p e o f o w nership companies actually or potentially involved in the waste trade. T h e research o f the results of ac ceding to the Convention by Poland should allow u s to d efin e its influence upon the change of the n u m b er o f products w hich are b eing controlled. This research m ay also result in opening up the substitute m arket o r the abandonment o f the trade in question.

In o rd e r to give the answ er to the above m en tio n ed research problem s, th e fo llo w in g research is needed:

1) implementation path o f the Convention and its com pliance with the law w hich is currently in force in Poland,

2) identifying the im plem entation m echanism an d monitoring both at national and international level,

3) estim ating economic outcomes o f the implementation o f the Convention provisions in the sphere of trade and indicators o f the achievem ent of environmental aim s of the Convention,

4) identifying and estimating the size o f the illegal trade and com paring its scale before and after signing the Convention. A fundamental question is whether the scale of illegal trade is a menace to the possibilities to achieve environmental aims,

5) exam ining whether the applied trade policy m easures accelerated the achievement o f specific environmental objectives and, on the o th er hand, if the application o f these measures resulted in secondary (side) effects such as:

shortages o f goods, additional costs fo r receiving forbidden chemicals and

waste m aterials. These secondary effects may also influence the extent to which environmental objectives are achieved.

One can accept a thesis that the accession to the Basel Convention implies specific econom ic and competitive results of macro- and m icroeconom ic quality, both positive and negative. The results, in general, can be of tw o kinds: a) on the one hand, the membership in the Convention results in identifiable costs, b) on the other hand, one can expect positive econom ic and environmental results. Therefore, in order to fix economic and competitive results which are the consequence of the ratification o f the Convention one has to ask the following research questions:

1. W hat costs, both in terms o f th eir kinds and size, have to be borne by a country as the consequence of acceding to the Convention? It is important, from the research point o f view, to distinguish fixed and variable costs, with taking into consideration the costs of creating institutional infrastructure to implement the provisions o f the Convention and to m onitor its performance. A nother important group of costs are the expenses for purchasing the rights to apply necessary processing technologies, changes in the management structures and the costs resulting from the necessary limitation o f production (if such a situation occurs).

2. W hat co sts (if any) are involved in trade as a consequence o f acceding to the C onvention? This may refer both to the costs connected w ith the change in trade directions and alterations in exchange forms.

3. W hat secondary costs occur as the result of adaptation to the Convention? Even a prelim inary analysis is able to prove that the ratification of the Convention results in both micro- and macroeconomic costs. However, due to the lack of any research and statistical data it will be extremely difficult to give the answers to the above mentioned questions by means of concrete numerical data. Undoubtedly, the ratification of the Basel Convention has influenced the foreign trade directions. However, it is difficult to calculate the cost of respective changes. The ratification o f the Convention brings also about secondary costs connected with the inability to transfer certain waste types abroad and subsequent necessity to store them in the country, which has its reflection in extra costs.

A n o th er basic research problem is how to d efin e economic benefits, esp ecially savings resulting fro m acceding to the C onvention.

A n ac t of acceding to the Convention is directly linked to the problem o f techn o lo g y transfer. T herefore, it is important to specify economic constraints to the achievem ent of environm ental objectives, esp ecially those related to th e im plem entation of technology, and to check w h e th e r the migration of “dirty tech n o lo g ies“ or/and sectoral changes connected w ith the Convention have taken place.

T h e Convention will probably have an impact on th e m arket structure and its functioning, especially on the m arket of goods w hich are directly com prised by the C onvention. Attempts to estim ate these results w ill have to be undertaken.

G iven the positive results o f the Convention, the m echanism of their achieving and its effectiveness should be described. Specific benefits connected w ith econom ic mechanisms and incentives encouraging the development of trade o f environm entally friendly substitutes, voluntary foreign direct investments and technology transfers can be surveyed according to the follow ing scheme:

a) differentiated patterns o f reducing the d ifferen ce in waste m anagem ent b etw een developed and d eveloping countries,

b) financial procedures,

c) program s to establish the institutions which serve the conclusion o f th e pro ject - if such programs exist,

d) technology, procurem ent, development and tran sfer programs, e) sm all business participation,

0 participation of particular sectors in m echanism s to stimulate the b enefits im plied by the Convention,

g) locally available incentives to encourage public and private investments, h) o th er global or local m echanism s aimed at th e improvement o f w aste technologies, trade, m anagem ent etc.,

T h e above mentioned factors should be analysed fro m the standpoint o f th e ir contrib u tio n to the achievem ent o f environmental g o als o f the Convention.

W h ile comparing the effectiveness of protective an d liberalized waste trade policy, the following issues should be addressed:

a) a com parison o f tra d e costs with the c o sts o f application o f o th e r m e a su re s,

b) a ratio of costs o f applying the trade policy m easures to m onetary o r o th er benefits resulting from M ultinational E cological Agreem ent (MEA, later on in the paper),

c) an analysis of the necessity and effectiveness o f the application o f trad e policy m easures from a national perspective.

2. WASTE MANAGEMENT AND TRADE IN POLAND. MACROECONOMIC AND MICROECONOMIC ASPECT

OF THE PROBLEM

2.1. Introductory remarks

A ccording to the statement o f the Chief Inspector o f Environmental Protection, “ in the second part o f the 1980’s Polish authorities received a number o f proposals from abroad to organize in Poland storage yards and incinerators fo r hazardous waste. T hese proposals included n o t only projects of a com plete technical preparation o f respective installations b u t also offers of transfer o f large amounts of m oney.” (Transboundary w a ste transfer - June 1993 - D e cem b er 1994, The C h ief Inspector of E nvironm ental Protection.) None o f the projects was concluded, although some o f th em were taken into consideration by pertinent State adm inistrative agencies.

