The Inflation Reduction Act: A pivotal opportunity to push back against false solutions

The Inflation Reduction Act (IRA) channels $270 billion in tax credits for climate investments but raises concerns about incineration—a false solution to waste disposal that could generate 637.7 million tonnes of CO2e emissions over two decades, further harming the environment and disadvantaged communities.

By: Marcel Howard (Zero Waste Program Manager, US/Canada) and Jessica Roff (Plastics & Petrochemicals Program Manager, US/Canada)

Key Highlights

  • The Inflation Reduction Act (IRA) is primarily a tax bill. Of the promised $369 billion in climate investments, $270 billion will come in the form of tax credits1
  • Incineration is one of the most polluting and expensive waste disposal systems. Industry2 often greenwashes incineration as  “waste-to-energy”3 despite producing minimal amounts of usable energy and massive energy input
  • By measuring the lifecycle climate impacts of incineration accurately, the Department of the Treasury can deny polluting facilities billions in tax credits intended for actual sustainable energy solutions and ultimately delay or block their construction or expansion
  • If industry succeeds in propping up incinerators for 20 years, they will produce 637.7 million tonnes of climate-change-inducing CO2e emissions and further exacerbate toxic pollution and environmental racism4
  • Pairing new subsidies for incinerators with incentives for EVs is perverse
  • Turning waste, including fossil fuel-derived plastics, into jet fuel is dangerous and does not decarbonize air travel 
  • Two-thirds of US incinerators are located in states that include incineration in their renewable energy portfolio
  • The IRA allocated billions of dollars in lending subsidies specifically meant to drive reinvestment in low-wealth and environmental justice communities. Environmental justice, frontline, and fenceline groups should consider applying for these IRA lending programs


The United States (US) has a waste problem compounded by a plastic problem. For decades, we have been handling our waste in ways that harm communities, our climate, and the natural world. Federal, state, and municipal governments continue to site waste incinerators of all forms in Black, brown, indigenous, and lower-wealth communities — plaguing them with decades of harmful air emissions, high levels of greenhouse gasses, toxic waste, accidents, and other health and safety-related concerns. From fossil fuel extraction to final waste product disposal, the entire production process damages these communities and numerous others. Across the board, incineration is one of the most polluting and expensive waste disposal systems.

Industry often greenwashes incineration as  “waste-to-energy” despite producing minimal amounts of usable energy and leverages this greenwashing to access billions of dollars in federal, state, and local green, renewable, and sustainable energy subsidies and tax breaks.
Against this backdrop, the Biden Administration signed the Inflation Reduction Act (IRA) into law on August 16, 2022. Many agencies are already approving and funding false solutions under the IRA. The Department of Energy (DOE) is funding new carbon capture programs at nearly $3.5 billion and allocating $1.2 billion of Justice40 money to develop direct air capture facilities. We are in a pivotal moment where the US must decide if it will take critical steps to lower greenhouse gas and toxic emissions and move toward a truly sustainable future or will continue to subsidize the dirtiest industries to annually emit millions of tonnes of new CO2 and other dangerous air pollutants.

IRA Overview

The Biden Administration claims its 755-page IRA is the most comprehensive climate bill in US history that is supposed to “make a historic commitment to build a new clean energy economy.” Its provisions on climate change mitigation, clean energy, and energy innovation dominate headlines, as it raises nearly $800 billion from multiple sources. President Biden said, “With this law, the American people won and the special interests lost.” To ensure this is true and stop the incinerator lobby and other special interests from cashing in on a new pool of taxpayer money, the federal government must implement critical changes to its business-as-usual model.

The IRA is primarily a tax bill. Of the promised $369 billion in climate investments, $270 billion will come in the form of tax credits. Before the IRA, Congress awarded tax credits to specific technologies (including incinerators) regardless of greenhouse gas emissions or community harm. Beginning in 2025, however, their eligibility will depend entirely on the Department of Treasury (Treasury) determining that they are zero-emission technologies. By measuring the lifecycle climate impacts of incineration accurately, Treasury can deny polluting facilities billions in tax credits intended for actual sustainable energy solutions and ultimately delay or block their construction or expansion.

Threats & False Solutions

Lifelines to Old, Failing Incinerators

Corporate polluters are corrupting the IRA, lobbying to weaken its rules and definitions to qualify for billions in new subsidies to expand and retrofit existing incinerators, most of which have been operating for an average of 32 years. It is nearly impossible to construct new conventional incinerators due to cost and community opposition, so industry is focused on expansion and modification. If industry succeeds in propping up incinerators for 20 years, they will produce 637.7 million tonnes of climate-change-inducing CO2e emissions and further exacerbate toxic pollution and environmental racism. 

Codifying False and Greenwashed Definitions

The incinerator lobby’s goal is to maximize subsidies, profits, and expansion and to use the IRA and other climate bills as a subsidized path to an undeserved sustainable image upgrade. In the context of the IRA, federal agencies such as the Treasury, the Department of Energy (DOE), and the Environmental Protection Agency (EPA) can either categorize incineration as the dirty, expensive, polluting process it is or bolster industry’s claims that incineration produces sustainable energy. If the federal government supports industry’s definitions in the earliest stages of IRA implementation, they will frame agency action and provide billions in tax credits, likely being codified for many climate laws, including the IRA.

IRA Breakdown & Opportunities for the Incinerator Lobby 

The incinerator lobby is working to undermine all aspects of the IRA, specifically focusing on (1) the Renewable Fuel Standard (RFS), (2) Sustainable Aviation Fuel (SAF), and (3) IRA lending programs. 

Renewable Fuel Standard (RFS)

In consultation with the Department of Agriculture and DOE, EPA implements the Renewable Fuel Standard (RFS) program. The RFS program is a “national policy that requires a certain volume of renewable fuel to replace or reduce the quantity of petroleum-based transportation fuel, heating oil, or jet fuel.” The four renewable fuel categories under the RFS are biomass-based diesel, cellulosic biofuel, advanced biofuel, and total renewable fuel. Although long limited to liquid fuels like ethanol, Biden’s EPA is in the process of allowing electricity from certain types of bioenergy to generate eligible credits. Under the current proposal, electric vehicle manufacturers would contract with power producers to generate highly profitable RFS credits.

