5 Metal Use Efficiency
126. Resource use efficiency is the cornerstone
of long-term sustainability. The 3R concept of "reduce, reuse,
recycle" is widely used to highlight ways of minimising waste.[176]
This concept will be key to maximising the efficient use of strategic
metals.[177] Efficient
use will help to minimise demand for strategic metals, which may,
in turn, reduce the social and environmental impact of metal extraction.
Nicholas Morley, Director of Sustainable Innovation at the sustainability
consultancy, Oakdene Hollins, stated that:
Speciality metals typically have high embodied energy,
and where manufactured in countries with carbon-intensive
energy systems, high embodied carbon. They also have large volumes
of resources associated with their extraction and refining. Hence
techniques to increase their resource efficient use are recommended.[178]
127. The Government explained to us what it is
doing to drive resource efficiency:
The UK is looking at targeted measures to encourage,
incentivise and enable improved resource efficiency through the
Review of Waste Policies, the new strategic steer for Defra's
resource efficiency delivery body, WRAP, the Natural Environment
White Paper, and through the Roadmap to a Green Economy being
developed by Defra, BIS and DECC. It is also important to continue
working with Businesses and Trade Associations to raise awareness,
and spread best practice.[179]
128. Defra co-ordinate waste policy through the
Waste and Resources Action Programme (WRAP) whose vision is a
"world without waste, where resources are used sustainably"
and whose remit is to "help businesses and individuals
reap the benefits of reducing waste, develop sustainable products
and use resources in an efficient way".[180]
The life cycle approach and product
design
129. A product goes through many phases in its
life. Raw materials are extracted and processed; a product is
designed and manufactured, then packaged, distributed and purchased
by a consumer. At this stage it enters the "product use"
phase. At the end of its useful life, it can end up in storage
before entering the waste stream. In the waste stream, the product
can be incinerated or go to landfill. Alternatively it can be
reused or go through some form of reprocessing to extract useful
raw materials, which may then be used to create new products.
130. On a product's environmental impact, Louis
Brimacombe, Head of the Environment and Sustainability Research
Team at Tata Steel, stated:
we need to emphasise more and more the whole product
life cycle. You can make decisions about end of life, which might
have a marginal effect or even a detrimental effect on the use
phase. Whichever way you look at it these days, roughly 60% of
the environmental impacts of something is in the use phase, be
it automotive, buildings and so on. We need to be careful that
any kind of guidance or regulations takes that into account. There
are tools such as life cycle assessment to assist with that kind
of evaluation. That is a good thing. Life cycle assessment tends
to look at environmental issues, carbon and water footprinting
and so on.[181]
In its written submission the British Standards Institute
said:
The recovery and recycling of metals from discarded
products should only take place when it has been established that
incorporating the metals in the products, and recovering and recycling
them at the end-of-life stage is the most sustainable option available.
Other options may include using other materials, or adopting other
end-of life options.[182]
131. Life cycle analysis is necessary to establish
whether a particular resource efficiency measure causes a product
to have a higher overall environmental impact through unintended
consequences in another phase of that product's life cycle. This
is important for strategic metal efficiency measures, as the metals
are often present in very small quantities in the products that
contain them. For example, Tony Hartwell, Knowledge Transfer Manager
at the Environmental Sustainability Knowledge Transfer Network
(ESKTN), pointed out that there was only about 50 milligrams of
tantalum in a mobile phone and roughly the same quantity of other
high value materials.[183]
In its written submission, the Government said that "currently,
re-use and re-manufacture of components rich in [many] strategically
important metals would be preferable to recycling on a cost and
environmental basis".[184]
This was because strategic metals can be difficult and very labour
intensive to isolate from a product. Professor Robert Watson,
Chief Scientific Adviser to Defra, added that Defra was "working
with WRAP to look at the issue of product design in the first
place, the life expectancy of the product and then the potential
for recycling".[185]
He said that "a lot of work" needed to be done on product
