Waste crime illegal operators
Firstly, with metal prices remaining high, the problem of metals theft is not going away. An increased focus on the identification and prosecution of illegal, unpermitted sites is absolutely key to containing the outlet for stolen metal, deterring thieves and eliminating unfair competition for all those permitted sites that operate under the heavy burden of compliance.
Environmental protection agencies have traditionally put all their efforts into enforcing environmental regulations on the compliant leaving illegal sites somewhat under the radar.
The metals recycling sector is plagued by unfair competition from unregulated operators that damage the industrys reputation, the environment and local communities.
The review has stated that Government will ensure that enforcement bodies have sufficient resources to tackle such illegal sites something the 5 billion UK metals recycling industry welcomes.
It aims to deliver a more strategic national intelligence-led approach to tackling metal theft, targeting illegal traders whilst ensuring that law abiding businesses can trade safely. And by working with the relevant authorities, it will examine how to strengthen enforcement of the waste carrier regime, including revocation of registration against those who repeatedly flout the waste carrier registration rules and undermine legitimate business.
Regulatory reform
We now need to see Government reducing the burden of compliance on legitimate business, and thus continue to push for a sector-based approach to regulation that recognises the distinctive and low-risk characteristics of the vast majority of metals recycling activity.
We are particularly keen to see the roll out of the much talked about standards-based approach to regulation which would elevate environmental protection to being a board-level issue for companies rather than being a technical compliance concern as it is now.
Generating energy from shredder residue
Secondly, we are pleased to see Government has pledged to remove barriers from energy from waste, something which is absolutely critical if we are to meet tough European targets in terms of recycling and recovery. For metals recyclers, this is particularly an issue when it comes to End of Life Vehicles (ELVs).
Although metals recyclers are recovering and recycling more material than ever before from ELVs already over 85% and developments in technology mean more is possible, there will still be a fraction left over which cannot be recovered into discrete material streams. Therefore the only options remaining are to send it to landfill or use as a fuel for generating energy.
However, the debate about whether generating energy from this shredder residue should be classed as recovery (rather than disposal) continues. It was hoped that thinking on this would have been much further developed and so BMRA continues to consult with Government on clearing the way for the UK to determine a definition of recovery for the pioneering processes employed to generate energy from this unique waste stream.
Solid policies are now critical
Although many of the themes in the review, and the fact that Government has taken on board industry comments during the consultation, have been welcomed BMRA remains disappointed that so little progress has been made on putting some detailed policy in place after more than a year of work.
Developing these policies and putting necessary infrastructure in place is now becoming critical.
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