Pairing new subsidies for incinerators with incentives for EVs is perverse. While support for electric vehicles is vital, it must not be fueled by dirty energy nor sacrifice frontline and fenceline communities. Incinerator interests recently launched a lobbying campaign to secure these incentives. Fortunately, EPA is not required to allow incinerator electricity into the program and has recently tabled an industry-backed eligibility proposal. But, only public pressure on Biden’s EPA and key Administration climate deciders will ensure they don’t approve such proposals.

Sustainable Aviation Fuel (SAF) 

As one of the most generous IRA incentives, the Sustainable Aviation Fuel Tax Credit (SAF) poses an urgent environmental justice concern. The credit increases in value for lower lifecycle emissions fuels. Treasury’s implementation will determine if this approach succeeds or fails. Industry interests are pushing to make the credit friendlier– and more lucrative–to a new generation of incinerators masquerading behind greenwashing like “pyrolysis,”  “chemical or advanced recycling,” and “plastic-to-fuel.” Turning waste, including fossil fuel-derived plastics, into jet fuel is dangerous and does not decarbonize air travel. 

Although the new aviation production tax credit theoretically excludes petroleum-based feedstocks like plastic, industry is pressuring the Administration to interpret the law to maximize benefits for incineration-based aviation fuels. President Biden and Treasury must decisively determine that plastic-derived fuel — including that derived from pyrolysis oil or any other product of chemical recycling/pyrolysis/gasification — is ineligible for these tax credits.

Lending Programs

The IRA allocated billions of new dollars to EPA and DOE, in particular, to expand existing lending programs and launch entirely new ones. Like the rest of the IRA, these programs’ climate and justice benefits depend on implementation. EPA is in charge of the new Greenhouse Gas Reduction Fund (GGRF), arguably the most important non-tax provision of the IRA. Worth $37 billion, it will be divided into three separate programs. EPA released broad, unenforceable guidelines in April 2023, suggesting they will focus lending on distributed generation, building decarbonization, and transport. These guidelines will not ensure the money is appropriately allocated, so EPA must prioritize applicants working on proven zero waste approaches. 

DOE is in charge of The Energy Infrastructure Reinvestment (EIR) Program, a new loan guarantee program with $250 billion that must be spent before 2026. It can fund energy infrastructure upgrades and the reopening of defunct energy infrastructure, both of which industry could coopt to support their ongoing incineration and chemical recycling plans. DOE must refuse to consider any incinerator applications to guarantee industry does not use loopholes to access clean energy tax credits. 

In July, the Republican-led House Appropriations Committee passed the Interior, Environment, and Related Agencies budget for Fiscal Year 2024. Their budget supports chemical recycling while cutting massive amounts from EPA’s budget and the IRA’s environmental justice efforts, including a nearly $4 billion EPA budget cut (a 39% reduction over 2023), reneging on the IRA’s $1.35 billion promised in environmental and climate justice grants.

Call to Action 

The incinerator lobby is so desperate for money and a government-greenwashed reputation that they launched a new, big-money–astroturf5 network, including DC power brokers and local government enablers. The combined movements6 for climate justice don’t have industry money, but we have people power, the truth, and a prime opportunity to fight against this industry push. There are three key areas in which to counter industry’s agenda: (1) Treasury engagement, (2) state-level renewable portfolio standards, and (3)  IRA lending subsidies. 

Treasury Engagement

As the Washington Post exposed in May 2023, the incinerator industry is among polluting industries racing to position themselves as green to access billions in subsidies and tax credits. In the last year alone, industry launched two trade groups to push their message: the Waste-to-Energy Association and the Circular Economy Coalition. Both have made comments to access benefits for incinerators under the Inflation Reduction Act, or considered prioritizing it. Industry is dedicated to getting Treasury to qualify incinerators as renewable, despite overwhelming evidence that incinerators are extremely polluting. 

It is critical to engage with Treasury as it develops policies, rules, regulations, and procedures to implement the IRA. If Treasury determines this most costly and polluting form of energy is zero emission, it will set an appallingly low bar within the IRA that will exacerbate rather than address the climate crisis, perpetuating and compounding the issues we currently face, and permanently scarring the Biden Administration legacy.

State-level Renewable Portfolio Standards 

The IRA has broad implications, reaching far beyond the federal level of government. Defeating federal government incinerator giveaways in the IRA and other federal climate initiatives will strengthen communities fighting state and local government incinerator giveaways. Currently, different states provide a patchwork of policies and incentives related to incineration. Perhaps most notable are state Renewable Portfolio Standards (RPS). Twenty-nine states, the District of Columbia, and four US territories have an RPS. Each RPS has its own renewable electricity targets, defines what technologies qualify as renewable, designates particular technologies as higher or lower tier within the mix, and enables the trading or sale of renewable energy credits. Two-thirds of US incinerators are located in the 26 US states and territories that include incineration in their renewable energy portfolio. Showing industry’s power, scope, and connections at both the federal and state levels of government. It also shows an entrenched mentality that incineration is a clean energy solution. It is imperative that the IRA does not follow suit.

IRA Lending Subsidies

Along with Treasury engagement, environmental justice, frontline, and fenceline groups should consider applying to IRA lending programs. The Greenhouse Gas Reduction Fund (GGRF) and DOE’s Energy Infrastructure Reinvestment (EIR) Program offers billions of dollars for projects specifically meant to drive reinvestment in low-wealth and environmental justice communities. Both programs provide an opportunity to fund proven zero waste solutions that push back against false solutions, like incineration. 