design.[186]
132. Sophie Thomas, Trustee of the Design Council
and Founding Director of Thomas Matthews Ltd, stated that "the
way we recover things at the moment is not as innovative and technologically
efficient as the way we are designing our electronicsour
goods".[187] Recovery
of materials, in particular strategic metals, from goods is very
tricky and will require intelligent and innovative design practices
to be cost effective and to not adversely affect a product's environmental
impact over its whole life cycle. The Royal Society of Chemistry
(RSC) provided us with an example of how innovative design was
beginning to improve material use efficiency:
Orangebox is an office furniture design company setting
a good example. Their business model encompasses a cradle-to-cradle
approach to product design. Incorporating an end-of-life pick-up
recycling service, the entire production process is designed to
have minimal energy impact. Orangebox have been supported by Chemistry
Innovation Knowledge Transfer Network, an organisation that brings
together designers, businesses, chemists and engineers to promote
cradle-to-cradle product design. This pioneering approach needs
to be extended to other businesses.[188]
133. This resource efficiency success story has
been promoted by successful knowledge transfer networks. The cradle-to-cradle
approach is also being used in the Netherlands by Philips, the
large electrical manufacturing company. Mrs Thomas explained:
Crucial partnerships were set up within manufacturing
systems, including waste manufacturers like Van Gansewinkel, a
large waste manufacturing group in the Netherlands, who are now
working closely with Philips. They are setting up [...] "cradle
to cradle" groups, looking at the whole process of a closed
loop system, because Philips could tell them exactly what was
in their product and they could then work out how it was collected
at the end of life. If there is a design product like, for instance,
a coffee maker that they send to the recovery plant, and which
is a closed loop product, they needed to know that they could
easily recover all the materials in it and they could have accreditation
for the quality of those different separated materials afterwards
making it gradable so that it would go back up into the loop to
be re-made into another coffee maker. The design of the components
and their recovery was made much simpler through this design process.[189]
134. This approach is gaining ground in the UK.
Ian Hetherington, Director General of the British Metals Recycling
Association (BMRA), explained that:
We are now starting discussions with the automotive
manufacturers on advance battery packs because the design of the
battery pack in the cars we are going to be seeing in the next
10 years is absolutely critical to the means and effectiveness
by which we can extract the critical metals from those battery
packs. Those discussions are going on. They are very receptive
to it and we are looking here at a closed loop, so, hopefully,
by the time we are seeing the volumes of these materials coming
through on to the end of use market we will have those processes
in place.[190]
135. We consider that design of products is crucial
to maximising the recovery of materials from a product at the
end of its useful life. Therefore, as explained by Mr Hetherington,
BMRA, what happens to a product at the end of its life must be
considered in the early phases of a product's design and development.
However, this is often not the case. Dr Mike Pitts, from the Industry
Technology Division of the RSC, stated that:
The people taking the vehicles apart aren't necessarily
connected up with the people making the components in the first
place, who would really like to get those materials back [...]
there is no way that a car speaker manufacturer, from the way
we manage our vehicle waste at the moment, is ever going to see
those speakers again, much as they would like to.[191]
136. If a manufacturer never sees its product
again after it has left the shelves, then there is no incentive
to consider spending money on design for its disassembly. The
Design Council emphasised, however, that if a company takes its
products back at the end of their life, for every £100 spent
on design the company sees a return of £225. Mrs Thomas,
Design Council, explained:
Take the example of Xerox, the evidence suggests
that they have redesigned their machines so that they can take
bits back and directly use them in other products. They estimate
they can get their products to have up to seven lives within each
recovered component and this process is twice as profitable as
manufacturing in the first instance [...] because they
have a recovery system in place they get back their materials,
they have managed not to have to bring in raw materials for that.