The pro cess of the transform ation o f the Polish econom y into a market economy w hich started in 1989, and the signing by P oland o f the association agreement w ith the European C om m unities as well, resu lted in adopting the waste m anagem ent principles which are consistent with tho se being accepted in the EU. T h e se are: waste generation prevention, waste re -u se (recycling) and environm entally friendly waste neutralization.

The prev io u s economic and trade results of ach iev in g environmental objectives in Poland are the results o f m any factors:

- process o f transformation from th e centrally planned to a m arket economy, - liberalization of foreign econom ic co-operation an d changes in the directions o f foreign trade,

- P olish aspiration after acceding into the EU structures, which requires a necessity to adjust rules of law, and o f ecological law in particular, to standards which are b in d in g in the European U nion,

- acced in g by Poland to the Basel Convention,

- the grow th of ecological consciousness of the Polish society and establish­ ment o f stro n g non-governmental ecological organizations (N G O s),

- p u ttin g g reater stress on re searc h connected with th e im plem entation of enviro n m en tal objectives and allo c a tin g more resources fo r the accom plish­ ment o f th em ,

- legal regulations within the country with the purpose o f achieving proper environm ental goals.

As a result o f the emerging o f different factors operating a t the same time, it is difficult to univocally distinguish economic and trade results of Poland’s acceding to the Basel Convention.

2.2. The problem of waste disposal in the Polish system of ecological law

T h e problems of industrial and municipal w aste, and hazardous w aste in particular, emerged in the P olish economy and th e P olish legal system at the turn o f the 1970’s and 1980’s. The 1980 statute on shaping and protecting the natu ra l environment was an attem pt to regulate th e issues of waste production, sto rag e and utilization by econom ic subjects. T h e nature of environm ental p ro tectio n policy at that tim e made it im possible to take advantage o f th e ex istin g law for im proving the environmental q u ality and the institutions o f S ta te adm inistration w ere no t able effec tiv ely enforce this law . T h e in effectiv en e ss referred to w as linked to the v ery nature o f the c o m m a n d - an d -c o n tro l economy an d , apparently, p e rta in e d to other sp h eres o f e c o n o m ic and social life as w ell.

In the second half o f th e 1980’s, the p ro b le m o f hazardous w aste w a s m o o te d in a good deal o f p rogram s of ecological m ovem ents. In the se c o n d p a rt o f 1988, the p ro b lem o f the import o f s m a ll am ounts of w aste fro m G e rm a n y and A ustria em erg ed . The lib era liza tio n o f rules of e c o n o m ic a c tiv ity was abused and th e w aste was placed in sm all com panies as ra w m a te ria ls which were su p p o sed to be processed.

T h e sessions of the “ro u n d table” (the a g re e m e n t betw een the c o m m u n ist g o v e rn m e n t and the o p p o sitio n ) in 1988 are co n sid ered to be th e firs t

im p o rta n t step to e ffic ie n tly increase th e enforcem ent o f e x is tin g

en v iro n m e n ta l law w ithin th e w hole system o f th e legal-econom ic s y ste m o f en v iro n m e n ta l protection in Poland. It was the a g re e m e n t between th e ru lin g a u th o ritie s and the p o litic a l opposition w hich p ro v id e d the grounds fo r an ev o lu tio n a ry transition to a dem ocratic system .

A n ecological team (the so called “green su b -tab le“) was a part of the “ro u n d ta b le ” . The team dealt m ainly with the issues o f environm ental protection. It w as provision no. 20 am ong its other provisions w hich had an im pact on the fu tu re performance of the B asel Convention in P oland. It says, that “there is a ban on any waste im port to Poland with the aim o f its storage, processing and rem o v al; perpetrators o f this activity will be reg ard ed as perpetrators w ho a c t to the detrim ent of the society and natural en vironm ent (with a possibility to p ro secu te them for such activity and to appeal to the court). Specific ru les re g ard in g the transit o f toxic substances or substances dangerous fo r the environm ent will be issued” . (“A ura” 1989, p. 16)

In 1989 this provision h ad its reflection in an am endm ent to the statu te of sh ap in g and protecting th e natural environm ent which is the fram ew o rk environm ental law in P oland. A new legacy was introduced: “The w aste im p o rt is b an n e d ” (Dziennik U staw 1989, no. 26) 3. It w as the first Polish rule o f law

which touched upon the problem o f international w aste trade. Prior to this legacy, this question was not addressed by Polish law.- It w as a reaction to attempts (som e o f them successful) to export waste to P o lan d by developed countries. A ccording to the State Inspectorate of E nvironm ent Protection, just after the ban on waste import had been put into force, by Jan u ary 1991 Poland was offered to import 18,389,000 tons of waste. Only 6 1 ,0 0 0 tons of waste which could b e utilised were im ported.

The legacy o f the Statute was very strict and it contained som e deficiencies. First of all, th ere was no distinction betw een ordinary and hazardous waste. The ban included also the import of m etallurgical waste, especially the scrap of non- ferrous m etals which is the raw m aterial for iron and steel industry, and waste paper. A lso, th e ban had a unilateral character - it made it p o ssib le to export the waste freely. Subsequently, the country was almost d eprived o f non-ferrous metal scrap and waste paper (a sim ilar phenomenon can b e observed in other post-socialistic countries). It is w orth mentioning that in th e case of some technologies the scrap constitutes o f as much as 80% of the fu rn ace charge. The situation ch an g ed in 1994 when the Governm ent put into force a ban on export from Poland o f non-ferrous metals scrap, especially those containing copper, zinc, tin and brass and bronze alloys. In 1994 a rule regarding the export of iron scrap was put into force; export quotas w ere established.