The Greenhouse Gas Reduction Fund (GGRF): The GGRFis a $27 billion investment program designed to achieve the following: “ (1) Reduce greenhouse gas emissions and other air pollutants;  (2) deliver benefits of greenhouse gas, and air pollution-reducing projects specifically to low-wealth and disadvantaged communities; and (3)  mobilize financing and private capital to stimulate additional deployment of greenhouse gas and air pollution reducing projects.” The GGRF is being implemented via three grant competitions, which include: (1) the National Clean Investment Fund, (2) the Clean Communities Investment Accelerator, and (3) the Solar for All Fund.”7 

The National Clean Investment Fund: “The National Clean Investment Fund competition will provide grants to 2-3 national nonprofit clean financing institutions7 capable of partnering with the private sector to provide accessible, affordable financing for tens of thousands of clean technology projects across the country.To learn more about the program and how to apply, visit Application packages must be submitted on or before October 12, 2023, at 11:59 PM (Eastern Time) through

The Clean Communities Investment Accelerator: “The Clean Communities Investment Accelerator competition will provide grants to 2-7 hub nonprofits that will, in turn, deliver funding and technical assistance to build the clean financing capacity of local community lenders working in low-wealth and disadvantaged communities so that underinvested communities have the capital they need to deploy clean technology projects.” To learn more about the program and how to apply, visit Application packages must be submitted on or before October 12, 2023, at 11:59 PM (Eastern Time) through 

DOE Energy Infrastructure Reinvestment (EIR) Program: “The EIR Program provides $250 billion for projects that retool, repower, repurpose, or replace energy infrastructure that has ceased operations or enable operating energy infrastructure to avoid, reduce, utilize, or sequester air pollutants or greenhouse gas emissions.” To learn more about the program and how to apply, visit Individuals interested in applying should request a no-cost pre-application consultation with a member from DOE’s Loan Programs Office. 

USDA Empowering Rural America (New ERA) Program: “The ERA program provides $9.7 billion for projects that help rural Americans transition to clean, affordable, and reliable energy intending to improve health outcomes and lower energy costs for people in rural communities.” To learn more about the program and how to apply, visit Individuals interested in applying should submit a Letter of Interest (LOI) by September 15, 2023.  


On paper, the Biden Administration’s IRA may be the most comprehensive climate legislation in history, but it also has the immense potential to be a climate destroyer. We are at a crossroads where the Administration and all other levels of government have the power to use the IRA for its stated purpose to “confront the existential threat of the climate crisis and set forth a new era of American innovation and ingenuity to lower consumer costs and drive the global clean energy economy forward.” To make the promise a reality, the Administration — including all the executive agencies, particularly Treasury, Energy, and EPA — cannot succumb to industry greenwashing lobbying.

The Biden Administration must accurately measure the lifecycle climate and health impacts of all forms of incineration and its products (including pyrolysis and gasification) and unequivocally determine that it is not a source of clean energy or a safe way to make jet fuel. It will be up to our ever-expanding movement to hold the Administration accountable to the ideal of the IRA and ensure it is not another greenwashed handout to industry — and that its tax credits and funding go to sustainable solutions that benefit the Black, brown, indigenous, and low wealth communities as it initially intended. 

  1. As a tax bill, the categories and definitions of processes are critical because they will determine if a process is covered under it. Historically, there have been some good and some bad determinative definitions (including currently for chemical recycling). ↩︎
  2.  Industry refers to the plastics, incinerator, fossil fuel, and chemical industries who are all perpetuating the plastic waste problem ↩︎
  3.  Industry labels waste-to-energy (WTE) a number of different ways including: plastic-to-fuel (PTF), plastic-to-energy (PTE), refuse-derived-fuel, etc. ↩︎
  4.  This is entirely dependent on if the federal government places incinerators into favorable categories for purposes of massive amounts of tax credits and de facto subsidies. ↩︎
  5.  Astroturfing is the practice of hiding the sponsors of a message or organization (e.g., political, advertising, religious, or public relations) to make it appear as though it originates from, and is supported by, grassroots participants. ↩︎
  6.  The movement includes, but is not limited to – and is always open to expand – the environmental justice movement, climate movement, conservation movement, public health movement, plastics movement, etc. ↩︎
  7. The deadline for the Solar for All Competition has recently been extended to October 12, 2023. Please review this link for additional information:,%2C%20Tribal%20governments%2C%20municipalities%2C%20and ↩︎

Interview with Mahesh Nakarmi by Dan Abril

Mahesh Nakarmi, professionally a Disaster Risk Management Specialist, with a qualification of Masters degree in Civil Engineering  underwent a transformative experience that led him to embrace Zero Waste. While as a co-founder of the National Kidney Center, he personally encountered the improper disposal of hazardous waste, posing significant risks to communities and waste workers. Witnessing this first hand, he felt an urgent need to take action and promote improved methods for health care waste management which was neglected during those days.

He co-founded Health Care Foundation Nepal (HECAF) in 1994 to address this and ultimately, Mahesh’s efforts in advocating for proper health care waste management prevailed. In 1999, through his efforts, the NKC became the first hospital in Nepal to disinfect the waste generated during care of the kidney patients by using autoclave as a non burn technology. So when he developed a complete health care waste management system at the center, it ultimately  resulted in the reduced quantity of waste  being sent to the landfill. His path took another turn upon meeting GAIA Asia Pacific and Health Care Without Harm. Through these organizations, Mahesh learned about non-burn and no harm approaches including Zero Waste principles and realized that what he was doing is already  Zero Waste. 

In 2020, HECAF became the Health Environment and Climate Action Foundation (HECAF360) and today has a team of 20 people coming from diverse backgrounds such as engineering, environmental science, environmental engineering, biomedical engineering, nursing, public health, and healthcare. 

We had the opportunity to chat with Mahesh and we discussed HECAF360’s journey in becoming a Zero Waste pioneer in Nepal. 

The HECAF360 Team. (Photo courtesy of HECAF360)

What are HECAF 360’s top priorities?

We work on a lot of areas and we address the gaps. These include Zero Waste, healthcare waste, hygiene, and climate resilience. It’s all interrelated. When we talk about menstrual hygiene management, we talk about women’s health and also talk about waste management. But mainly it’s all about Zero Waste and advocating for zero toxins and zero burn approaches to waste management. 

We understand that waste management is a long-term process that cannot be resolved within a short period but by adopting a Zero Waste approach we will achieve our ultimate goal of not having to send any waste to landfills. To realize our objectives, we are trying to define the role of individual citizens in the management of the waste that they generate daily, so we are exploring smart waste management solutions. Through this, we ensure that different types of waste are appropriately handled: recycling is directed to designated recycling centers, landfill waste is appropriately disposed of in landfills, and food waste is routed to food processing facilities to be converted into compost. 

An essential aspect of this system is it provides employment opportunities to waste pickers and integrates them into the waste management process.