That was a result of the design decisions. They designed and built
them so that they could pull them apart easily. Also, their designers
were in touch with their waste manufacturing people, so it was
a completely closed loop.[192]
137. Two key challenges facing innovative design
for product disassembly and material recovery are: encouraging
manufacturers to take back products at the end of their useful
life; and, connecting manufacturers with waste processing companies
to achieve the most efficient recovery methods. Dr Pitts, RSC,
explained that long distributive supply chains also cause problems
as it is difficult keep track of the materials and get them back
to their original manufacturer in an economic way.[193]
Mrs Thomas stated that to encourage this, a huge amount of incentive
needs to be built in and that:
designers tend not to be clued up on policy. A huge
amount of communication is missing. Relationships with British
Standards, where we are assisting with new sustainable design
guidelines, have great potential [...] new conversations with
manufacturers, designers, recovery and recycling facilities. That
is where the power is and having the Government there and legislation
in place is really key.[194]
138. Mrs Thomas was impressed by a recent visit
to the Netherlands where she considered the Dutch were making
significant progress in reducing waste and achieving design of
goods for disassembly.[195]
Mrs Thomas said that:
good, strong central government laws and local municipal
laws [...] helped make sure that the chain of custody, knowledge
and experience of all the people came together to create very
innovative ways of designing and recovery of materials. We could
learn a lot from them here. And it showed that a mixture of these
things brought the ideal environment for innovation. There was
a big push from Government there, including [a] landfill ban.[196]
139. The most effective method for materials
to be recovered from goods is for the producers of those goods
to have them returned at the end of their useful life. This will
foster innovative design, communication with waste managers and
other stakeholders. Using
a cradle-to-cradle approach to return products to manufacturers
at the end of their useful life is an effective means of managing
scarce resources, including strategic metals, efficiently. We
have been given examples of the financial benefits to manufacturers
that have tried this approach. We would like to see widespread
use of this approach in UK manufacturing, and intelligent product
design is key to its effective implementation. It is essential
to build networks and facilitate communication between manufacturers,
waste processors and designers. The work of the knowledge transfer
networks in achieving this should continue to be supported by
the Government. The Government should encourage the incorporation
of sustainable design thinking into the manufacturing and waste
processing sectors, thereby fostering a cradle-to-cradle approach.
Recycling strategic metals
140. While we see recovery as preferable to recycling,
we cannot disregard recycling. Recycling rates of many strategic
metals are lower than for the more widely used, bulk metals.[197]
For example, Research Councils UK (RCUK) stated that "recycling
rates for elements such as Gallium, Indium, Tantalum and Rare
Earths are currently less than 1%".[198]
Dr Rickinson, IOM3, stated that "the UK could develop itself
incredibly well within the field of recycling".[199]
MEETING DEMAND WITH RECYCLING
141. Due to the current low rates of strategic
metal recycling, any improvement in recycling rates would help
to provide new supplies of strategic metals at a time when demand
is increasing. This has been identified as a strategy for mitigating
supply risks in the recent EU report.[200]
142. Chatham House stated that "in the long-term,
genuine issues of physical scarcity apply" to reserves in
the ground.[201] However,
Mr Hartwell, ESKTN, explained:
We don't consume metals. When we use oil, we burn
it and it is destroyed, but, with metals [
] we dissipate
them to a greater or lesser extent [...] it goes into the technosphere
and is available for future use.[202]
Dr Pitts, RSC, agreed that "you can't create
or destroy elements".[203]
He warned, however, that "the way we are managing most elements
is really bad, and we are dispersing them in the environment in
a way that makes them harder and harder to recover".[204]
For example, when recycling large volumes of scrap material there
may be small quantities of valuable strategic metals present that
are difficult to recover. Louis Brimacombe, Head of the Environment
and Sustainability Research Team at Tata Steel, told us that little
effort is put into screening scrap steel for scarce materials.[205]
He explained that:
Scrap management is about optimising the through
value[...] The scarce materials, from a steel industry perspective,
is fairly low on the agenda. For niobium, for example, which is
in some high strength steels, it is in tiny amounts. If you are
referring to trying to recover low volume materials you wouldn't
go to the steelworks to try and recover rare earth metals. It
is probably better done by the equipment dismantlers and scrap
merchants at source.[206]
Mr Brimacombe acknowledged, however, that through
clever and efficient processes, low volume materials can be recovered.[207]
He explained that "if you have low niobium alloy steels in
the scrap, you can factor that into your processing to achieve
the required new alloy".[208]
We recommend
that where economically viable processes exist to extract or re-use
strategic metals from scrap materials, these processes be encouraged
by the Government.