The Basel Convention was ratified by Poland on 20 M arch, 1992 and put into force on 5 May, 1992 in accordance with article 25 o f the framework environmental law. The text of the Convention was form ally published in an official g azette announcing the current legislation. T his delay had an organizational character and did not influence the operation o f the Convention concerned. T h e ratification of the C onvention was published in an amendment to the statute on shaping and protecting the natural environment dated May, 1993 (Dziennik U staw 1996, no. 40). It obliged the Minister of Environm ental Protection, Natural Resources and Forestry to publish a list of hazardous waste which is binding in Poland. The list was published in August 1993 (D ziennik Ustaw 1993, no. 76); it includes 106 kinds of waste regarded by law as hazardous ones. The ratification o f the Convention was accompanied by pressures exerted by different lobbies which aim ed at relaxation o f rules regarding waste import.

According to current legal status, there is a complete ban on hazardous waste import to P oland. Dangerous waste is defined at present as: “w aste which due to its origin, chem ical or biological com position, other features o r circumstances that are dangerous to human life or health or natural environm ent and which are included in the list of the M inister of Environmental P rotection, Natural Resources and Forestry” (Dziennik U staw 1996, no. 49).

T h e import of other waste is allowed by permission o f the Chief Inspector o f Environm ental Protection (w ho is a vice-minister o f environmental protection). W aste can be imported to Poland provided that:

1) th e y are intended fo r secondary processing as raw materials in P o la n d o r a b ro a d ,

2) it is impossible to find in Poland waste su itab le for a given econom ic utilizatio n or the amount of w aste is insufficient,

3) w aste imported from abroad and the way o f its utilization will not b rin g about an increased hazard to the natural environm ent n o r will it contribute to the g row th of waste generation.

T h e C h ief Inspector o f Environm ental P ro te c tio n takes the v o iv o d 's o p in io n and the opinion o f resp ectiv e v oivodship/m unicipal self-g o v ern m en t b o d ie s before he takes a d e c isio n allowing fo r b rin g in g waste to a sp e c ific voivodship/m unicipality. A dditio n ally , the In sp e c to r can demand the o p in io n o f e x p e rts from the M inistry o f Environm ental P ro te c tio n , Natural R e so u rc e s and F o restry regarding the fu lfilm ent of co n d itio n s defined in point 3. T h e im p o rt o f dangerous w aste is liable to p unishm ent o f an up to five y e a rs im p riso n m en t. The im port o f o th er waste w ithout th e perm ission of the C h ie f In s p e c to r of Environm ental protection is liable to pun ish m en t of up to th re e y ea rs im prisonm ent.

D a n g ero u s waste m ay b e exported. In this c a se , perm ission of the C h ie f In s p e c to r of E nvironm ental Protection is re q u ire d . Perm ission m ay be g ra n te d if:

1) w aste is exported abroad with the aim o f its environmentally safe eco n o m ic use,

2) respective agencies o f th e waste importing states and transit states w ill grant perm ission for the im port and transit of waste,

If the disposal of w aste exported from P oland n o t can be perform ed in acco rd an ce with the conditions o f the contract or w aste was exported w ith o u t p erm ission, the exporter is oblig ed to take back the w aste.

T h e export of waste w h ich is not hazardous d o es not require perm ission, h o w e v er the Minister o f Environm ental Protection, Natural Resources a n d F o restry may - by way o f resolution - impose an oblig atio n of getting perm its to ex p o rt non-hazardous w aste to other countries.

T h e transit of hazardous waste through the area o f Poland requires the perm ission of the Chief Inspector of Environmental Protection. An additional requirem ent is to get the perm ission of the countries taking the waste and countries through which the waste will be transported (transit and taking permits).

A breach o f the above m entioned rules is an offence. B o th Polish citizens and foreigners can be perpetrators. T h e maximum punishm ent for hazardous waste export without permission is three years imprisonmeht.

A further adaptation of Polish law to the Basel C onvention is connected with a new law on w aste passed in A ugust 1997. According to th is law, the ban on hazardous w aste export to Poland is still binding u n d er consideration. An analogous situation takes place in the case of delivery o f non-hazardous waste which im plies the necessity to get the permission of the C h ie f Inspector of Environm ental Protection. The conditions of getting the p erm it remain un­ changed. T h e limitations no longer include - as far as w aste im port is concerned - the receipt o f waste in waste collection/disposal facilities at air-ports, river and sea harbours which have been produced as a consequence o f the routine operation o f respective transportation m eans. Following the requirem ents of the Basel C onvention, a hitherto obliging rule of the necessity to obtain the opinion of a voivod o r relevant municipal body before granting a w aste import permit has been cancelled.

The procedure of application for a w aste import perm it has been made more detailed. T h e application should include:

a) d e sc rip tio n of waste to be delivered, especially its physical and chem ical fe a tu re s,

b) quantity,

c) place o f utilization,

d) d e sc rip tio n of waste utilizatio n technology and its en v iro n m e n t im pact assessm ent,

e) nam e and address of the w aste producer,

f) ju stificatio n of the necessity o f w aste delivery from abroad.

A lso, it is possible for the M in iste r o f Environm ental P ro tectio n , Natural R esources a n d Forestry to make a list o f waste whose d e liv e ry from abroad would n o t re q u ire getting any p e rm its which have been p re v io u sly binding. It refers to w aste (metal scrap, p ap e r) which is u n d o u b te d ly used as secondary ra w m aterials.

To som e extent, the rules regarding waste export have b een changed. The legacy has rem ained that the w aste is exported w ith the aim of its environm entally safe use and that it is necessary to get the perm ission of a waste receiving state. The requirements regarding an export application have been extended. T h e application should include:

a) description of waste which is being delivered, especially its physical and chemical features together with the w ay o f its generation,

b) quantity,

d) th e address of a receiver,

e) description of the way o f waste utilization abroad, f) justification of the necessity o f export.

T h e transit permit should include: description o f physical and chem ical featu res, quantity, the route a n d the name of a receiver. Penal law sanctions fo r the b re ach of the above m entioned rules remain u n changed.

