The government brought in the first of two stages of new regulations on the recycling of vehicles that have come to the end of their natural lives last month (see letsrecycle.com story). The second set of regulations is expected to go to consultation later this month.
The BMRA has warned of a “severe contraction of the metals recycling sector – by far the largest UK recycling sector – with a collapse of SMEs in particular” because of the nature of the new regulations. It also foresees an increase in the level of abandoned vehicles and the prospect of missed recovery targets in years to come because of the new regulations.
The BMRA believes the government has “largely ignored the metals recycling sector” in opting for the 'Own Marque' system favoured by vehicle manufacturers. The system sees manufacturers organising contracts with recyclers to handle their own branded vehicles. Despite assurances that officials were still considering alternatives to this system, the BMRA has said this was not the case.
In a statement to Parliament, the Association said: “The sector has been misled by (government) officials – despite assurances when consulted earlier this year on the vehicle assemblers/importers preferred 'Own Marque' option that all other alternatives remained open, despite finding the scheme impracticable, Government has now advised that it is now too late to consider any other option.”
The BMRA is giving evidence to a Parliamentary inquiry on the government's implementation of the ELV Directive and the Waste Electrical and Electronic Equipment (WEEE) Directive. The inquiry begins next week (11/11/03), but the BMRA has submitted evidence in writing.
Funding
Rather than the Own Marque system, which would provide no guarantee of contracts for any business, the metal recyclers would have preferred to see a more flexible funding mechanism such as a recycling levy or vehicle recycling note system. This would have meant that recyclers could have received funding for any car treated, without the need to win contracts with certain manufacturers.
In going for the Own Marque system, the BMRA said the government had failed to link producer responsibility for vehicle take-back to responsibility for meeting associated recycling costs.
It said: “We are faced with a late and hotly disputed implementation plan for ELVs, in which the many practical arguments put forward by the metals recycling sector – one of only two key stakeholders – have been largely ignored in an effort to achieve “a light regulatory touch” on the UK vehicle assembly industry.”
The government's impact assessment of the regulations suggested that 420 million to 907 million would be needed over the next ten years for upgrading ELV recycling and dismantling sites to meet the treatment standards required by the new regulations. However, since the majority of ELV recyclers will find themselves without contracts, the BMRA said few are putting in the investments needed.
Failure
The Association warned: “Operators who currently process ELVs have not invested in additional facilities to meet the new requirements of the Directive, because they cannot see how it will be funded and hence make a business plan to justify the investment. This is likely to lead to a shortage of treatment capacity to the required standards, an increase in abandoned vehicles, and a failure to meet the 2006 recovery targets.”
In a stinging attack on the government, the BMRA suggested that officials had a poor understanding of commercial markets and called DEFRA's ability to cope with the legislation “questionable”.
It said: “DEFRA's capacity to deal with these Directives is questionable. There have been a number of occasions during the development of the ELV Directive when papers have been held up due to a lack of legal advisors in DEFRA, without which the drafts could not be released. Agreed positions have been varied or reversed with no or little explanation. There appears to be limited or poor dialogue between DEFRA and Environment Agency officials.”
Implementation of WEEE Directive “is likely to be less contentious” than the ELV regulations, the BMRA said, but noted that there is still cause for concern over the “painfully slow” progress of the revisions to the WEEE recycling permitting regime.
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