143. Strategic metals are also being dispersed
by users discarding old goods and waste materials, which often
end up in landfill. Professor Watson, Defra, stated that "obviously,
we are trying to move much closer to a zero-waste society".[209]
Charles Swindon, Chair of the MMTA Trade and Lobby Committee,
believed that using the word "waste" was a misnomer
and that products at the end of their life ought to be viewed
as a resource.[210]
Illustrating this point, Mrs Thomas, Design Council, stated that
"there is about as much gold in one tonne of computer scrap
as there is in 17 tonnes of gold ore".[211]
144. Mr Hartwell, ESKTN, stated that "we
don't import a lot of these special metals directly. They are
in the computers and the equipment we purchase and support. In
a way, we could look at that as a potential resource".[212]
In 2009 UK householders purchased 1.25 million tonnes worth of
electrical and electronic goods.[213]
This presents a significant strategic metal resource in the future.
Rt Hon David Willetts MP, Minister of State for Universities and
Science, agreed that "as more and more old computers, IT
equipment and mobile phones are chucked out, they are a potential
resource".[214]
However, RCUK explained that:
The upper limit on what is available for recycling
is determined by what comes back from society; the ceiling on
this is what we consumed 40 to 60 years ago. By way of illustration,
global consumption of copper in 1970 was approximately 8 million
tonnes per annum. Five million tonnes was from mining, with 3
million tonnes from recycling. In 2008 global copper consumption
was about 24 million tonnes, of which 8 million tonnes are derived
from recycling, with the remaining 16 million tonnes from primary
production.[215]
145. The demand for copper has not yet been met
by recycled, or "secondary", copper. With the continuing
increase in global demand for copper primary production remains
the main source of supplies. This is also the case for other metals,
RCUK explained:
Even if recycling rates [
] were much higher,
we must recognise that the strategically important metal 'resource'
currently residing in the anthropogenic environment is very small
compared to that needed to meet predicted demand from manufacturers
of electric vehicles, wind generators, solar panels and digital
devices.[216]
146. Mr Hetherington, BMRA, agreed, "the
volumes of strategic metals [...] occurring in the end of life
supply chain at the moment are very limited"[217]
but he said that the lifespan of many products containing strategic
metals was likely to be less than those containing copper, somewhere
in the order of 10-16 years.[218]
147. Although demand for strategic metals is
likely to increase, the UK may be in a position to meet some demand
with recycling. The UK has the capability to exploit the strategic
metal resource in products at the end of their useful life.[219]
The Research Councils "are investing in research looking
at the long-term sustainable use of materials".[220]
For example, "NERC [Natural Environment Research Council]
are proposing a major £15m initiative on Resource Recovery
from Waste".[221]
148. One drawback to exploiting strategic metal
resources was highlighted by RCUK:
Assessing the further potential contribution of recycling
to meeting demand within the UK is hampered by lack of figures
on imports of strategically important metals contained in finished
and semi-finished goods. This makes it difficult to quantify the
amount of strategically important metals residing in society which
may become available as a "resource" for recycling.[222]
149. The lack of information extends beyond simply
the import of strategic metals in finished and semi-finished goods.
The Construction Materials Group of the Society of Chemical Industry
stated that:
We need a national review of metallic wastes in the
UK, quantifying the amounts and locations of each metal in the
national waste inventory and then to identify routes to their
recovery. Once we understand the nature of the problem, we will
be in a position to address it. At present a large, but unknown
quantity of metals are neither in use, nor in the recycling circuit.[223]
150. Dr Pitts, RSC, added that:
It would be helpful for companies to have something
akin to the Stern report for resources, putting an economic value
on the linear economy as it stands, where we dig things out of
the ground, add value to them and discard them.[224]
151. Professor Watson, Defra, acknowledged there
is a role for Government to provide "information as to the
cost of these products [containing strategic metals] and the potential
for recycling".[225]
He added:
One needs to let the market work, basically. As long
as the private sector has all the relevant information about what
the current and potential future demand is and they can think
through how you would produce a product and what the potential
for recovery and recycling is, that is the role of Government
basically, and then one will let the market work.[226]
152. Several witnesses considered that the market
could encourage more efficient use of resources. As we have noted,
Anthony Lipmann, Managing Director of Lipmann Walton & Co
Ltd and former Chairman of the MMTA, stated that rhenium "was
worth $300 a kilo in 1996 [but] in August 2008 it reached $10,000
a kilo, [...] price is like a beam of light that lights a way
on a subject. Then everyone starts to recycle".[227]
Dr Pitts, RSC, agreed:
Behaviour change does come with changes in price.