A n elem ent com plem enting the new waste law is a new classification o f w aste. It is adjusted to the European C lassification o f W aste and E uropean W aste C atalogue accepted by the decisions of the E uropean Union taken in th e years 1993-1994.

T h is fact corresponds to th e association agreem ent signed by Poland and th e E u ro p ean Economic U nion in 1991 which oblig ates Poland to adapt its e c o lo g ic al legislation to the law o f the European U n io n within ten years. O f k ey im p o rtan ce are also the follow ing regulations: the ordinance of the C ouncil o f E u ro p ean Union dated 1993 regarding transboundary waste transportation, in clu d in g hazardous waste, directives concerning g eneral principles o f w a ste m anagem ent, special directiv es related to hazard o u s and toxic w a ste m anagem ent and the problem o f hazardous and toxic w aste. The latter includes, am ong other things, unified lists o f hazardous and to x ic substances.

In th e aforementioned lists, the waste was m ark ed by means of a six d ig it code w hich includes three groups of information:

- origin and characteristics,

- com ponents and a description of the m anufacturing process, - chem ical constitution.

T h e system that protects P oland from w aste im ports, including h azardous w aste, w as organised in 1990 taking into account actual executive possibilities o f the S tate administration. It is based on close co-operation between the S ta te Inspectorate of Environm ental Protection, individual custom s offices, B o rd er G uard and the National S anitary Inspection. T he procedural law basis o f c o ­ operatio n is the agreem ent regarding the p rotection o f Poland from w a ste im port, signed on 29 A ugust, 1990 by the C h ief Inspector of E nvironm ental P ro tectio n , the President o f th e C hief Customs O ffice an d the Commander o f th e B o rd er Guard Troops (at present - the Border G uard ). The convention has n o t been m odified since the lim itations of waste im port w ere put into force, as th e issues within this sphere are registered in appropriate statutes, especially in th e Law on Customs and the L aw on the Border Guard.

W ith in the above m entioned system, the State Inspectorate of E nvironm ental P ro tectio n plays the role o f a professional advisor w h ich gives an opinion on th e type o f goods in doubtful situations. The customs officers and border guards ask the N ational Inspection o f Environm ental P rotection fo r help w henever th e y

intercept goods which may be suspected of containing w a ste and when the decision to send them back is m ade. T he State Inspectorate of Environmental Protection subm its information regarding possible w aste im ports or exports to the border guards. This information is compiled by means of:

- analysis of changes in the rules of law and econom ic phenom ena which take place abroad (this situation to o k place after the re-unification of Germany when th e rules regarding environm ental protection becam e stricter which contributed to the increase in export o f withdrawn pesticides);

- data exchange as a part of international co-operation;

- analysis o f projects of undertakings extended by P olish econom ic subjects; - analysis o f data submitted by the border guards;

- supervision of Polish econom ic subjects.

A dditionally, in June 1995 the C h ie f Inspector of E nvironm ental Protection obtained access to data concerning international trade b ein g compiled by the Centre o f F oreign Trade Data Processing.

A basic instrument of controlling international waste trade is granting licenses for transboundary transportation. T he system of international co-operation includes the unification of forms of admittance to international w aste trade in which the general rule is to make granting of an export permit dependent on prior obtaining an import perm it. It means that the principle of “control at source” is being applied. Several international agreements w hich regulate the issues o f international waste trade, and hazardous waste in particular, are in operation all over the world.

T hese are the basic elements o f the system of international co-operation in the field o f w aste management:

- the B asel Convention on the control of transboundary transportation o f hazardous w aste and its removal;

- the sy stem of enforcement o f th e regulation no 259/1993 o f the Council o f European U nion on the control o f w aste transportation w ithin and into the Union;

- Interpol.

So far, there has been no investigations in P oland on the results o f ratification and operating of the B asel Convention. There are no research reports or attem pts at estimating both expenditure and results o f th e Convention itself and the achievem ent of its environm ental objectives. It also pertains to the outomes o f signing the C onvention to the State b u d g et (macroeconomic dim ension) and economic subjects (microeconomic dim ension). Information on m em bership fees being paid to co v er the costs of operation of institutions serving th e conventions ratified by P oland is available. T h e fees for the Basel C onvention are being paid by the C om m ittee of Scientific R esearch which is a ministry d ealing with organization and financing the R & D activities. The total

am o u n t o f rates intended fo r this aim which w ere p aid by the C om m ittee of S cien tific Research am ounted, in 1995, to 1,051,000 P L N (Polish zlotys). (T h is refers to international organizations which service: U nited Nations Environmental Program UNEP, the Ram sar Convention, the Helsinki Convention HELCOM , the W a sh in g to n C onvention, th e V ienna C onvention, M on treal Protocol an d th e B a se l C onvention).

T o sum up: the w aste m anagem ent issues, in clu d in g the problem o f w aste im p o rt and export regulated by the Basel C onvention, emerged in the co u rse o f w orks on the reform o f environm ental law in P o la n d in the 1990’s. T h e legal so lutions which were im plem ented during that tim e are a bit stricter than the provisions of the C onvention itself. On the one han d , it may contribute to b e tte r w a ste management (and trade), on the other hand, it m ay also bring about so m e d angers. These are connected, first of all, with:

- the still inefficient enforcem ent of the law;

- the lack of proper institutional solutions (a sp ectacular example o f o rg a n i­ zational and institutional inefficiency is that the B asel Convention is serviced by the C h ie f Inspectorate o f Environmental Protection, though this additional duty has no t been officially defin ed in any organizational and financial regulations.);

- a disordered m arket o f secondary raw m aterials w ithin the country;

- insufficient co-ordination between an ex istin g (and designed) system o f w a ste management and the technological, econom ic and financial possibilities o f econom ic subjects with respect to waste utilization;

- insufficient level o f social consciousness an d the lack of app ro p riate behavioural patterns concerning waste m anagem ent;

- the lack of a proper system of environmental m onitoring.