Photo courtesy of HECAF360

What are HECAF360’s ongoing campaigns?

We have campaigns on plastic waste and water-related campaigns but everything leads to Zero Waste. You simply cannot advocate for Zero Waste without taking these issues into account. When we conduct our education campaigns in hospitals and government offices, we talk about Zero Waste and we talk at all levels from kindergarten and up, as well as from municipality to federal ministries.

What are HECAF360’s biggest accomplishments/achievements?

We have a lot of stories to share! We’re proud to have introduced Zero Waste not only in hospitals but to the rest of Nepal. We are continuously creating Zero Waste coalitions. We do not only collaborate with hospitals but through coalitions, we also bring together schools, businesses, INGOs, the government, and those working on recycling and upcycling. 

Photo courtesy of HECAF360

What challenges are you currently facing and how is the organization impacted by the COVID crisis?

In 2020, we only had a staff of about 6 to 8 people. At that time, Nepal had not yet experienced the impact of COVID-19. Then, the Minister of Health reached out to us for assistance during the evacuation of 175 students studying in Wuhan, where the pandemic began.

We responded to the call and we took on the challenge and designed a comprehensive waste management system in collaboration with the army, police, the civil aviation authority, and airlines. Our efforts extended from managing waste at airports and handling quarantine centers. 

In this endeavor, we partnered with the Tzu Chi Foundation in Taiwan to facilitate the donations, which involved 10 charter flights. However, there are several challenges in the process. To provide support for waste management in hospitals and donate essential items like ventilators, oxygen concentrators, High Flow Nasal Cannula, and personal protective equipment (PPEs), we were required to have special permission from the government. Though it was a significant challenge, we persevered, and worked closely with authorities and handed over all these items to the Ministry of Health and Population.

With the leadership of the Ministry of Health and Population and with the support of the World Health Organisation (WHO) in Nepal, GiZ Nepal, and the Swiss Government; the HECAF360 team worked at the government health facilities around the clock to improve waste management systems.  Working around these challenges not only strengthened our resolve but also made life more interesting. Despite the risks brought by the pandemic, our staff felt a sense of fulfillment in being able to contribute to the community by providing food relief for needy people in different communities. It provided an opportunity to learn and collaborate with our waste pickers. We were successful in providing a little support to the waste pickers.

Overall, the experience of managing waste during the COVID-19 crisis offered unique learning experiences as we worked closely with both government offices and local communities.

Photo courtesy of HECAF360

What are the main environmental issues your country or region is facing?

The current waste management situation is connected with various environmental issues, including landfills, air pollution, and river pollution, these are related to the broader problem in waste management. Our specific concern now are the chemicals leaching out of Nepal’s landfills, this has worsened the waste management issue. This has directly impacted the public health of the people residing in surrounding communities near the landfill sites. So we need to find a better solution to minimize the quantity of waste to be disposed of at the landfill by integrating waste into a circular economy through the Zero Waste Cities program. And we are actively collaborating with the local, provincial, and federal governments in search of solutions.

How do you see your HECAF360’s work evolving in the next years? 

We have identified numerous areas to focus on, and we still have many plans in progress, including improving the way we communicate our work. Our goal is to be more proactive in implementing Zero Waste systems throughout the country.

Recently, the Ministry of Health began discouraging the use of incinerators in hospitals and encouraged the use of non-burn technologies. This indicates a growing awareness and commitment to the Zero Waste approach. As such, in the coming years, we look forward to Nepal becoming more Zero Waste.

Do you collaborate with partners in other regions? If so, how?

We establish partnerships wherever we go. We want to learn from partners and they want to learn from us. One example is when we went to Penang in Malaysia. At the Tzu Chi Dialysis Center in Penang,  Tzu Chi Foundation Volunteers run a waste recycling program  and the income from this program supports the operation of center and their outreach to communities in need. 

How does your work on waste relate to social justice?

We call on our right to health and a clean environment and we are also advocating for a just transition for waste pickers. Despite the challenges, we continue to push for the government to act. 

Who do you admire most in the environmental work (in your country or in the world)?

There is a lot of good environmental work being done in other countries. I have a lot of admiration for environmental groups in the Philippines for succeeding in banning incineration. There is also a lot of work being done in reclaiming rivers and bringing them to life again. That is commendable. 

HECAF360 always believes in action. That’s why we have action in our name. We don’t do a lot of writing or publishing. We don’t post a lot on social media but we have action. We have zeal for what we want to do and we will continue to do so until we bring the smile back. 

Call for funding: 

Currently, HECAF360 lacks the necessary resources to fund their policy work. Support HECAF360 and their goal of achieving a Zero Waste Nepal, email HECAF360 at or visit their website at

By Aminat Ibrahim, SRADeV Nigeria

Following a series of online meetings towards hazardous chemicals and pesticide export ban, the European Environmental Bureau (EEB) hosted a face-face Advocacy and Capacity-building Campaign meeting with NGOs from the global south in Brussels, Belgium between the 12th – 14th July, 2023. 

Stakeholders and partners at the event consisted of EEB consultants, the EU Parliament and NGO representatives such as SRADeV Nigeria, Community Action Against Plastic Waste (CAPws), Center for Public Health and Environmental Development (CEPHED), Journalists for Human Rights (JHRMK), PAN Europe, Nanny Africa; across countries including Nigeria, Cameroon, Zambia, Benin, Senegal, Sierra-Leone, Kenya, South Africa, North Macedonia, Nepal, India and Vietnam. 

The first two days of the hybrid event were an avenue for partners to share experiences on activities carried out in their organizations, building communication capacities, providing support on database information and also review and analyze a joint campaign to ban the export of hazardous chemicals in the form of pesticides to the global south.

As part of the agenda for the event, there was a visit to the European Parliament on the 14th of July to lend a voice to introduce a mechanism prohibiting the production and/or exportation of hazardous pesticides already banned in the EU- to protect non-EU countries from their negative effects on humans and the environment. 

Dr. Leslie Adogame, the Executive Director of Sustainable Research and Action for Environmental Development (SRADeV Nigeria), attended the meeting as a Global South representative. In his speech at the Parliament House, he called for the need to work on the three pillars of the framework for sustainable development (people, environment and profit). The GAIA Africa member representative also reminded the relevance of discontinuing to place profit over the health of people and the environment and that what is not good for the global north can never be good for the global south. 