I have heard much anecdotal evidence in the last few days where
companies, because the price has risen, have started to do internal
recycling where they had not done that before.[228]
153. The Government acknowledged that recycling
was, in many cases, a costly process[229]
but the impact of changes in price was recognised: "to be
cost-effective in Japan, the price of rare earth metals would
have to rise 10-fold, but with further price rises likely, the
likelihood of more [rare earth] recycling increases".[230]
154. Assessing the potential
contribution of recycling strategic metals to meeting demand within
the UK is hampered by a lack of information. This includes a lack
of information on the strategic metals contained in finished and
semi-finished imports, as well as the amounts and locations of
strategic metals in the national waste stream. We recommend that
the Government conduct a review of metal resourcesfinished
and semi-finished goods and wastein the UK. This should
include an estimate of the market value of these resources. It
would also be valuable to assess the movement of these resources
into and out of the UK. Provision of such information will not
only identify routes to the recovery of strategic metals, but
will also empower the private sector to realise the economic potential
of recovery and recycling.
WEEE LEGISLATION
155. We were told that even when prices of metals
were high this in itself was insufficient to stimulate the market
for recycling. RCUK explained intervention by government was sometimes
required: "In general, the free market has so far been ineffective
in encouraging recycling and resource efficiency. Policy and related
economic instruments have proved more effective".[231]
156. One of the main interventions by government
has been the 2002 European Commission Waste Electrical and Electronic
Equipment (WEEE) Directive which was designed to increase the
recycling and re-use of electrical and electronic waste by creating
free of charge collection of e-waste for consumers.[232]
The Minister told us that the Government backed "the principle
of the WEEE regulations".[233]
157. Mr Hetherington, BMRA, explained how the
regulations were operating:
Currently, we are recovering substantial quantities
of platinum, rhodium and palladium, along, with gold and silver,
mainly from recovered waste electrical and electronic equipment.
Recovery rates from materials that actually get to UK recyclers
are very high. We are hitting over 90% of all materials that are
recovered and reused. The difficulty comes from collecting the
stuff in the first place. The rates of collection are low.[234]
158. This raises two issues. First, despite the
fact that by weight, 90% of collected waste is recycled, strategic
metals, which are often in products in small quantities, are likely
to be lost in the 10% not being recycled. Mr Hetherington, BMRA,
also highlighted the need to use more "sophisticated models"
for the collection of WEEE.[235]
Secondly, there is a need to improve collection of waste electrical
and electronic equipment.
159. The directive set a collection target of
four kilograms of waste per person per year. It is estimated that
two thirds of WEEE is going uncollected.[236]
This prompted the EC to re-visit the legislation in December 2008.[237]
The poor collection rates were recognised and, to rectify this,
the EC proposed to change the targets from an absolute weight
per person per year to a proportion "equal [to] 65% of the
average weight of electrical and electronic equipment placed on
the market over the two previous years in each Member State".[238]
160. The Society of Chemical Industry suggested
that the Government improve collection of WEEE by using "both
carrot and stick" by, for example, imposing fines on people
discarding metal waste while also providing a VAT discount on
new phones when consumers traded in old ones.[239]
The Minister explained that the WEEE directive has a framework
of collective producer responsibility.[240]
This means that the cost of recovery, recycling and re-use are
absorbed collectively by all producers, therefore an individual
producer has no specific incentive to make their products easier
to recycle or re-use. The Minister added that the Government is
"working with industry stakeholders to see if we could get
a system of individual producer responsibility which might improve
the incentives".[241]
161. In addition to improving collection rates,
another option would be to extend the WEEE directive. Currently
it covers domestic but not commercial or industrial electrical
and electronic waste.[242]
The Society of Chemical Industry said that "to increase the
recycling of metals generally, a strategic review of the efficiency
with which industries and local authorities deal with their waste
inventory is needed".[243]
Mr Hetherington, BMRA, recommended that "the WEEE regulations
should be expanded to cover industrial and commercial waste".[244]
162. We are pleased that the
metal recycling industry in the UK is recycling 90%, by weight,
of collected waste and that substantial quantities of platinum,
rhodium, palladium, gold and silver are being recovered, mainly
from recovered waste electrical and electronic equipment. However,
it is of great concern to us that some strategic metals, which
are often in products in small quantities, are likely to be lost
in the 10% not being recycled.
