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Welcome for end-of-waste regs but much is left unclear for traders

With the arrival of the long-awaited End-of-Waste Regulations for iron, steel and aluminium scrap, the industry has breathed a collective sigh of relief.

The news was widely welcomed by the British Metals Recycling Association (BMRA), and in particular the European ferrous recovery and recycling federation, which described the change as a “legal recognition that has been wanted for 20 years”.

Despite broad support for the Regulations, it appears that few in the industry are aware of what they will mean for their business in practical terms.

A Sims spokesman told MRW: “The change of classification is welcome. However we are presently awaiting further details on the practical implications in implementing this change so that we can take a more informed view.”

When the Regulations come into effect on 9 October 2011, what will they mean for the industry and who will benefit?

The answers are not yet clear. MRW understands that there is concern from small scrap traders about the opaque nature of the legislation. The regulations state that once the end-of-waste criteria have been met, the producer must “demonstrate compliance with the criteria” by “implement[ing] a quality management system”.

“A conformity assessment body…shall verify that the quality management system complies with the requirements of this Article. The verification should be carried out every three years.”

It is also expected that at least every six months as part of self-monitoring requirements, merchants will “take representative samples of foreign materials [to] be analysed by weighing after magnetic or manual (as appropriate) separation of iron and steel particles and objects under careful visual inspection”.

Some in the industry believe this refers to the ISO90001 quality management system, which will mean that only larger, ISO- accredited merchants will be able to trade their post-waste material. This will therefore prevent smaller, unaccredited businesses from intervening in the market.

Merchants believe this to be so following cases in previous years, where British steelworks threatened not to take any material from merchants which were not ISO9001 accredited. But it did not happen and works had to backtrack.
However, the BMRA disagrees. It believes the opaque wording of the regulation is a benefit to smaller merchants rather than a detriment.

A spokesman told MRW: “We feel the regulation does not [specifically] require ISO compliance, and any suitably accredited quality management system is acceptable. The fact is that many of the internal systems that traders already use to prove their processes and quality to customers will help them to comply. The ISO is only one way of meeting the criteria.”

Concerns have also been raised over the vague wording of the criteria themselves. The legislation demands that recovered scrap “shall not contain excessive ferrous oxide in any form, except for typical amounts arising from outside storage of prepared scrap under normal atmospheric conditions”.

But it is not clear what ‘excessive’ or ‘typical’ quantities of iron oxide mean or how these quantities are to be measured.

Although the regulations appear to be a benefit for the scrap metal sector, it will be some time before the full implications of the regulations are understood, and the sector can judge whether these legislative changes really are welcome or not.

WHAT ARE THE CRITERIA?

The End-of-Waste Regulation sets out specific criteria which determine the point at which scrap metal ceases to be waste, these are:

  • When the total amount of foreign materials is less than, or equal to, 2% by weight [of the metal]. In this instance, ‘foreign materials’ mean non-ferrous metals and non-metallic materials such as earth, dust, insulation, glass, rubber, plastic, fibre, organic substances, non-conductive brick-sized pieces such as tyres, wood or concrete.
  • The scrap cannot contain ‘excessive’ amounts of ferrous oxide, but ‘typical’ amounts which arise from outside storage of scrap are allowed.
  • The scrap must be free of visible oil, emulsions, lubricants and grease except for ‘negligible amounts’, and cannot contain pressurised, closed or ‘insufficiently open’ containers that could explode in a furnace.
  • In order to reach these points, iron or steel scrap must have been segregated at source. Mechanical treatments to prepare the metal for direct input into steelworks and foundries must have been completed. Such treatments include cutting, shearing, shredding or granulating, sorting, separating, cleaning, de-polluting and emptying.
  • Filings and turnings or barrels and containers holding oil or oily emulsions are not allowed as inputs. The only exception is equipment from end-of-life vehicles, which contain or have contained oil or paints.

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