Mercury waste is regulated in Thailand by DIW for local regulations and for import/export (competent authority for Basel convention on transboundary hazardous waste movement). We have a relatively good working relationship with DIW who supervises us.
Basel convention stipulates and strongly recommends that mercury waste should be treated locally unless there is no local solution, in which case it can be exported.
A local solution exists (BMTP) which is clearly qualified and has capacity: DIW agrees. We have documented via a letter our excess capacity this year and generally our capacity to handle close to 100% of Thailand waste.
Nevertheless DIW has regularly and quite freely, almost on a yearly basis, granted export permits towards Europe, mostly in favour of the PTT group (PTT-EP, PTT-GS) has exercised this option.
DIW has not encouraged the local solution BMTP which is also supported by the BOI.
Export of Mercury waste seems to be an open door, contrary to Basel recommendations. Why?
Should import of Mercury waste be allowed, the situation would be somewhat balanced and whatever excess capacity in Thailand could be filled with neighbouring waste (Myanmar, Indonesia, Malaysia, Vietnam for example).
However it also looks like import is not authorised.
I have not receive this message directly from DIW in spite of asking what are the criteria for importing waste, however a number of other sources in and out of Thailand mention that import of mercury waste is banned.
I believe there is an official position (import is possible on theory) that contradicts the effective position (no hazardous waste will be imported in Thailand). Why?
==> as you can imagine this has a serious impact on my business and I know I don’t have the relationships to really be told and understand the position of DIW.
PTTEP & PTTGS
We are struggling with PTT and in spite of many efforts to be accommodating, I believe we do not get a fair chance (my opinion). I believe that there is something in PTT, perhaps a while back, that is makes PTT not being supportive.
I have not been able to understand what and even I have not been able to get a chance to talk to PTT.
We hear that we are too expensive but I believe this is not the entire situation.
I also suspect that tight relationships to an agent also affect our position.
==> I do not have the relationships too understand what it would take to be fairly considered by PTTEP.
In both cases, my main issue is to really understand the position of DIW and PTT to be able to act accordingly. For this I think I need the assistance (Short term? Long term?) of a person with deep understanding of business/government.