Dr. Leslie finished by making an appeal, as quoted below:

“I hereby make this appeal on behalf of all Nigerians towards not just the ban of export of these chemicals from EU-member states to the global south but also to stop the production of these chemicals and pesticides in entirety. AS INJUSTICE TO ONE IS INJUSTICE TO MILLIONS.”

As part of the next steps to back up the Parliament visit, a regulation to “Stop Toxic Exports” was also proposed to support the reduction of waste dumping in global south countries.


Opinion By Eldad Kwaku Ackom, Green Africa Youth Organisation

The Green Africa Youth Organization, as part of its campaign against incineration and plastic pollution, partnered with the All-Africa Students Union (AASU) to march for climate action at Ghana’s 66th Independence anniversary celebration on 06 March 2023. Highlighting the disastrous impact of climate change on the environment and the lives of people, echoing youth’s voices in climate action, and orientating the hearts and minds of the public and elected leaders to act with urgency. This formed part of its national sensitization program for the year and was strategic to reaching various categories of stakeholders and leaders. 

On Independence Day, we reflect on the nation’s progress from the era of colonialism and what lies ahead. Generally, the focus has been on classical areas of Ghanaian History, culture and economy. However, one issue that undermines all the key areas of society deserving attention is the problem of pollution from the endemic plastic lifestyle and widespread open burning.

Contrary to the enthusiasm around independence, developed countries exporting their waste and toxic materials to developing countries like Ghana, mostly in the form of used and often broken equipment, unveils a demeaning form of colonialism which is often overlooked. Waste colonialism is a long-standing issue, typically in the case of Agbogbloshie and other dumps in Accra, climbing to the “enviable” spot of being the world’s largest e-waste dumps and a major health and environmental hazard. 

By 2018, roughly 13,000 tons of plastic waste were imported each month, mainly illegally burned. Meandering through the economy is a quick fix to various needs in society today. Despite government efforts like outlawing the import of electronic waste and working towards a ban on plastic bags, plastic waste litter our beaches, rivers, and streets, endangering the health and well-being of our communities, wildlife and ecosystems. 

It is quite ironic for any country to celebrate 66 years of independence without a robust plan to break free from plastics. 

False solutions like incineration with the alluring energy generation tag have received immense welcome. Even as Governments discuss these, the practice of burning in households, industrial facilities and even hospitals has created a sense of normalcy to the consequences on life and the environment. 

From recent media reports, emissions and airborne pollutants have aggravated respiratory conditions and other health issues. The Ghana health service can attest to the exponential cases and risks of respiratory-related instances linked to the falling ratings of the country on the air quality index.

As a duty to our heritage, we must commit to true independence by prioritizing measures to reduce plastic waste, promoting sustainable consumption patterns, implementing effective homegrown strategies, legislating a clear path to holding corporations accountable and encouraging them to take responsibility for their waste.

We must break the waste colonialism cycle and reject short-sighted solutions like incineration and instead work towards a more sustainable future for all Ghanaians and Africa at large.


UNWRAPPED es un proyecto del que GAIA ha participado activamente y que tiene como objetivo crear conciencia en todo el mundo sobre los riesgos para la salud humana que plantean los plásticos y otros materiales de envasado de alimentos. En el marco del proyecto, se desarrollaron herramientas que ilustran dichos riesgos.

Las 9 cartillas informativas que compartimos a continuación, presentan datos y cifras sobre cómo los envases desechables pueden ser perjudiciales para la salud humana. Además, hacen un llamado a que las empresas y los responsables de tomar de decisiones pongan fin a los envases de un solo uso y adopten un enfoque de precaución ante el uso de sustancias químicas nocivas que se traspasan desde los envases a los alimentos y causan graves consecuencias en la salud humana.

  1. Productos químicos peligrosos en envases de alimentos – una amenaza a la salud humana
  2. Sustancias químicas en envases de alimentos: recomendaciones políticas para proteger la salud
  3. Los envases reutilizables protegen la salud pública y el medio ambiente
  4. Amenazas contra la salud humana debido a los micro plásticos
  5. Contenido reciclado en embalajes de comida y la exposición a químicos tóxicos
  6. El Covid 19 y los envases
  7. Plásticos usados en envases de alimentos
  8. Glosario: terminología para envases de alimentos
  9. Resumen de las sustancias químicas prioritarias y de mayor preocupación

Proyecto desarrollado en colaboración entre: UPSTREAM, Zero Waste Europe, GAIA, Plastic Solutions Funds y Passport Foundation.

¿Cómo abordamos el tema en nuestra región?

En el contexto del lanzamiento del proyecto Unwrapped en América Latina y el Caribe, los días 7 y 14 de abril desarrollamos el taller “Agroecología: un camino para desplastificar nuestros alimentos”, con el  fin de conectar el envasado de alimentos y la salud con elementos de interés y culturales propios de América Latina y abrir la discusión y compartir de experiencias en temas como la búsqueda de la soberanía alimentaria, el desarrollo de estrategias como la economía de trueque, regenerativa, local, estrategias basura cero y cómo se podrían desarrollar más experiencias en esta línea.

Javier Souza, facilitador del espacio, diseñó como ejes principales 1) analizar las sustancias químicas presentes en los alimentos ya las usadas en el proceso de producción , en el empaque y aquellas que están presentes, que migran, desde los envases, 2) analizar los efectos en la salud de los contaminantes químicos utilizados en la producción agraria y los presentes en los envases frecuentemente utilizados y 3) analizar la posible sustitución/eliminación de envases y su reemplazo por envases biodegradables, entre otros. Las y los participantes discutieron sobre sistemas de trazabilidad de los alimentos, formas de recuperar conocimientos, saberes, ideas relacionadas con la producción agroecológica y la economía social y solidaria y el comercio justo.

