Further supplementary memorandum submitted
by the British Metals Recycling Association (BMRA) (Waste 38b)
INFORMATION IN
RESPONSE TO
SUPPLEMENTARY QUESTIONS
RAISED BY
THE ENVIRONMENT,
FOOD AND
RURAL AFFAIRS
COMMITTEE, NOVEMBER
2008
Question 1: What are the main barriers to
expansion in infrastructure growth and are policy changes needed
to overcome them?
This question was circulated to some BMRA members.
The response was so wide ranging that it has not been possible
to include all their comments here. It has been pointed out that
the question has never been asked in any of the (over 40) government
consultations that the industry has had to respond to in the last
two years.
The Waste Strategy Chapter 4 (targeting materials,
products and sectors) omits metals from the materials to be considered,
other than an objective to develop "proposals (subject to
further analysis) for higher packaging recycling targets beyond
the 2008 European targets" in relation to aluminium. We have
been told, by senior Defra officials, that this is because "the
market will take care of metals".
The policy change that is needed is senior level
government commitment from a range of government departments to
work with the metals recycling industry on a co-ordinated strategy
to maximise metal recycling and the achievement of UK recycling
and recovery targets, by removing these barriers to growth.
Some of the issues to be addressed are as follows:
1.1 Collection & Landfill
According to the Defra Waste Strategy (p.55)
approximately 1.5mt ferrous metals and 0.5mt aluminium still go
to landfill (no figures are given for other non-ferrous metals).
There is a well established global market for metals
which could absorb more volume and the energy saving benefits
of using secondary raw materials in metal smelting are well known.
What is needed is a strategy for bringing the metals that are
currently land-filled into this system.
1.2 Solutions for residual wastes
Meeting European targets for recovering End-of-Life
Vehicles, WEEE and other complex products requires a coordinated
UK strategy that doesn't yet exist. Much of the 2015 ELV target
to recycle, reuse or recover 95% of a car will be met by recycling
metals (75%) and other materials recovered by post shredder technology.
The metal recycling industry has invested heavily in driving this
forward.
But there is no national strategy for industrial
Energy from Waste or other recovery capacity to cope with the
residues; nor is there sufficient overseas capacity. At present
these residues have to be sent to landfill (approx 1 mt pa). Development
and commissioning of appropriate recovery capacity to cope with
these residuals will take seven to eight years—we need to
start now if 2015 ELV targets are to be met.
[Solutions might include new build capacity
and/or a requirement that municipal developments reserve (say)
10% capacity for such use.]
1.3 Local Infrastructure & Planning issues
Local waste structure inquiries rarely consult
the privately-run metal recycling sector, with the result that
necessary metal recycling capacity is frequently understated in
plans. This results in:
— Near impossibility of opening new
sites
[which are required to maintain infrastructure,
eg to replace family companies winding up].
— Established sites being threatened
with compulsory purchase, to make way for housing.
— Established sites subjected to additional
controls, such as reduced operating hours.
[this happens particularly where the site was set
up in an industrial or dockside area which is redeveloped for
residential use].
— Unnecessary delays when established
sites need revised planning consent (eg to obtain appropriate
licences to comply with new Directives, such as ELV or WEEE).
1.4 "Producer responsibility" Directives
Many recycling developments are EU Directive
driven. But UK Government tends be late in implementing such Directives.
This hinders our preparation for capital expenditure projects,
since companies cannot plan and invest until the "rules"
are clear. It also prevents UK equipment manufacturers from benefiting
from these new production lines. For example: there is no significant
level of UK manufactured equipment in UK fridge recycling plants.
UK Government also has a tendency to "gold plate"
EU Directives to a greater extent than other Member States. An
example is the requirement for proof of "equivalent standard"
of recycling when materials derived from WEEE products are exported
to non-EU countries. This requirement rarely exists in other Member
States (we can find only one example).
Changes negotiated by industry in respect of
one Directive do not "read" across to others—which
causes industry time, money and frustration. Thus Defra has recently
amended the Packaging Regulations to recognise that it is ridiculous
to make the assumption that metals (or other materials sold at
relatively high values) will not be recycled. But there is no
automatic extension of this thinking to WEEE.
1.5 Lack of joined-up government
a. Europe
Different EU Directives have a tendency to be
mutually self-defeating. For example:
(a) the WEEE Directive necessitates the recycling
of plastic from waste electronic goods in order for recycling
targets to be met. But the RoHs Directive then puts limits on
the content of these materials, making recycling significantly
more difficult; and
(b) aggregates recovered from car shredders
have been designated products under a WRAP protocol to facilitate
their recycling and this has been achieved as the environmental
risk from these good is infinitesimal. They then have come under
the Reach Directive—which could divert them back to landfill
due to their very low value.
