And, a review of the evidence system is to be carried out by the government and the environment agencies for all categories of WEEE and derived materials.
Full details of the review are expected in April and will include an examination of other producer responsibility regimes in the UK and elsewhere in the European Union.
The Department for Business Enterprise and Regulatory Reform (BERR) said today that it was taking action. This comes in the wake of concerns from approved authorised treatment facilities that they were facing difficulties when the metals derived from WEEE were to go abroad for reprocessing.
Stockpiles
Metals exporters such as EMR, Nortons and Sims may keep stockpiles of metal at the dockside for some months before material is exported. And, the metals industry is also thought to have found it hard to keep track of the volumes of metal from WEEE when these are mixed with other metals.
As a consequence, the industry has been reluctant to issue paperwork confirming the metals had been exported in case they were still on the dockside. This hiatus meant that AATFs could not get the evidence per tonne that they needed in the form of a document saying the metals had been exported for reprocessing.
While the Environment Agency spoke of adopting a flexible approach to the situation, one AATF operator told letsrecycle.com that “there was a real vagueness to the system and obtaining the piece of paper necessary to say the metal had been exported was a real difficulty.”
Complex
Now BERR has stepped in and said that it will investigate the “complex” issues involved and has introduced an interim system to speed up the issuing of evidence. The system will apply for the first compliance period (the last six months of 2007) and the second compliance period, (all of 2008).
BERR said today that: “AATFs dealing with metal derived from WEEE destined for export can with immediate effect, issue evidence of collection, treatment and reprocessing at the point that metal has completed all necessary treatment processes in the UK. That is the metal derived from WEEE is in a state to be placed into a smelter for reprocessing without further treatment. These arrangements are for Compliance Period 1 and Compliance Period 2 only.”
The interim arrangement is specifically for WEEE-derived metals to be exported. It will not, said BERR, be applied to whole appliances or other WEEE derived materials for export nor will it apply to metals or other materials to be reprocessed within the UK.
One AATF operator is the south of England said that it welcomed the decision as “a good move. This is a pragmatic solution and should speed up the issuing of evidence.”
Source-segregated
In comments on its decision, BERR has emphasised that the metals must be source-segregated and need no further processing overseas.
In terms of keeping track of the WEEE metal, the department also said that the AATF issuing evidence must ensure they have appropriate documentation as part of the audit trail to show:
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The treated metal can be related to a tonnage of untreated WEEE received by the AATF;
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The treated metal is subject to a sales agreement with an approved exporter for reprocessing outside the UK, or where the AATF is an approved exporter, processes are in place within the organisation to show transfer from treatment to export;
Supplement
BERR will shortly issue a supplement to the Non Statutory Guidance Notes to confirms this position on exports and the environment agencies will also be amending and reissuing their guidance on evidence.
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