Examination of Witnesses (Questions 256-259)
15 DECEMBER 2003
MR NEIL
MARSHALL, MR
STUART COTTAM
AND MR
SHANE MELLOR
Q256 Mr Mitchell: Welcome, gentlemen.
We have Mr Mellor of Mellor Metals, a nice name. We have Mr Marshall,
the Director General of the Recycling Association and Mr Cottam,
of Sims Metal UK. You wrote to us, and I was grateful that you
did, suggesting there has been a lack of clarity about producer
responsibility, which I think is right. I wonder if you would
like to develop that argument and tell us whose responsibility
you think it is to clarify the rather vague wording of the Directive
in respect of producer responsibility. Is it the Government's
or is it Europe's?
Mr Marshall: I think it has to
be our Government because they have authority delegated to them
to do just that. It seems to me if we are at the end of the road
with the expected transposition in April, we are in a very strange
position because we have regulations in force but we do not know
fully what those regulations pertain to. We certainly do not at
this moment, my member companies, have full information for basing
investment decisions to fulfil the requirements of those regulations.
We have no idea whether people who put investments down will be
able to take part in the new system, what sort of volumes they
might have, what sort of costs; we still have elements of the
regulations not yet clarified. So we are in something of a muddle,
the whole thing seems to me to be rather back-to-front. We have
a consultation from DTI which was due out tomorrow, was cancelled
at 10 o'clock today. The last point at which people can apply
for licences is the end of January, the consultation will now
come out in the middle of January, presumably with a six or twelve
week consultation period. It is all very interesting but my market
place is confused. There will be casualties, no matter what we
come up with.
Q257 Mr Mitchell: There will also be
a reluctance to invest?
Mr Marshall: I think people are
caught. They are required to apply for licences and you therefore
to commit themselves to fulfil the requirements of those licences
by the end of January, yet we do not even know what final form
the structure will be.
Q258 Mr Mitchell: At what point did your
alarm bells begin to ring as an organisation and say, "Something
is going wrong here"? Were you consulted in the early stages?
Mr Marshall: My involvement has
been since the beginning of March when I joined the organisation.
I have to say in 30 years of dealing with legislation I have never
seen such a muddled position, confused partly because of the plethora
of agencies involved but also because the structure seemed to
be very strange. We have had consultations where we have been
looking for consensus and there are only two parties involved
in this—the sector and the vehicle manufacturers—and
when you have an impasse, you have no agreement, you would expect
them to move on, yet we seem to keep coming back with the same
approach, which suggests a systemic bias towards the vehicle manufacturing
industry. I would like to say that I support very much our manufacturing
sector, and in particular the vehicle manufacturing sector, but
the system has pushed us against the other party in the market
place and I regret that. If you look at the WEEE Directive, for
example, it starts with a much more coherent approach, where everyone
is pulling together, there is a greater role for industry, and
I think that coherence will produce a far better set of regulations.
Q259 Mr Mitchell: How do you expect the
producer responsibility aspects of this Directive are going to
work? There is an "Own Marque" approach, what effect
is that going to have?
Mr Marshall: I do not want to
hog the microphone but clearly it enables the people who are responsible
for creating the product, the vehicle manufacturers, to evade
their responsibilities through their prominent position in the
market place. It seems to me therefore what we should be aiming
for is a structure which involves the greatest number of recycling
sites so we can continue to have neighbourhood recycling opportunities.
What we have is a very, very efficient pyramid, which works at
a very low margin, so it works extremely well, it encourages other
forms of recycling and this is clearly going to damage that permanently.
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