Strategically important metals - Science and Technology Committee Contents


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 electronics—our 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 resources—finished and semi-finished goods and waste—in 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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