3. MACROECONOMIC AND MICROECONOMIC CONSEQUENCES OF ACCEDING TO THE BASEL CONVENTION BY POLAND

3.1. Introductory remarks

In general, one can say th at acceding to the B asel Convention by P o la n d had its reflection in the results both for import and ex p o rt. A s regards im port, P o lish ru les o f law have been stricter than the regulation accepted by the B asel C onvention. The act of acceding to the C onvention had no additional re su lts in the operating of economic subjects as far as im port is concerned.

A s regards export, the act of acceding to th e Convention resulted in an im plem entation of new legal regulations concerning:

- control of hazardous w aste transit, - control of hazardous w aste export.

3.2. Waste export

Constraints to hazardous waste have been effective from 3 September, 1993 at the moment o f putting into force the regulation of the M inister o f Environmental Protection, Natural Resources and Forestry dated 3 August, 1993 regarding the compilation o f the list of hazardous waste. Hazardous waste export refers to its one category only, namely to the waste that is a source of non-ferrous metal recovery (metallurgical waste, used catalytic converters). Only one advanced trial of preparation o f such export was reported. It was a case of the “Europol-Bosschem” company from Ł ódź (in 1993) going to export to Ukraine com pletely useless paint waste and used condensers containing PCB.

Export directions are diversified. Beside importers from Western Europe (Austria, B elgium , France, Germany, Great Britain, Italy), the companies from Belarus, Kazakhstan, Ukraine, India and Thailand are also interested in waste from Poland. In the period of imposing control on the hazardous w aste export, Polish companies intended to export about 80,000 tons of this type o f waste. By the end of 1994, four cases o f illegal hazardous w aste export from Poland w ere recorded; in one case the Dutch authorities efficiently sent the transport back. The most hazardous undertaking was an export to Kazakhstan of about 50,000 tons of lead- bearing sludge from the “Legnica” C opper Mill (October, 1993 -Septem ber, 1994). Further export was stopped in Poland. A n illegal transport o f coppered debris to Slovakia was stopped at the border. In June 1995, the State Inspectorate of Environmental Protection, at the request o f the authorities of Kaliningrad district, on the basis o f article 53c paragraph 4 o f the Statute on Shaping and Protecting the Natural Environm ent, enforced the sending back to Poland o f around thousand tons of metallurgical slag exported from Poland in August and Septem ber, 1994 by the MUT com pany, a conglomerate enterprise from Szczecin.

The control o f hazardous waste export gave rise to specific econom ic results connected w ith:

1) e lim in a tio n of some h az ard o u s w aste trade in a c c o rd a n c e with the C onvention,

2) lim itation o f export of som e w aste which was the re su lt o f some trade barriers fo r econom ic subjects,

Elim ination o f export takes place due mostly to the creatio n o f two barriers. These are:

- im possibility to export from P o lan d waste if the country o f destination is

not a m em ber o f the Basel Convention. This is the im plem entation of constraint to waste transportation resulting from the provisions o f the B asel Convention into Polish legislation.

- introducing a ban on th e im port of specific g ro u p s of waste by m eans o f internal regulations within som e countries. These tw o types of barriers often c o ­ ex ist at the same time (e.g. in Ukraine).

T h e following cases of w aste export elim ination illustrate the results o f th e b arriers concerned.

1. T h e first case refers to an export of cadmium sp o n g e which is the result o f m etallurgical processes. This w aste is processed o n ly to a limited extent th e P o lan d , mainly due to the impossibility to sell recovered cadmium in th e co u n try and abroad. Polish com panies have found a receiver in the R epublic o f K azakhstan which is w illing to purchase and p ro c ess cadmium sponge. T h e contract, however, cannot be concluded as K azakhstan is not a signatory o f th e B asel Convention.

2. T h e second case refers to lead-bearing slu d g e . A s in the first case, its p ro c e ssin g is limited in P o la n d due to the la c k o f sufficient re c o v e ry fa c ilitie s. M oreover, one o f enterprises w hich d e a lt with processing th is slu d g e in the past was liq u id a te d owing to e c o n o m ic reasons. Sludge e x p o rt to a p o ten tial receiver in K azakhstan is im p o ssib le as a consequence o f th e p ro v isio n s of the Basel C onv en tio n .

3. T h e third case refers to the export of m ercury catalysts to Ukraine. T h e possibilities of co-operation w ith a Ukrainian receiv er w ere hindered because o f tw o reasons. First of all, U kraine is not a signatory o f the Convention. S econdly, fo llo w in g internal regulations the Ukrainian g overnm ent imposed a ban on hazard o u s waste import, including mercury containing waste.

P roblem s in waste export are the consequence o f th e following reasons: 1. A waste importing country must agree on taking and processing a specific am o u n t o f given waste. S om etim es, the authorities o f countries of destination delay in answering or do not answ er at all the q uestions directed to them by th e authorities of the waste exporting country, d e sp ite the fact that fo reig n contractors are interested in waste reception. T his refers, amongst others, to India, the Czech Republic, Italy.

2. T he transit countries m ust univocally agree on the transit of waste thro u g h th e ir territories. The M inistry o f Transport of a given country specifies the rou te, perio d , conditions of transit and protection required. Sometim es the country o f tran sit requires a “surety” for transit. This may be reg ard ed as a specific fo rm o f insu ran ce in case of possible disasters and environm ental detriments resu ltin g from transit. The rate o f surety can constitute a finan cial burden, especially fo r sm all and medium com panies. In order to get the tran sit permit one has to o ften w ait fo r two to six m onths, which can adversely influence the possibility o f sig n in g and concluding the contract.

3. The delay in economic activity connected with the necessity to get an export perm it from the Chief Inspector o f Environmental P rotection. The permit can be granted only when all the required documents are supplied.

