WRITTEN EVIDENCE BY THE BRITISH METALS RECYCLING ASSOCIATION

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WASTE MANAGEMENT IN ENGLAND

The case for smarter regulation in the new waste management policy framework.  

Background on metal recycling in the UK

 

  1. The BMRA is the trade body for the metals recycling industry, serving a membership ranging from small family-owned enterprises to large multi-national companies. It represents around 85% of the industry, by volume.

 

  1. Not only does our £5-6bn industry make a huge difference to the environment – reducing pressure on landfill and natural resources, and cutting carbon emissions and water use – it does more than any other to ensure that the UK meets its targets under the various EU producer responsibility directives.

 

  1. As well as being a major low carbon industry, the UK metals recycling sector – because it processes far more metal than domestic metal producers (steel mills and non-ferrous smelters) can consume – is one of the world’s largest exporters of recovered metal, accounting for 45% of Europe’s ten million tonne global trade. Not only does this make a major contribution to the UK balance of trade, worth over three billion pounds a year, it also means that UK metal recyclers are the leading exporters of furnace-ready metal in Europe and among the most important globally. 

 

Q: The ability of existing recycling policy measures to ensure that England reaches the EU target of recycling 50% of household waste by 2020.

 

  1. The industry does more than any other to ensure that the UK meets its targets under the various EU producer responsibility directives. Metal recycling is the largest and most successful recycling sector in the UK. Each year, metal recyclers recover around 13 million tonnes of metal, including two million cars (more than any other EU country), five billion food and drink cans, three and a half million white goods, and around eight million automotive batteries. Notably the European target for the recovery of ELVs is currently 85% and rising to 95% in 2015. The UK is on target to achieve its increased ELV targets.

 

  1. We however remain concerned that the current Environment Agency (EA) approach to regulation is progressively imposing more measures on our members without any, or with inappropriate, environmental justification. This interpretation of existing policy is undermining the industry’s potential to grow and abiliy to improve its contribution to UK  and EU recycling targets.

 

Examples include:

 

­        Fridge Treatment – the EA’s reclassification of de-gassed Pentain fridges as “hazardous”, with a very short notice period, has meant that the majority of local recyclers cannot now buy them. This has resulted in a collapse in the value of scrapped fridges, and because the specialist processors do not have sufficient plant capacity there are increased risks of fire resulting from the consequential stockpiling and an increase in the fly-tipping fridges.

 

­        EA is proposing to classify all end-of-life electronic and electrical equipment (WEEE) as hazardous unless the collector/processor can be certain the all potential hazards have been removed. This would result in a major change in the supply chain that should not be contemplated without a very thorough study of the “actual” hazards” to the environment and human health that exist in, for example, large domestic appliances and the currently acceptable means of processing this stream. Having undertaken this there needs to be an understanding of the preferred means of treating or removing any actual hazards, without fundmentally disrupting or distorting the metal recycling market.

 

­        Noise reduction – measures being taken by the EA to reduce the impact of noise on local communities means that facilities are likely to close.

 

  1. We are also specifically concerned about:

 

­        The current regime of regular inspections, which is highly resource-intensive for both the regulator and the regulated.

 

­        Lack of sufficient resourcing and effectiveness of efforts to police illegal operations.

 

  1. Taking the above in combination, this £5.6bn industry faces significant challenges in delivering green growth and jobs. Impacts of the above are also particularly damaging because they disproportionately affect our smaller and medium sized members.

 

  1. In line with broader changes and DEFRA’s intention to ‘step back’ in areas of waste management oversight and regulation, the BMRA is seeking a more balanced and objective approach to the regulation of the sector, to transfer responsibility to industry and relieve the EA of some of its regulatory burden.

 

  1. The BMRA also believes that progress must be made to ensure the regulatory framework for metal recycling takes account of the industry’s particular context.

Specifically:

 

­        We would like to see a transfer of responsibility for environmental stewardship from the regulators to the regulated, through tools such as environmental and quality management systems, and compliance certificates.

 

­        This could be a combined with a shift to an ‘inspection by exception’ system to replace the current regime of regular inspections, which is highly resource-intensive for both the regulator and the regulated. It also focuses inspection efforts on compliant rather than non-compliant operators.

 

  1. The approach taken by the EA in regulating the industry is also resource-hungry, particularly for the small and micro business that it regulates. The steps covered above would establish environmental standards as a board-level concern rather than a low-level compliance issue, allow EA resources to be reallocated to where they can be most beneficial while ensuring continued high levels of environmental protection.

 

  1. We fully recognise the Government’s commitment to reduce public spending and seek efficiencies in departmental budgets. The suggestions above are made in this spirit and the BMRA is keen to enegage with Government on the process of transition.

 

  1. With the appropriate policy framework in place, particularly a more balanced approach from the EA in regulating the sector, the industry stands ready to go even further in ensuring the UK meets its EU target of recycling 50% of household waste by 2020.

 

Q: The feasibility of the introduction of a ban on landfill and/or incineration in England.

 

  1. In recent years, the metal recycling industry only landfills those elements of the waste streams we handle that are incapable of being harvested for single material recovery. In 2009 BMRA members generated around 800,000 tonnes of landfill from a gross input tonnage of 15m tonnes, however we now estimate that in 2014 the sector will only be accountable for around 200,000 tonnes of landfill.

 

  1. A ban on the land-filling of metal would not have a material impact on the metal recycling sector, however we believe that continuing the current trajectory of the Landfill Tax will produce less unforeseen conseuences and will, in the medium term, be a more effective policy lever.

 

  1. A ban on incineration may or may not be desirable, however any policy developed in this arena must take account of the needs of those who have developed advanced energy recovery solutions to utilise the final residues arising from the intensive recycling of a particular waste steam. BMRA members will achieve close to 95% recycling and recovery rates for end of life vehicles in 2015 only because they have invested heavily in post-shredder recovery techniques, plastics recycling, and now energy recovery which utilises the final 10% of this material stream.

 

British Metals Recycling Association
May 2014