En América Latina, el uso de envases retornables sigue siendo parte de la vida cotidiana en muchos lugares, además que una cultura de uso de productos naturales para el envasado de alimentos está arraigada en diversas culturas de la región.  Por otro lado, existe un amplio conocimiento sobre prácticas agroecológicas y un deseo generalizado de avanzar hacia una soberanía alimentaria que ponga valor en hábitos alimentarios sanos y propios de la región, así como formas locales de producción. Sin embargo, todos estos hábitos se ven profundamente amenazados por la agresiva comercialización y entrada de la industria de “usar y tirar”, asociada a alimentos procesados y a la comida rápida. 

Es urgente comunicar sobre la trazabilidad de las sustancias químicas utilizadas en los envases a lo largo de la cadena de suministro y restringir el uso de sustancias químicas peligrosas en envases en contacto con alimentos. La adopción de normativas que apoyen la transición hacia envases seguros para la salud, reutilizables y rellenables debe ir acompañada de una clara promoción hacia sistemas de producción y distribución de alimentos locales y sostenibles. 

World Health Day, Apr 7, 2021—The Global Alliance for Incinerator Alternatives (GAIA) Asia Pacific, together with #breakfreefromplastic, Greeners Actions (Hong Kong), Health Care Without Harm-Southeast Asia, and UPSTREAM warn the public of another pandemic waiting to happen: diseases borne out of toxic chemicals present in most food packaging.

“The dramatic rise in the use of single-use plastics in food service during the pandemic has been fueled by a false  industry narrative that single-use plastics (SUPs) prevent virus transmission,” said Miriam Gordon, UPSTREAM Policy Director in a media briefing on The Unwrapped Project: Exposing the health risks of plastics + food packaging chemicals. She added, “COVID-19 research demonstrates the virus is transmitted from aerosolized droplets not by touching contaminated surfaces and the idea that plastic packaging makes us safer lacks any scientific basis.”

While SUPs are being marketed as the safer option, The Unwrapped Project is exposing that there are over 4,000 chemicals present in plastic packaging and many are known to be hazardous to human health. (1) 

In test samples from 19 locations world-wide, 93% of the bottled water samples contained micro-plastics with an average of 10.4 plastic particles per liter.  Unknown to many, micro-plastic can translocate across the gut and enter the circulatory system, accumulate in the major organs, and travel through the lymph system ending up in the liver and spleen. When inhaled micro-plastics, depending on size and shape, can travel through the respiratory system, become lodged in the lungs, and possibly translocate to other parts of the body.

“During the pandemic, we encourage people to bring their own food boxes when ordering takeaways. The risks of contracting the virus come from respiratory contact. Using SUPs does not mean you are better protected from the virus,” said Michelle Chung, Senior Project Officer and lead of the ST0P campaign at Greeners Action in Hong Kong. “With our ST0P campaign, we educate consumers and business owners (restaurants and malls) alike that there are safer options to use other than SUPs that end up in landfills.”

The health care sector is another sector that has seen an increase in single-use plastics use during the pandemic.  “While there are essential single-use plastics such as IV lines and syringes being utilized in the health care sector, there are also a number of non-essential ones like disposable utensils that the sector can start transitioning away from.. What we want is to find safer and sustainable materials, design, management or alternatives for essential plastics and a complete phase out of non-essential plastics in health care,” said Paeng Lopez, Plastics in Healthcare Project Officer and Sustainable Health in Procurement Project Philippine Coordinator at HCHW-SEA. “That said, and pursuant to our objective of a healthy recovery, we are encouraging the health care sector to begin saying no to non-essential plastics now.”

“The good news is that there are alternatives,” said Miko Alino, GAIA Asia Pacific Program Manager. “There are businesses offering SUP-free packaging all over Asia Pacific and the world. Some say those are niche businesses, but they are not. We used to bring reusables when we bought food, our parents used to bring traditional native baskets to markets. Sachets were unheard of until just a few decades ago.”

Knowing the hazards of the toxic chemicals found in plastics food packaging, the groups are calling for:

  • Making alternatives available by providing incentives to refilling stations and Zero Waste stores;
  • Guidelines on toxic-free packaging to include elimination of chemicals in food packaging;
  • A phaseout schedule for sachet use to be included in SUPs ban; and
  • Incentivize development of community-driven livelihood projects for alternative natural and local materials.


  1. According to The Unwrapped Project, over 4,000 chemicals can be present in plastic packaging and of those, 906 have been identified as likely to be present in plastic packaging with 68 chemicals particularly hazardous for the environment and 63 to human health.


The UNWRAPPED Project aims to raise awareness across the globe about the human health risks posed by plastics and food packaging materials and chemicals. All forms of single-use food and beverage packaging appear to contain health-harming chemicals that migrate into food and beverages and pose health risks. Therefore in addition to calling for an end to single-use plastic packaging that is filling the environment with large-scale to nanosized forms of plastic (polluting the air we breath, water we drink, and food we eat), The UNWRAPPED Project calls for corporate and government decision makers to take a precautionary approach to using harmful chemicals that are known to migrate out of packaging and cause human health impacts and use only chemicals and packaging materials that are proven safe.  UPSTREAM, Zero Waste Europe, and GAIA lead the work in the US, Europe, and Asia Pacific.


Sonia G. Astudillo, Asia Pacific Communications Officer, Global Alliance for Incinerator Alternatives, +63 917 5969286

Julian Carlos Cirineo, Communications and Outreach Associate, #breakfreefromplastic, +63 977 8077627

Related resources:

Por Magdalena Donoso, Coordinadora de GAIA para América Latina.

El libro “El Derecho a la salud en el oficio del reciclaje: Acciones comunitarias frente al COVID-19”, es un esfuerzo por desmantelar el miedo como motor para enfrentar la pandemia que experimenta el mundo hoy, y en particular las recicladoras y recicladores de base en Ecuador y América Latina. En sus páginas, el virus no aparece como el culpable de nuestros males. Al contrario, el COVID-19 aparece como una expresión de nuestra insana relación con la naturaleza, la que ha alterado los procesos metabólicos que se daban en armonía entre sociedad y naturaleza, y ha quebrado también las relaciones de colaboración entre los seres humanos.

