Written evidence submitted by the British
Metals Recycling Association|
1. Metals recycling is the largest and most successful
recycling sector in the UK. Every year this £5 billion industry
recovers around 15 million tonnes of metal per annum, including
two million end-of-life vehicles (more than any other EU country),
five billion food and drinks cans, three-and-a-half million white
goods, and around eight million automotive batteries. Metals
recycling not only brings huge environmental benefits by reducing
the UK's dependence on dwindling natural resources and landfill
but also lowers greenhouse gas emissions and water usage when
producing new metals (compared to using virgin ores): the industry
does more than any other to ensure that the UK meets its targets
under the various EU producer responsibility directives.
2. Metals recyclers also use advanced shredder and
media separation techniques to recover other materials. For example,
besides 1.5 million tonnes of metal, 100,000 tonnes of other secondary
raw materials, such as glass and plastics, are recovered from
end-of-life vehicles each year. This contribution means that,
as well as playing an important role in fostering green growth
and jobs, the metals recycling sectorbecause it processes
far more metal than domestic manufacturing needsis one
of the world's largest exporters of recovered metal, accounting
for 45% of Europe's 10 million tonne global trade.
3. However, with the appropriate fiscal and regulatory
support, the industry could be making an even bigger contribution.
This submission sets out the British Metals Recycling Association's
position on the role of the landfill tax regime in promoting innovation
and improved recycling rates, which will become necessary as EU
recycling targets increase.
4. 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.
5. The metals recycling industry has invested heavily
in developing the advanced media separation techniques and solutions
for residual wastes required to not only meet but exceed recycling
targets under the various EU producer responsibility directives
but also to divert materials from landfill and realise the "zero
waste" agenda. Examples include new technologies to allow
the recovery of non-ferrous metals using dense media and advanced
downstream systems, employing copper analysers, and investing
in mega-shredders. BMRA members are also leading the way on plastics
recovery and in adopting advanced thermal processes such as gasification
and pyrolysis for end-stage recovery of non-recyclable materials.
6. With producer responsibility targets set to increase
over the next decade - for example, the targets for the recovery
of end-of-life vehicles will increase from 85% to 95% in 2015further
capacity needs to be put in place urgently if these targets are
to be met and infringement proceedings from the EU avoided.
7. However, the requirement to pay landfill tax on
current activity whilst also being expected to fund investment
in new technologies to reduce landfill acts as a significant inhibition
to developing these solutions. Support in the form of a landfill
tax credit or holidaywhereby waste would be landfilled
free of landfill tax whilst approved investment programmes in
new technology are in developmentwould be a welcome step.
8. Such support could also extend to a "holiday"
from the escalatorfor example, in the event that material
is stored now until it could be treated using a new process, but
should the development of that process ultimately prove unsuccessful,
the rate of landfill tax would be backdated to the year in which
the waste would otherwise have been landfilled rather than the
9. With metals recycling not currently able to benefit
from the framework of incentives aimed at developing renewable
and other technologies, support for investment in research and
development through the landfill tax regime represents an obvious
means by which HM Treasury can support the sector in enabling
the Government to meet its own public policy objectives around
sustainable development and environmental protection.
20 April 2011