Memorandum submitted by British Metals
Recycling Association (BRMA)
In response to the Select Committee's announcement
of an inquiry into Hazardous Waste Disposal, this memorandum is
submitted by the British Metals Recycling Association (BMRA).
The BMRA is the trade association for the metal
recycling industry in the UK, which has an annual turnover of
some £4 billion. The sector plays an important role in the
UK economy, employing over 10,000 people and generating significant
export revenue, in excess of £2 billion. The BMRA represents
some 320 members who, collectively, recycle around ten million
tonnes per annum of ferrous and non-ferrous scrap metal into secondary
raw materials. The BMRA thanks the Environment, Food and Rural
Affairs Committee for the opportunity to submit evidence.
We recognise the need for waste which is genuinely
hazardous to be controlled and disposed of in a proper manner.
Our main concern with hazardous waste disposal is to ensure that
regulation, when applied, does not become so onerous that established
recycling routes for materials which might be nominally classed
as hazardous, eg lead, become non-viable. There is a great danger
that the classification of materials and products as hazardous,
for example by means of their being "starred items"
in the European Waste Catalogue (EWC), invokes a whole set of
controls and restrictions which had hitherto been considered unnecessary
as they were being recycled effectively.
A classic example is that of End of Life Vehicles
(ELVs). From January 2002, undrained ELVs are classified in the
EWC as hazardous waste, which means that, in theory, additional
controls and documentation will be needed for their collection,
transportation and treatment. These will add to the cost of an
already expensive process for the depollution of vehicles in accordance
with the End of Life Vehicles Directive-also due to be introduced
this year. In fact, most ELVs are no more hazardous than a vehicle
in current use, and the point at which it suddenly becomes hazardous
when somebody decides to dispose of it is hard to comprehend.
It is equally confusing that an ELV that is "rescued"
from the waste stream by somebody taking remedial action with
the vehicle, not its hazardous elements, miraculously becomes
The Committee has indicated its intention, inter
alia, to examine the steps taken by the Government to prepare
for the implementation of the ELV Directive. In our view, this
has been woefully inadequate, partly as a consequence of a desire
to exercise a light touch, which meant that it did not want to
impose more rigorous measures than other Member States, but predominantly
because of a failure to recognise the need for infrastructure
developments to be funded, both for investments in facilities
and ongoing treatment costs. Even now, we still have no visibility
on this, as a result of which there will be serious inadequacies
in the infrastructure for some time to come.
Another example is Electrical and Electronic
Waste (WEEE) and white goods in particular. These, too, are being
classified as hazardous, and this will impose additional controls
and costs on the operators, particularly those in the retail sector,
who will find it increasingly difficult to justify continuing
their existing collection rounds. Refrigerators which, until December
2001, had been routinely recycled by the metal recycling sector,
suddenly became a liability with the imposition of the Ozone Depleting
Substances Regulation in January 2002, and huge stockpiles of
scrap fridges was the result. Admittedly, this was not because
they were hazardous, but it is a clear illustration of what happens
when heavy-handed regulation is imposed on an established and
We would like to stress that for both Metallic
Waste and End of Life Vehicles and, to a lesser extent Waste Electrical
Equipment, sophisticated and well-developed infrastructures are
already in place, employing a great many people and achieving
very high levels of recycling. They exist because their processes
are economically viable and the companies involved, many of whom
are our members, can make a reasonable return on their efforts
and investments. If those returns, which are not by any means
great, are diminished by the imposition of excessive controls
and compliance costs, businesses may well decide that continuing
with their recycling is not a worthwhile option.
In conclusion, we would urge the Committee to
consider the potential negative consequences of gold-plating any
legislation on Hazardous Waste Disposal to the extent that established
routes for recycling these materials or products are destroyed,
because it is easier and cheaper to consign them to landfill.
If Committee members require any further information,
representatives of the BMRA would very much welcome the opportunity
to explain and expand upon these views in more detail at the Committee's
British Metals Recycling Association
27 May 2002