(a) Escalating landfill tax (to encourage
recycling) imposed on recycling streams that already have their
recycling levels set by other legislation (ELV and WEEE).
(b) The 2003-05 End of Life Vehicle Regulations
(BERR) require a joined up system of issuing Certificates of Destruction(CoD)
when a car is scrapped. Businesses (metal recyclers or car dismantlers)
authorised to issue CoDs must install costly depollution equipment
(£50-100k per rig). But we do not yet have a watertight CoD
system; DVLA is now addressing the need for change but needs legislation
to achieve this.
— estimates have to be made to report
figures to Europe; and
— metal recyclers who have invested
in expensive depollution equipment are being undercut financially
by unregistered operators who have not.
(c) The continuing number of illegal metal
recycling sites allowed to continue without complying with environmental
regulation. These provide a route for stolen metals. They also
threaten legitimate trade. But police, HSE, Environment Agency
and others are all under-resourced to tackle the problem, and
generally focus on their own immediate priorities rather than
working together.
1.6 Regulatory burden
The significant, and growing, regulatory burden
on the metals recycling sector is a significant barrier to infrastructure
development—since it increases the cost of day to day operation,
and diverts the whole industry into dealing with a seemingly endless
stream of consultation on regulatory change and implementation
of new systems. This is exacerbated by:
— Uneven application of regulations,
which mitigates against best practice.
— Shoe-horning materials recycling
into "one size fits all" regulation designed for the
wider waste industry, or to prevent the overseas dumping of "problem"
wastes.
Question 2: How has Defra responded to your
suggestion that companies investing in research and development,
on how best to reduce the amount of waste sent to landfill, should
be allowed to offset this against landfill tax?
We raised the need to consider this issue in
our response to the public consultation on the Waste Strategy
submitted in May 2006. We raised the specific proposal of an offset
against landfill tax in our policy paper Agenda for Change issued
in April 2007, and in a meeting with Joan Ruddock (then Environment
Minister) in June 2008. We have not yet received a response.
We have also raised the omission of a metals strategy
from the Waste Strategy with Defra officials, on numerous occasions.
The reply has been "the market takes care of metals".
Question 3: What examples do you have of
investment from your sector in this type of R & D?
Traditionally, the industry's expertise lies
in recovering and trading metals to internationally recognised
specifications and standards. Significant investment has been
made in recent years, in response to the UK's need to meet European
"producer responsibility" Directive targets—notably
those concerning End of Life Vehicles and WEEE.
For small to medium sized companies, this has included:
— £50-100k investment for a depollution
rig, in order to meet treatment requirements for end-or life vehicles.
For all companies, this has meant:
— additional staffing and/or computer
systems to cope with regulatory paperwork
[estimated to increase weighbridge work per transaction
from 2 to 5 minutes]
For medium and larger companies, very significant
(often multi million pound) investment has been made into:
— developing new equipment to meet
treatment requirements
eg. development of ELV depollution equipment—not
available "off the shelf"
— improving recycling levels
eg. multi-million pound investment in shredder
technology to ensure that maximum metal is recycled
development of refrigerator recycling techniques
development of WEEE recycling techniques
— developing new technologies for separating
out recyclable non-metallic materials after shredding
notably for plastic streams which have never
previously been recycled
several of the larger companies have multi-million
pound developments in progress in this area, in which the UK is
a European leader
— developing overseas markets for these
materials
newly recovered materials, such as hard plastics
from fridges and computer equipment, do not have ready-made markets.
This has required new trade to be established with businesses
which, typically, can only be found outside Europe and the OECD.
Further information on specific developments
is available on a confidential basis, but is not reproduced here
for reasons of brevity and commercial confidentiality.
Question 4: Do you have an estimate of how
much more investment could be incentivised by the carrot of a
landfill tax offset
The landfill tax offset would help:
— maintain momentum in the current
economic down turn, which is threatening progress in many developments
in progress;
— medium sized companies, which are finding
it hard to raise funds from traditional lenders such as banks;
— both large and medium sized companies
to take the risks inherent in developing technologies which are
entirely new and untried;
— redress the current position where
companies in the metal recycling sector are refused consideration
fora BREW or WRAP funding; and
— enable the industry to contribute
fully to the national strategy on residual wastes proposed above.
At present we send approximately one million
tonnes of residual waste to landfill.
The landfill tax payable on this is currently
£32 million (@:£32 /t).
By 2010 this will rise to £48 million (@
£48/t).
Over five years the cost to industry of this
tax will be over £200 million.
Offsetting these funds to R&D would be a
significant boost to meeting future targets.
British Metals Recycling Association (BMRA)
November 2008
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