Memorandum submitted by S Norton and Co.
Ltd (E13)
INTRODUCTION
1. The following evidence is submitted by
S Norton and Co. Ltd., a medium sized company, which is third
largest metal recycling operation in the UK. Established over
40 years ago, Norton operates from five sites in Liverpool and
Manchester, processing and shipping around one million tonnes
of recovered metals annually.
2. Norton is a prominent member of the British
Metals Recycling Association (BMRA), the trade body for the metal
recycling industry, and supports a number of its key committees.
The Company works closely with the Association on important issues
such as the End of Life Vehicles (ELV) and Waste Electrical and
Electronic Equipment (WEEE) Directives.
3. Norton is also a member of ICER, the
Industry Council for Electronic Equipment Recycling, which it
joined specifically in order to keep abreast of developments in
the WEEE Directive.
4. Two of our sites house large metal shredders
and their supporting infrastructure, and process a large number
of End of Life Vehicles and Electrical Whitegoods, solely for
the purpose of recovering their metallic content for recycling.
5. The UK's interpretation and implementation
of both the ELV and WEEE Directives are therefore of vital importance
to our ongoing operations, and we welcome the opportunity to comment
on the Government's role in transposing and introducing them.
COMMENTS
6. We have contributed to and generally
agree with the evidence submitted to the Committee by the BMRA,
and there is very little we can add to it.
7. We feel that DEFRA's declared intention
to avoid over-specifying the technical requirements has been a
key factor in delaying the issue of guidance, which has resulted
in uncertainty for operators wishing to invest in facilities,
while the eventual outcome offers little comfort.
8. The greatest difficulty for recyclers
has been the uncertainty over funding, both for treatment costs
and increased recovery targets. The DTI's failure to acknowledge
the need and provide for a substantial injection of new funds
to meet the increased costs of the Directive has set the producers
against the recyclers, each equally determined that the other
should bear the cost.
9. As a result, even at this late stage
of the Directive, our suppliers who process vehicles in the first
instance lack the confidence to invest in facilities as they cannot
put together a sensible business plan to justify the investment.
There is therefore a strong possibility that treatment capacity
will be inadequate and the delivery of properly treated cars to
our shredders will be hindered which, in turn, will impair our
ability to process and recover the significant metal content.
10. The fact that Producer Responsibility
for funding in the WEEE Directive is spelled out more clearly
than the ELV Directive illustrates the shortcomings of the latter,
and shows that the European legislators are willing to learn from
their mistakes.
11. We need the UK Government to apply similar
principles to both Directives, and carry the sound Producer Responsibility
funding mechanism of the WEEE Directive back to the ELV Directive
before it is too late and there is no infrastructure to deliver
it.
12. We hope the Committee will use its influence
to secure a change in Government policy and facilitate an adequately
funded system to ensure the delivery of properly depolluted vehicles,
which will help the ultimate achievement of the recovery targets
stipulated by the Directives.
24 October 2003
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