The above mentioned difficulties negatively influence the scale and costs of activity o f econom ic subjects w ithin the sphere of waste export. An average period o f com pleting legal procedures and getting a perm it from the Chief Inspector o f Environm ental Protection to export waste is 4 - 6 m onths.

As fa r as the kinds and featu res o f economic su b jects actin g as waste im porters an d exporters are co n c ern e d , their significant differen tiatio n can be observed.

A w aste exp o rt permit is, on average, granted to 2 0 -3 0 econom ic subjects a year. The perm its can be divided into tw o groups:

1. The first group are waste producers, especially those generating metallurgical waste. They are mostly large enterprises. For this group of enterprises, the disposal and utilization o f industrial waste frequently becomes an im portant problem which is difficult to solve. In the case of these enterprises the significance o f a transaction is limited as far as economic calculation is concerned. An incom e is rather low, and is on the verge of profitability. The main problem is waste utilization. As there are no receivers within the country, an export of this type of waste is the only way to get rid of substances - noxious for the com pany - which are the result of technology applied. This situation refers mainly to metallurgical industry and such waste as: zinc, copper and brass dross, dusts and ashes containing non-ferrous metal oxides, sludges. The export of this waste is often connected with the necessity to pay extra costs for its storage and packing, with a type of the package used and transport mode. Som etim es an enterprise is forced to implement a new technological line which guarantees a proper way of preparation of the waste for export. These are mostly the solutions which are more environment-friendly; for example, hermetic receipt of ashes containing metal oxides. A sale for receivers within the country would not require such procedures, so the costs would be low er and the profit on a transaction would be higher. However, in Poland there are lim ited possibilities of recovery o f m any groups of waste. This results from the lack of appropriate processing technologies by domestic enterprises.

2. The other group of exporters are companies which deal w ith waste trade and waste collecting from numerous small economic subjects. T he latter are mostly small limited liability companies which specialise in the waste m etal trade. In this case the form erly mentioned phenomenon of the internal m arket "clearance" from non-ferrous metal scrap took place. Its mechanism was as follows: a lot of purchasing centres of non-ferrous metal scrap came into being, the prices rose, of that socio-pathological phenomena w ere recorded and the theft of parts of equipment and devices which were m ade of nonferrous metals and their alloys

-copper, tin, brass or bronze (e.g. electric traction w ires, telecommunication and railway wires) was recorded. T hese phenomena becam e notorious. In 1992, about 60,000 tons of non-ferrous m etals scrap were exported from Poland, which equals to 2.5 tim es the yearly dem and o f one of the largest com panies in Poland w hich deals w ith its recovery. Such large state-owned com panies were losing the m arket com petition in the range of the purchase of non-ferrous m etal scrap with com panies which w ere established only to conduct the export activity. A reason was that state com panies could not offer high purchase prices and they were less efficient in m arket activity then privately owned export oriented small companies. Large enterprises used domestic scrap, as its import was banned at that time and now it requires the permission of the Chief Inspector o f Environmental Protection. M oreover, potential foreign suppliers (e.g. Ukraine, B elarus) imposed a ban on the export o f non-ferrous scrap from their territories.

T o sum up, one can talk about two basic problem s connected with the implementation of a full control over hazardous waste export. The first one relates to a com m on, among environmental civil servants also, conviction that a limitation of w aste export is pointless (a so-called NIMBY - not in my backyard syndrome). The other problem is that a readiness to take waste by a foreign contractor is regarded as a permission to export the waste. The contractors are not aware of the fact that there may be some administrative constraints to this waste trade. A specific hindrance is connected with a deficiency of definitions o f some metal-bearing hazardous waste included in the regulation of the M inister Of Environmental Protection, Natural Resources and Forestry. On a list this regulation includes they are called “the waste containing a specific hazardous com ponent”, which means that every tim e it is indispensable to analytically test the m aterial. It refers for exam ple to alum inium dross that typically contains fluorides and copper and lead com pounds. In the regulation no 259/93 of the European Union the group of w aste w hose import to the Union requires a permit (a so-called “yellow list”) includes, am ong others, aluminium dross.

3.3. Waste import

A s reg ard s the reasons fo r operating and o rg a n iz a tio n o f waste im port o n e can distin g u ish :

- large enterprises w hose long term aim is to transport to Poland large am o u n ts o f waste which w ould be stored, removed, com busted etc. in Poland,

- sm uggling, “at the opportunity” of single w aste transport, being frequently done by companies which run a completely different k in d o f economic activity,

- enterprises whose aim is to purchase waste w ith a real economic value w hich can be used as secondary raw materials.

Polish enterprises were offered to im port several million tons of waste (5.2 million tons officially, several million beyond control) betw een June 1993 and December 1994. Most offers referred to secondary raw m aterials (paper waste, metal scrap, plastics waste, textiles waste). There were also som e offers to import industrial and municipal waste. The M unicipal Office from P iotrków Trybunalski and the “Izdebski” Co. Ltd. from Bielsko-Biała were offered to import and store municipal waste. The “Premex” company from Liechtenstein offered the import and combustion o f hazardous industrial w aste in a facility that has been built for this goal in Brzeziny. There were also som e offers to import debris to be stored in opencast/underground workings.