En este escenario se encuentran el y la recicladora de base como parte de una población particularmente vulnerable a las múltiples dinámicas de relación que imperan hoy, donde por la forma en que este oficio se realiza, enfrentan una triple exposición: ambiental, laboral y doméstica. Así, el libro entrega información y recomendaciones exhaustivas para la promoción y prevención profundas ante el COVID-19, y ubica el monitoreo comunitario participativo (MCP) como una herramienta emancipatoria fundamental. El MCP permite la comprensión de las determinaciones estructurales del problema y posibilita un diagnóstico aterrizado para la mejor toma de decisiones, así como una evaluación posterior clara sobre el resultado de los planes de acción definidos.

Este libro nos deja al final de su relato con un llamado a la construcción de otro mundo posible, un mundo basura cero, como apuesta para la  recuperación de la circularidad en las relaciones de las sociedades y sus naturalezas, en un camino de cambio profundo en nuestra forma de extraer, producir, distribuir y consumir. En este nuevo mundo, las y los recicladores de base en su rol de ecologistas populares, reivindican a la basura no como mercancía sino como una herramienta que, limpiando y reparando el mundo, aporta al bien común y nos acerca a una realidad donde pandemias y otros profundos desequilibrios no tienen cabida.

Philippine press contact: Dr. Jorge Emmanuel, Silliman University, Dumaguete, Philippines; +63 917 778 5866;

International press contacts (see below for the full list): Dr. Jane Muncke, Food Packaging Forum, Zurich, Switzerland; +41 44 515 52 55;

Thirty-three international scientists published a consensus statement urging decision makers in government, industry and civil society to reduce exposure to harmful chemicals that are present in food packaging such as plastics. The authors work in the fields of developmental biology, endocrinology, epidemiology, toxicology, and environmental and public health, including Dr. Jorge Emmanuel of Silliman University in Dumaguete.

“In the Philippines, so much of our food is in plastic bags and plastic containers and some people even microwave food in plastics, yet many studies have shown that chemicals can migrate from plastics into food,” said Dr. Emmanuel, who specializes in environmental toxicology, public health and polymer science, among others.

“Our scientific consensus statement explains that in the U.S., about half of the nearly 12,000 chemicals allowed as food additives are food contact chemicals [FCCs] but many of them have never been tested for endocrine disruption and other hazardous properties,” he said.

Endocrine disruption is the ability of some chemicals to mimic or interfere with the body’s hormones. Endocrine disrupting chemicals have been linked with developmental malformations, reproductive problems, increased cancer risk, and changes to immune and nervous system functions.

The consensus statement also points out that in Europe, some substances that are known to cause cancer, genetic mutations, or harm to the reproductive system, are still authorized for use in food contact materials.

The consensus statement notes that hazardous chemicals that can transfer from food contact materials are associated with chronic diseases such as diabetes, obesity, cancer and neurological disorders, like attention deficit hyperactivity disorder. The issue is especially relevant for recycled materials and plastics alternatives that are being promoted as more environmentally friendly in response to plastic pollution concerns.

The peer-reviewed consensus statement is based on more than 1,200 peer-reviewed scientific studies and highlights seven specific areas in need of improvement, including: elimination of hazardous chemicals in food contact articles, development of safer alternatives, modernizing risk assessment, consideration of endocrine disruption, addressing mixture toxicity, improving enforcement and establishing a multi-stakeholder dialogue to find practical solutions.

The consensus statement was published on March 3, 2020 in the open access journal Environmental Health.

“Virtually everyone who eats food is exposed to food contact chemicals, but some are known to be hazardous and many are untested or even completely unknown. This consensus statement is a wake-up call,” said Dr. Jane Muncke, managing director of the Food Packaging Forum and co-author of the statement.

“Chemical migration from food contact articles like packaging must be systematically addressed, and any hazardous substances removed – and not just replaced with other, less well studied chemicals that turn out to be regrettable substitutions, like BPS that replaced BPA. Getting the toxics out is essential as society moves toward a circular economy and increases the use of recycled or alternative materials,” she added.

BPA is short for bisphenol A, a chemical found in reusable water tumblers, baby bottles and other products made of polycarbonate plastic as well as in coatings of metal food cans. BPA was detected in 93% of urine samples of people six years and older by a 2004 U.S. government study. After tests with animals showed that BPA is an endocrine disruptor, manufacturers started selling “BPA free” products. However, the common BPA replacement, bisphenol S or BPS, turned out to be an endocrine disruptor also. A study in 2012 found that 81% of urine samples from Japan, U.S., China, Kuwait, Vietnam, Malaysia, India and Korea had detectable levels of the replacement BPS.

According to Dr. Emmanuel, another concern are phthalates, which are a group of chemicals added to many plastics to increase their flexibility and to soften polyvinyl chloride (PVC) plastic which would otherwise be rigid. Plastics with phthalates include food packaging, toothbrushes, tablecloth, schoolbook covers, garden hoses and medical tubing. Some phthalates have been shown to affect the reproductive systems of laboratory animals, resulting in damaged sperm, abnormal development of the male reproductive tract and decreased fertility. The health effects on humans are still being studied.

The authors of the consensus statement analyzed existing lists of food contact chemicals (FCCs) issued by legislators, industry and NGOs worldwide. They found that almost 12,000 distinct chemicals are potentially in use in the manufacture of food contact materials today, and that many have not been tested adequately for toxicity.

While there is a great amount of information for some of the most well studied FCCs such as BPA and phthalates, thousands of reported FCCs lack data on their hazardous properties and/or level of human exposure – but these are critical data for determining human health risks.

Furthermore, there is an unknown, but presumably even higher number of non-intentionally added substances present in food packaging that have the potential to migrate into food, especially from recycled materials. Non-intentionally added substances refer to impurities found with the chemical additives, the results of chemical reactions during manufacturing, or chemicals produced when the additives themselves degrade.

The scientific consensus statement resulted in a Declaration of Concern and Call to Action, which as of March 4 was already signed by more than 160 organizations worldwide. The Declaration (available at calls on lawmakers to ensure full disclosure and traceability of chemicals used in packaging, to restrict the use of hazardous chemicals in food packaging, and to adopt policies that support the transition to safe, reusable and refillable packaging.

Merci Ferrer, co-convenor of War on Waste/Break Free From Plastic – Negros Oriental, one of the organizations that signed the Declaration, concluded, “With the evidence presented by the international scientists, our lawmakers and government agencies such as DOH, FDA, DENR, DOST and others should apply the precautionary principle and take action to protect our people’s health.”



