As revealed by letsrecycle.com last year (see letsrecycle.com story), new end-of-waste criteria for metals could mean that reprocessors currently accredited to issue packaging recycling evidence face the risk of being frozen out of the UK system and replaced by a new set of metals businesses earlier in the recycling chain.
When the PRN system was set up more than 10 years ago, there was much debate about which part of the recycling chain could issue PRNs.
This was because the notes have a value and much of this value can be retained by the issuer to develop recycling, which can, for example, include funding of new collection vehicles or to pay for recycling campaigns.
Originally waste paper merchants and scrap yards lower down the recycling chain argued that they should issue PRNs but Defra decided that only reprocessors, such as paper mills and steel mills, should be allowed to do this, primarily because material was still seen as not being fully recovered from being a waste until it had been reprocessed.
One notable exception then was the detinning operation run by AMG which was deemed to be a reprocessor even though it did not melt the cans involved.
Down the chain
Now, the end of waste criteria for metals have been changed and this will see metal not being a waste further down the chain, although exact details are still being resolved. Accordingly collectors of the material, it is thought, ranging from local authorities through to waste companies and metal recyclers/scrap metal merchants could be eligible to issue PRNs.
The consultation is thought to have come as something of a surprise to the packaging waste sector because it has come before the Waste Review has been published and is thought to have been undertaken with producers of obligated packaging waste (such as retailers, canners, bottlers etc) rather than compliance schemes.
Defra statement
The full implications of the criteria for steel, aluminium and iron which were agreed by the European Commission in March 2011 (see letsrecycle.com story). The current PRN consultation comes in a Defra statement headed: End of Waste Regulation (metals) and the Producer Responsibility Obligations (Packaging Waste) Regulations.”
In the statement, Defra says:
“At the Transport Council on 31st March 2011 the EU End of Waste Criteria Regulation for certain types of scrap metal was adopted. The Regulation entered into force in April following its publication in the Official Journal on the 28th April and will directly apply from 9th October 2011 in all member states.
“Where the criteria are met, the practical effect of the Regulation will be to set the point at which the specified types of scrap metal cease being waste, which may change the point at which such materials are considered to have been recovered/recycled.
“The adoption of this Regulation has direct implications for the UK packaging recovery system. Within the Packaging Regulations there is no definition of the point of issue for a PRN/PERN. The ability to issue PRNs is linked to the recovery of packaging waste and the Regulations define recovery as any applicable operation provided for in Annex II to the Waste Directive.
“Any business engaged in the recovery of waste packaging can apply to be accredited as a reprocessor, stating which recovery process (and material) they wish to be accredited for.
“Based on compliance with the end-of-waste criteria established under the Council Regulation, a new group of businesses may now be able to show that they have recovered the waste metals and so apply to be an accredited reprocessor.
“Following the coming into force of the end-of-waste criteria established under the Council Regulation on 9th October 2011, the scrap metal may cease to be waste before it reaches those currently accredited as reprocessors or exporters if it meets the criteria. If that is the case, it is no longer considered packaging waste and PRNs cannot be issued against it by those accredited reprocessors or exporters who receive the material
“Existing established reprocessors would still be eligible to be accredited and able to issue PRNs, but only on material they received which had not already had a PRN issued against it.
“The Environment Agencies will issue revised guidance for the next accreditation round and it is envisaged that the changes will take effect for the 2012 obligation year.
“Due to the scope of the likely changes, we would welcome any comments from interested parties on how the system will function and any operational risks and how to manage them.”
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