163. We are satisfied that the
Government is working with industry stakeholders to see if implementation
of the WEEE directive could be improved with a system of individual
producer responsibility. We consider that the Government should
continue to work with key stakeholders to identify other means
of improving WEEE collection rates. In addition, we recommend
that the Government work with EU partners to carry out a cost-benefit
analysis of extending the WEEE regulations to cover commercial
and industrial waste.
EXPORTING METAL WASTE
164. Within the waste industry, metal recycling
is exceptional, as the BMRA explained: "the recycling of
metals is generally cost effective and it is notable that BMRA
members buy every ton of 'waste' metal that they process, unlike
any other part of the waste industry".[245]
Mr Hetherington, BMRA, stated that the largest WEEE processing
facility was in Newport and that "the UK is a major importer
of waste electrical and electronic equipment".[246]
165. However, other organisations expressed concern
that the UK was exporting large quantities of scrap metal, including
bulk metals, such as iron, copper and aluminium, as well as some
specialist metals, such as tungsten.[247]
Given that these waste materials are a potential resource (see
paragraph 144) for the UK, it seems questionable to be exporting
them abroad. Dr Rickinson, IOM3, explained that this was because
there were few places left to process scrap metal in the UK.[248]
For example, IOM3 explained the reason for exporting copper out
of the UK:
the logistic network to collect and segregate copper
scrap is in place within the UK, but the downstream investment
to remove the polymer and other sheath materials from the copper
and then to remelt and cast this is not in place. Commercial and
environmental concerns are important here. Insulated cable can
be granulated and the plastic coating removed from the copper
to use both materials in a controlled recycling loop. By contrast,
an easier solution is to burn the plastic coating off the copper
cable directly in the melting furnace. This creates environmental
issues which, within the UK, would be expensive to overcome.[249]
166. The environmental problem created by burning
away the plastic coating is therefore being exported elsewhere.
IOM3 suggested that "no melting facilities are available
in the UK due to the high investment cost required to satisfy
all legislation [e.g. environmental] and to make a commercial
return".[250]
IOM3 added that there were, however, some alternatives to burning
the plastic coating in order to separate out the copper.[251]
167. The export of metals for recycling elsewhere
was also viewed by others as environmentally damaging.[252]
Mr Hartwell, ESKTN, described it as being akin to "exporting
carbon credits" due to the energy saved re-melting scrap
compared to extracting metal from the ground.[253]
There have also been reports in the media highlighting the negative
social impacts of waste electrical and electronic equipment that
is being exported for processing abroad.[254]
Mr Swindon, MMTA, stated that he had "seen grannies in their
80s in the freezing cold in China taking apart these pieces of
scrap metal".[255]
The Society of Chemical Industry added that:
the ethics of recycling are occasionally very poor
indeed [...] the export by sea of huge quantities of metals has
ethical implications in that their initial 'reprocessing' in India,
China and the Philippines is often crude and environmentally damaging
[...] we have a legislative framework in place which, by and large,
prevents ethically unsound practice in the UK, but once out of
our control becomes very difficult to manage.[256]
168. Given that scrap metal
and waste electrical and electronic equipment are a potential
resource for the UK, it seems nonsensical to be exporting them
abroad. The Government should be actively working towards minimising
the export of these materials. We are also concerned that the
export of scrap metal and waste electrical and electronic equipment
abroad for recycling is, in effect, exporting our environmental
problems elsewhere. We recommend that, where exporting has to
take place, the Government engage with the governments of the
countries importing these materials to encourage higher environmental
standards and adequate working practices for those processing
the goods material.