There are issued around 500 w aste import permits a year. Some of these permits are valid for more than one year. Enterprises w hich are engaged in waste im port are usually small, including one-person businesses. They may be divided into com panies which specialise in imports of:

- scrap w hich is the raw material fo r metallurgical industry,

- post-sulphide lye which is used as a binding agent indispensable for copper production (T he largest importer o f post-sulphide lye is the Industrial Group of Copper M ining and Metallurgy “P olsk a M iedź” Inc. This com pany imports

130,000 tons o f this substance a year.),

- cotton and flax waste which is the raw material for th e cotton industry (This is a rem ainder of the co-operation within the Council o f M utual Economic Aid. At that tim e cotton producers from the former Soviet U nion were not able (due to technological reasons) to utilise the raw material, so th ey collected it and sent it to P o land which specialised in its recovery and utilization as raw material in the cotton industry.),

- waste p ap e r which is a raw m aterial used in pulp and p a p e r industry, (It is an import o f marginal significance w hich constitutes 0.8% o f waste paper consumption in Poland). The largest importer is Pulp an d Paper Works “Celuloza” Inc. in Swiecie which im ports 40,000 tons o f th is kind o f raw material. A t present, waste paper supply is higher than dem and which is connected w ith demand for w aste p aper substitutes. T h is results from an insufficient technological preparation o f the works of pulp and paper industry to recover w aste paper,

- second-hand clothes (about a half o f all permits refers to this kind of activity). In Poland, they are segregated into clothes which can be further used. Subsequently, they are sent to popular retail shops (so-called “lumpex” shops). A remaining part of clothes is classified as unsuitable for further use. This latter group o f clothes should be sent back to an exporter. One suspects, however, that a part of these clothes remains in Poland and is sent to refuse dumps (legal) where storage charges are

low er than in the countries o f W estern Europe. Som etim es this waste is also stored illegally (moonlight dumping).

T h ere are also major im porters of other waste. T he m ost spectacular exam ples are such companies as: “Aspik” Co. Ltd. from Oława - 1 . 3 million tons of sew age sludge within two years, “G eoplan” Co. Ltd. from O pole - 1.4 million tons o f debris within seven years, “Koopol Przemyski” Co. L td from Przemyśl - 0.5 million tons of used railway clippers within a year.

E very year almost a thousand single waste transports, including dozens o f hazardous waste transports, are stopped at the border. T h e waste which is im ported contains first of all used goods (clothes, different equipm ent, especially hom e appliances, car wrecks, used tyres). Despite the lack o f permits, in 1994 over 4.4 thousand tons of waste, mainly plastics waste, were im ported into Poland. T his phenom enon is of a pretty constant character. The most attem pts of hazardous w aste im port w ere recorded in 1991 and at the beginning o f 1992, when the area o f the form er German Democratic Republic was cleared from old/withdrawn chemicals. At that time over a thousand tons of old pesticides, pain t and varnish waste w ere successfully transported into Poland. It was only revealed during a control within the country. The part of waste w as sent back to the place o f origin. According to the C hief Inspector of Environmental Protection, between June 1993 and D ecem ber 1994 only one transport of hazardous waste, a fuel nam ed “industrial coal C arbo Plus” to be used by municipal heating plants took place. In fact it was a mixture o f coal an d cooking-chemical waste. (8,000 tons of the fuel containing 1,000 tons o f w aste w ere delivered to Poland.)

W h ile granting the w aste permits, the C hief Inspector of Environm ental P ro tectio n takes into consideration the following directives:

1) is it possible to get a given waste in Poland? 2) is it possible to process this waste in Poland?

T h is falls in accordance w ith the rules o f a r tic le 53a of the S tatute on S h a p in g and Protecting th e N atu ral Environm ent. F ollow ing this artic le , a p e rm it m ay be granted if:

- th ere is an intention o f secondary use of w aste as raw materials,

- th e re is no possibility to get a proper am ount o f th is kind of w aste in th e c o u n try ,

- a given waste is not environm entally hazardous.

T h e permits issued are lim ited with respect to w aste kind and quantity, as w ell as the time period w ithin which the imports are to take place. There are no co n stra in ts concerning the origin of waste (both in term s of countries a n d sup p ly in g companies).

In o rd e r to illustrate the phenom enon under exam ination, one can reveal th e fo llo w in g data. Between June 1993 and Decem ber 1994, the Chief In sp e cto r o f

E nvironm ental Protection received 899 applications fo r granting waste import p e rm its (there were 263 ap p lica tio n s in 1993 and 5 2 6 in 1994). Their distribution b y kinds of waste im p o rte d is given in th e fo llo w in g diagram shown in F ig .4 . 3 0 0 y 2 5 0 -- 200 - - 150 -- 100 ■ ■ 50 -- 0 -253 159 65 5 9 51 51 structure U textile wastes □ fibre □ scrap-m etal □ w aste paper □ p lastic ■ g u m w a ste s

F ig .4 . Applications for w aste im p o rt permits in the years 1 9 9 3 -1 9 9 4 Source: data o f the C h ie f In sp e c to r o f Environm ental P ro te c tio n

By the en d o f 1994, 160 p erm its were granted, 158 applications were rejected due to a hazardous type o f w aste. The following m a jo r import permits were granted:

- about 108,000 tons of waste p ap e r intended for “In tercell” Co. Ltd from Ostrołęka, “C eluloza” Pulp and P aper W orks Inc. from Ś w ieck, International Paper Inc. from Kwidzyn, Kostrzyn P ap er Works, Piechow ice P ap er Works,

- about 60,000 tons of non-ferrous metal scrap (copper and its alloys, aluminium) fo r Industrial Group o f C opper Mining and M etallurgy “Polska Miedź” Inc., “Będzin” Ironworks, “Dziedzice” M etal Rolling Mill, “S kaw ina” Metallurgical Works, “K ęty” Light Metal Works Inc.,

- post-sulphide lye,

- plant fibre waste (cotton, flax).

Import perm its were not granted if the waste disposal w as environmentally arduous. This was particularly the case when bringing waste from abroad was connected w ith the potential or actual removal of a part o f w aste to dumping grounds or w hen the subject of waste im port application was the hazardous waste. Due to the last reason, nine cases o f im port of used railway clippers intended for

com bustion were stopped. In 140 cases the applicants gave up. About 200 procedures are suspended as the applicants did not reply to inquiries forwarded to them and there are no grounds fo r concluding the procedure.

