The Recycling Association are 100% behind an electronic system for waste shipments and it is something we have been lobbying strongly for.
We also believe that a hybrid system is the most sensible and pragmatic way forward as it will allow member states to use existing systems to feed into a central web based system and will allow a phased in and much quicker turn around.
If we were to wait for a uniform, bespoke pan-European system that all member states used, we would be arguing about the fine detail for years!
The concern I have is that the EA currently do not have a specific system in place to feed into this and we are hoping that in the midst of all the cut backs, this will not become lost. We do, however, know that the EA have bought into the concept and that it would make all our operations far easier.
Our particular interest in an electronic system really relates to Annex VII’s, the document that accompanies the export of green list waste. It is archaic that in the 21st century we are still relying on a paper based system that is posted, faxed or emailed and which I have grave doubts actually makes it to the final destination in many cases anyway. Common practise is to put the Annex VII form in the back of the shipping container – a sheet of paper in the back of a consignment of paper……hmmm…….
All green list waste has to be accompanied by a fully completed Annex VII form with the emphasis now from the EA now being on the word “fully” and the EA have given notice that they intend to fine companies who are found in breach of these during port inspections. Incompletely filling in a paper Annex VII form is actually quite easy, but if it was electronic and you couldn’t actually submit it unless everything was filled in, would be a massive improvement.
The same obviously applies for other forms, for example for notifiable waste.
One of our members has recently been fined for a load that was stopped in Germany for having an uncompleted form and this was for minor detail – an electronic form will obviously make this impossible.
Similarly, I attended a EUROMETREC meeting in Brussels earlier in the month and a big UK operator was outlining to the meeting that he had containers that were been held in Eastern Europe for (unspecified) alleged breaches of Annex VIIs and that he was being charged massive storage, rental and handling fees which he felt was totally unjustifiable. He strongly felt that the authorities in that country were using Annex VIIs as an excuse to extort money! Again, an electronic system would prevent this.
Also, and very importantly for many of our broker members, an electronic system should have the ability to keep some information confidential. We strongly feel that it is ludicrous that we have to release our customer’s details into the public domain for everyone to see – business confidentiality is a huge issue for the paper, plastics and metal industries and although Article 18 of the Waste Shipment Regulations does not protect business confidentiality as it stands, so legally you have to declare everything, Article 18 itself may be illegal on the basis that it does not protect business confidentiality.
It is ripe for a legal challenge and we and our Brussels partners are looking at this very closely.
Simon Ellin is the chief executive of the Recycling Association