Illegal export of WEEE
169. By law, WEEE should be processed in the
EU. WEEE that is exported illegally is often labelled as second
hand equipment for re-use. A recent European Commission report
on waste management highlighted concern about the illegal export
of scrap within and from the EU:
More than 10,000 joint inspections on waste shipments
were carried out [...] demonstrating that about 19% of transfrontier
shipments of waste were in violation of the waste legislation
[...] illegal export of waste is a continuous problem which is
by essence difficult to quantify.[257]
170. In the UK we note that in November 2010
a group of individuals were charged with the illegal export of
WEEE from the UK after an Environment Agency investigation.[258]
171. We note that the Environment
Agency has responsibility for initiating enforcement where the
illegal export of WEEE is suspected. We recommend that the Government
ensure that the Agency is sufficiently resourced to carry out
this responsibility effectively. Given that WEEE is often exported
under the cover of re-use, the Government needs to put in place
safeguards to ensure that WEEE for export and labelled for re-use
is being used for this purpose.
176 For example, "Waste: reduce, reuse, recycle",
DirectGov website, November 2009, www.direct.gov.uk Back
177
Q 43 [Mr Brimacombe] Back
178
Ev w3, para 3.1 Back
179
Ev 42, para 26 [BIS] Back
180
"About Us", WRAP website, 2011, www.wrap.org.uk Back
181
Q 57 Back
182
Ev w35, para 3.1 Back
183
Q 44 Back
184
Ev 41, para 25 [BIS] Back
185
Q 144 Back
186
As above Back
187
Q 55 Back
188
Ev 59, para 26 Back
189
Q 55 Back
190
Q 49 Back
191
Q 22 Back
192
Qq 57-58 Back
193
Q 22 Back
194
Q 57 Back
195
Q 39 Back
196
Q 39 Back
197
Ev w32, para 33 [Research Councils UK] Back
198
As above Back
199
Q 11 Back
200
Critical Raw Materials for the EU, Raw Materials Supply
Group, EC, July 2010 Back
201
Ev 72 Back
202
Q 44 Back
203
Q 6 Back
204
As above Back
205
Q 51 Back
206
Q 52 Back
207
Q 54 Back
208
As above Back
209
Q 151 Back
210
Q 98 Back
211
Q 55 Back
212
Q 49 Back
213
"Solutions for the electrical products sector", WRAP
Website, 2011, www.wrap.org.uk/retail_supply_chain/ Back
214
Q 162 Back
215
Ev w32, para 32 Back
216
Ev w32, para 33 Back
217
Q 43 Back
218
As above Back
219
Q 11 [Dr Rickinson] Back
220
Ev w32, para 30 Back
221
As above Back
222
Ev w32, para 34 Back
223
Ev w26, para 8 Back
224
Q 14 Back
225
Q 146 Back
226
As above Back
227
Q 75 Back
228
Q 32 Back
229
Ev 41, para 25 [BIS] Back
230
Ev 42, para 27 [BIS] Back
231
Ev w32, para 31 Back
232
Directive 2002/96/EC of the European Parliament and of the Council Back
233
Q 162 Back
234
Q 43 Back
235
Q 44 Back
236
"Recast of the WEEE directive", European Commission
Website, 22 March 2011, http://ec.europa.eu/environment/ Back
237
As above Back
238
As above Back
239
Ev w26, para 9 Back
240
Q 164 Back
241
As above Back
242
Q 44 Back
243
Ev w26, para 7 Back
244
Q 56 Back
245
Ev 57, para 9 Back
246
Q 55 Back
247
Ev w18, para A3.1 [Wolf Minerals Ltd]; Ev 45 [IOM3];
Ev 49, para 17 [ESKTN]; Ev 56, para 1 [BMRA] Back
248
Q 28 Back
249
Ev 46 Back
250
As above Back
251
Ev 44 Back
252
Ev w27, para 14 [Society of Chemical Industry: Construction Materials
Group] Back
253
Ev 50, para 26 Back
254
"Breeding Toxins from Dead PCs", Guardian Website,
6 May 2008, www.guardian.co.uk/environment/; "Organised Crime
Targets Waste Recycling", Guardian Website, 8 July
2009, www.guardian.co.uk/environment/ Back
255
Q 101 Back
256
Ev w27, para 10 Back
257
European Commission report on the thematic strategy on the prevention
and recycling of waste, COM(2011) 13 Back
258
"Eleven named in biggest investigation into illegal WEEE
export", MRW, 12 November 2010, www.mrw.co.uk/news/ Back
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