T h e w aste import p erm it re la te d procedure la sts - on average - fo r a b o u t tw o m o n th s, depending on th e requirem ent to ta k e th e voivod’s and th e c o m m u n e ’s opinion and th e application’s c o m p le te n e ss. The protraction o f the p ro c e d u re may be c o n n e c te d with the fa c t th a t an applicant ask s f o r p e rm its fo r several e n te rp rise s in different v o iv o d sh ip s. A m ajor p ro b lem is also th e incom pleteness o f m an y applications.

S o m e applicants do not ta k e advantage o f all p e rm its. This p h en o m en o n m ay b e illustrated w ith d a ta presented in T a b le 1 below. T he m o st s p e c ta c u la r examples are “K ę ty ” Light M etals W o rk s, a jo in t stock c o m p a n y w h ich d id not import any alum inium scrap d e s p ite th e fact that it h ad a p e rm it to im port 12,000 to n s; the Industrial G ro u p o f C opper M ining a n d M e ta llu rg y “Polska M ie d ź ” Inc. which im p o rted o n ly 21 tons o f c o p p e r d e s p ite the fact it had a p e rm it to import 10,000 to n s; finally, ’’B aw tex” C o . Ltd. fro m Łódź which im p o rted only 81 tons o f c o tto n w aste although it w a s p e rm itte d to import 3,900 to n s.

T h e liberalization of P olish law within the sph ere of waste im port is d ep e n d en t on the following factors:

- technological possibilities o f waste processing a n d recovery,

- increasing social ac c e p ta n c e of this type o f econom ic (c o m m e rcial) a c tiv ity .

Table 1

Import o f se lec te d groups o f waste in 199 4 (in tonnes)

Kind o f waste A pplications P e rm its Import

W aste paper 126 355 101 805 38 452

P lant fibre waste 72 915 39 9 0 5 no data

R ubber waste 23 755 0 no data

C ullet 70 080 0 no data

M etallurgical w aste 20 0 0 0 3

Non-ferrous metal scrap 182 034 67 102 1 536

Steel scrap 10 300 3 0 0 85

Plastics waste 70 020 3 1 6 3 634

T im ber waste 599 974 0 no data

M unicipal waste 115510 0 no data

Debris 401 000 0 no data

Sew age sludge 708 300 0 No data

A big p ro b lem which hinders the thorough recognition o f th e phenomenon of illegal w aste im p o rt into Poland is th e lack of respective e stim a te s (statistics) of this phenom enon. Dozens of attem pts of illegal waste im p o rt to Poland are officially recorded at the border. It is difficult to specify its real range. Some cases are rev ealed after a long tim e (perhaps after several years).

The C h ie f Inspectorate of E nvironm ental Protection, th e B order Traffic Control A uthority of the Headquarters o f Border Guard and th e C hief Customs Office are engaged in the monitoring o f the transboundary w a ste trade.

3.4. The transit of hazardous waste

The constrain ts to the transit of hazardous waste were put into force together with those o f w aste export on 3 S eptem ber 1993. This tra n sit has a minimal range because the control of hazardous waste export in W estern Europe is becoming m ore and more rigid and the CEE countries have introduced import limitations. U ntil 1993, the natural environment in P o land w as exposed to dangers connected with hazardous w aste transit from the E ast to the West. This phenomenon dim inished after several cases had been rev ealed and they had been labelled as having a political ch aracter in Germany and th e Commonwealth of Independent Countries.

In 1994 a transit of oiled cleaner fo r combustion in the h ea tin g plant near St. Petersburg (w ithout the consent o f the Russian authorities) an d a transit of old chemicals to Belarus (the import o f which was hindered by the German authorities) w ere revealed.

A posterio ri, two cases of the illegal transit of hazardous waste (metal-

bearing w aste) from the East to the W est through the territo ry o f Poland were revealed. A n intensive transit o f non-hazardous waste (rubber, plastics) from Germany to Lithuania, Latvia, B elarus, Ukraine, G eorgia, Kazakhstan and Kirgisia is b ein g observed in turn. D espite the fact that P olish regulations do not allow to control this type transit, it is known that the transit takes place at the consent o f the authorities of the im porting countries w hich is the fundamental principle o f th e transboundary w aste transit.

4. FINAL REMARKS

The basic econom ic results of the Basel Convention ca n be divided into m acroeconom ic and microeconomic ones. The m acroeconom ic results are:

- changes in export and import directions, - sectoral movements,

- technological changes consisting in the im plem entation of more e n v iro n ­ m en tally friendly technologies.

M a jo r microeconomic results are as follows: - technological changes in individual companies,

- product mix m odifications due to the lack o f a sufficient amount o f w a ste to be processed, increase in c o st and changes in profitability,

- b reach of some co-operative links,

- application of more environm entally friendly w aste reception, packing a n d tran sp o rt technologies,

- production cost increase as a consequence of: • implementation of new technologies,

• implementation of new /im proved waste recep tio n and packing technologies,

• price rise for raw m aterials which are waste at th e same time

- th e protraction o f tim e w hich is necessary to conclude contracts o f w a ste trade,

- a necessity to bear the co st o f storage if it is im possible to export the w aste.

REFERENCES

“A u ra” (1 9 8 9 ), no. 7, p. 16.

B erstorf, A ., Pucket, J. (1990): Polska, In w a zja śm ieci [Poland, R e fu s e Invasion], Raport G re en p e a ce .

[The R e p o r t by Greenpeace],

D zien n ik i U staw : 1994, no. 19 pos. 89; 1989, no. 26, pos. 139; 1 9 9 6 , no. 40 pos. 183; 1996, no. 4 9 pos. 19 6 ; 1993, no. 76 pos. 362.

Z a p o b ieg a n ie importowi odpadów d o Polsk i. Raport (lipiec 1989 - sty czeń 1991) [Prevention fro m w a ste im p o rt to Poland. A re p o rt (July, 1989 - January, 1 991)]. M inistry o f E n v iro n m e n ta l P ro te c tio n , Natural R esources an d F o restry , Warszawa.