Muncke J et al. (2020) “Impacts of food contact chemicals on human health: a consensus statement.” Environmental Health, available online on 3 March 2020: doi:10.1186/s12940-020-0572-5

Groh K et al. (2020) “FCCdb: Food Contact Chemicals database. v2.0.” doi:10.5281/zenodo.3240108

Declaration of Concern and Call to Action:


Jane Muncke



Food Packaging Forum Zurich, Switzerland English, German
Maricel Maffini Independent Consultant Maryland, USA English, Spanish
Olwenn Martin Brunel University London London, UK English, French
Martin Wagner Norwegian University of Science and Technology Trondheim, Norway English, German
Jorge Emmanuel

Phone: +639177785866

Silliman University Dumaguete City, Philippines English, Filipino
Angel Nadal IDiBE and CIBERDEM, Universitas Miguel Hernandez Elche, Spain English, Spanish
Pete Myers Environmental Health Sciences, and Carnegie Mellon University Virginia, USA English
Arturo Castillo Castillo Imperial College London, UK English, Spanish
Bethanie Carney Almroth University of Gothenburg Gothenburg, Sweden English, Swedish
Konrad Grob Retired from Official Food Control Authority of Zurich Zurich, Switzerland English, German
Anne-Marie Vinggaard Danish Technical University Copenhagen, Denmark English
Nicolas Olea University of Grenada Grenada, Spain English, Spanish
Tracey Woodruff


+1 (415) 624-9959

University of California at San Francisco San Francisco, California, USA English
Frank von Hippel Northern Arizona University Flagstaff, Arizona, USA English


Scientific Consensus on Chemicals in Food Packaging Leads Environmental and Public Health Groups Around the World to Declare Global Health Threat

Groups call for policymakers to protect families’ health by phasing out toxic chemicals from food packaging and mandating safe, reusable alternatives 


Today, nearly 200 environmental and public health organizations led by the UNWRAPPED Project (UPSTREAM, Zero Waste Europe, and GAIA) released a Call to Action in response to a just released peer-reviewed Consensus Statement signed by 33 world-renowned scientists warning chemicals used in single-use plastic and food packaging represents a significant threat to human and planetary health – particularly the health of children.

The Consensus statement clearly states the facts:

  • Approximately 12,000 chemicals are intentionally used in packaging and other forms of food contact materials
  • An enormous body of research – over 1200 studies- shows that these chemicals migrate from packaging into food and beverages
  • Amongst those chemicals, many have been proven hazardous for human health: exposure may lead to cancer, heart disease, inflammatory bowel disease, rheumatoid arthritis, genotoxicity, chronic diseases (such as atherosclerosis, cancer, diabetes, cardiovascular diseases), and autoimmune diseases
  • Many of these chemicals are never tested for human health effects
  • For most of these chemicals, their presence is undisclosed 

Many of those chemicals, including phthalates, bisphenols and PFAs, are used in single-use packaging, made of plastic but also paper & board. The lack of disclosure by producers regarding chemicals used in packaging means that the risks associated with the use of those packaging cannot can’t be evaluated. Consumers and regulators aren’t the only ones in the dark– many packaging producers and waste managers are unaware of the chemicals present in the packaging they process, and possibly recycle in other products.

In response, nearly 200 organisations signed a Call to Action, demanding that regulators and industry protect public health and the environment by acting to:

  • Ensure that all chemicals used in food packaging are fully traced and disclosed 
  • Eliminate harmful chemicals in all food packaging and prevent regrettable substitutions 
  • Adopt policies that support the transition towards safe, reusable, and refillable packaging

The Call to Action is launched globally with dedicated media events in the United States (Click here to attend the telepresser on March 3, 7am EST) and Asia Pacific (Australia, Malaysia, Nepal, Taiwan, and the Philippines).  

In Asia Pacific, Beau Baconguis, Regional Plastics Campaigner, stated: “Our communities are a rich resource of traditional materials, practices and systems that worked without exposing the consumer to the toxic chemicals that came with plastic food packaging. We got sidetracked for a few decades by the plastic packaging industry. It’s time to reject this plastic packaged food culture and reclaim and, if necessary, update and scaleup on the sensible, safe alternatives we used to have.”  

In Europe Justine Maillot, Consumption and Production Campaigner at Zero Waste Europe commented: “Our current system of production and distribution of food and its packaging puts at risk the health of people, who don’t even have access to information on the chemicals present in food packaging. Regulators must take immediate measures to eliminate hazardous chemicals from food packaging, and ensure a transition to make it  toxic-free and reusable. This is urgently needed to protect both human health and the environment, and allow a clean circular economy.” 

In the U.S.,  Linda Birnbaum, former Director of the NIEHS and the National Toxicology Program commented: Families want to put food on the table that supports their children’s health and wellbeing. But it’s next to impossible to find options that aren’t wrapped in food packaging containing chemicals that represent a significant threat to human health. Current safety evaluations fail to consider impacts of very low dose exposures on the endocrine system and this puts children at the greatest risk of harm.”

Read the Call to Action (spanish and mandarin versions available)

Read the Scientific Consensus Statement 


Press Contacts: 

Europe: Agnese Marcon, Communications Coordinator, Zero Waste Europe & Rethink Plastic Alliance, 

+32 (0) 456 078 038

U.S.: Claire Arkin, Communications Coordinator, GAIA

+1 510 883 9490

Asia: Sonia G. Astudillo, Communications Officer, GAIA Asia Pacific

+63 917 5969286


 GAIA (Global Alliance for Incinerator Alternatives) is a worldwide alliance of grassroots groups, non-governmental organizations, and individuals whose mission is to catalyze a global shift towards environmental justice by strengthening grassroots social movements that advance solutions to waste and pollution. 

UPSTREAM works with businesses, schools, and communities to transition to a throw-away-free culture. We have launched campaigns across the country to make single-use history and “indisposable” the new norm.

Zero Waste Europe is the European network of communities, local leaders, businesses, experts, and change agents working towards the elimination of waste in our society.

We empower communities to redesign their relationship with resources, and to adopt smarter lifestyles and sustainable consumption patterns in line with a circular economy.