The warning comes as more details about the Code come to light following the Department for Environment, Food and Rural Affairs (Defra) meetings with key stakeholders.
The Code, which is being developed by Defra, WRAP, the Environment Agency and the Environmental Services Association, was first announced in June 2011 (see letsrecycle.com story). Defra is continuing talks with stakeholders in a bid to finalise proposals before it is put out to consultation this summer. It is expected to make the code mandatory.
In an update to stakeholders issuedlast month,Defra said that the Code would establish a consistent, industry-wide method for sampling and testing the quality of input and output material streams.
The department explained the Code would not outline quality standards and would not be limited to MRFs. The materials the code is expected to cover include: paper and card; steel and aluminium cans; plastics; and, glass.
Speaking to letsrecycle.com Simon Ellin, chief executive of the Recycling Association the trade association for independent waste paper processors and their suppliers – said that the Code is starting to take shape. He said: It is still a work in progress. One of our members took part in a working group the week before last where they established how the quality testing procedure would actually work. For example before the material leaves the facility they would need to sample so many bales and measure what is in them.
It will be a standard quality testing procedure that will be adopted across all MRFs. If you fall under the category of a MRF then there will be a minimum amount of testing procedures you must implement to ensure the quality of the final product.
Red tape
However, Dr Ellin warned that the Code could impact smaller players if it is made mandatory due to an increase in costs because of the additional quality testing.
He said: The concern is over the criteria that governs what is a MRF and that is any facility that processes more than 1,000 tonnes-a-year of material and separates out any two components of cardboard, glass, plastics and metals. 1,000 tonnes-a-year is not a great deal of material and we are concerned that some of our smaller members that might have a small trommel in the yard become classified as a MRF and are then wrapped in more red tape as they are having to undertake regular sampling procedures which will mean that costs go up.
While Dr Ellin said that it is more and more likely that the code will become mandatory, he said that it would work as a voluntary scheme if councils were to take charge and embed the code into contracts.
ESA
Meanwhile the Environmental Services Association (ESA) has said that the Code should be made mandatory.
David Sher, policy advisor for materials and energy recovery at ESA, told letsrecycle.com: If its not compulsory then we would need to reconsider how we could implement it. We think this is a good change for the market and we dont see why they shouldnt make this mandatory.
Mr Sher said he is confident that Defra will take the ESAs views on board. He explained that Defra was in talks with stakeholders, including local authorities and reprocessors, as it will affect the whole supply chain and not just MRF operators.
He explained: It will affect reprocessors as well, moving down the supply chain. They have a stake in this as a customer. These are changes in the stock of the market that we think should be to the benefit of the whole supply chain. We think it is a good idea and we are keen to see it taken forward to get both the regulations to back it up and the broad industry consensus to make it work.
Resource
The Resource Association, the trade body for reprocessors, also supports the view that the Code should be made mandatory. Many of the associations members have been calling for more focus on the quality of recovered materials collected.
Ray Georgeson, chief executive of the Resource Association, said: The Resource Association supports Defra in its desire to make a revised MRF Code of Practice mandatory, under the Environmental Permitting Regulations as they have publicly indicated. We believe that a proportionate but robust regulatory approach is needed to ensure that the recycling supply chain is capable of delivering consistent high quality feedstock to UK reprocessors.
He added: Reprocessors need quality recovered materials to make quality products, and to continue to contribute to the growth of the green, low-carbon economy which creates jobs and improves resource efficiency here in the UK and Europe. We are actively engaged in the stakeholder consultation being conducted by Defra, and will continue to express the needs of reprocessors directly into that process.
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