There is a danger that the UK will miss its 2008 Packaging Directive metal recycling targets.
But this is not necessarily because too little recycling is being done. It's more a matter of what can be officially counted towards the targets.
When the European Directive was transposed into the UK's Packaging Regulations, a broadly equivalent requirement was implemented, which affects UK exporters sending materials to overseas reprocessors.
For packaging waste recycled outside Europe to count towards UK targets, exporters must obtain evidence from reprocessors showing recycling conditions are broadly equivalent to European standards.
Then exporters can issue evidence notes, Packaging Waste Recovery Notes PRNs) and Packaging Waste Export Recovery Notes (PERNs), to UK producers.
However, getting the evidence to ensure overseas reprocessors can be accredited is proving difficult, particularly for metals waste packaging exporters.
Because of this, metals trade associations Alupro and the British Metals Recycling Association (BMRA) say that the broadly equivalent requirements have had a significantly negative impact on the reporting of overseas metals recycling.
Export reporting is paramount for the UK to hit targets because so much material is recycled outside the EU. In 2006, 50% of recycling evidence for steel packaging was from export sources, while it was 23% for aluminium.
So, why is it so difficult to get evidence?
Metal is different from other recycled materials because it has such a intrinsically high value. In the absence of broadly equivalent evidence, and therefore accreditation, exporters will continue to ship waste packaging outside the EU.
For reprocessors the cost of producing evidence relative to low tonnages is inhibitive.
Global metals markets also use traders and brokers, who are unwilling to provide commercially sensitive details of reprocessor clients to UK exporters for fear that they will be cut out of deals. Broker traded loads are also often broken up into a number of lots, which go onto different reprocessors making it difficult for exporters to identify the final recovery facility. Exporters also potentially have many customers so the burden of providing evidence can be significant.
PERNs alone are not a big enough incentive to produce evidence.
Alupro executive director Rick Hindley said: "The organisation estimates that up to 5,000 tonnes of aluminium packaging has not be officially reported."
But the Government acknowledges a need for change. It has just completed a consultation on revising the broad equivalence requirements for export reprocessing sites and Alupro welcomes such "streamlining of requirements".
Changes would mean that the Environment Agency (EA) could exercise discretion on what it considers evidence of broadly equivalent.
The EA would use a proposed set of conditions inspired by the end-of-waste criteria for scrap metal, of which the consultation document
said: "It is expected that only metal exporters will be able to avail themselves of the new provisions of the regulation."
However, Wastepack director of compliance Peter Gaffney said: "The draft regulations do not mention that the proposed changes apply to metals only. This could lead to other materials sectors challenging the regulators."
Other responses to proposals include a call for reprocessor accreditation to be for three years as opposed to annually. Both Alupro and the BMRA say this will reduce the burden on exporters. BMRA policy spokesman Howard Bluck warned: "Annual accreditation would be overly burdensome to the extent that they may not register as an accredited exporter, significantly reducing availability of PERNs."
The Government also proposes a central list of accredited overseas reprocessors. This was generally welcomed in the sector, as some respondents said it would prevent the perceived accreditation inconsistency and remove duplication of effort of collecting evidence. According to the consultation, the EA has already started work on the list. However, there was some disagreement about how information for the list should be gathered and how its development should be funded. The Government proposes that trade organisations could contact overseas Governments directly to request information.
However, Bluck said:"We believe trade associations will have extremely limited success in getting any responses. We would propose that any contact with overseas Governments should come from the UK Government."
The consultation also suggested that money from the PERN system could be used to develop the list and pay for overseas inspections to accredit reprocessors. But Bluck said: "We do not believe that PERN revenues should be used to fund overseas site visits by the EA or other expert witnesses until the European Commission has concluded its 'end-of-waste' research on metals. If fully-processed, furnace-ready recycled metals are re-categorised as non-waste, such site visits would be a costly, but ultimately irrelevant exercise."
While policy revisions are still being finalised it seems that changes must be made or, as most in the sector predict, targets will be missed.