The British Metals Recycling Association (BMRA) welcomes the publication of Government’s Resources and Waste Strategy. The Strategy contains many encouraging statements and shows a definite intention to focus on moving products through the waste hierarchy more effectively from encouraging sustainable design to promoting reuse and recycling.

However, we are disappointed that the Strategy focuses on single-use plastics and household waste to the detriment of other materials including metals and durable plastics, as well as wider waste streams. While all steps that will protect the environment are laudable, in focusing on highly topical items such as single use plastics and food waste, Government has missed a perfect opportunity to  overhaul the country’s entire approach to waste.

To achieve true circularity, producers need to be pushed to design products that not only last longer and can be repaired  but that can be recycled more easily. They need to take a ‘design for end-of-life’ approach not a ‘design for manufacture’ approach.

We believe that, in order to be able to meet its objectives of maximising the value of resources and minimising waste, Government should have made a clearer distinction between ‘resources’ and ‘waste’. We believe that waste should be defined as ‘a material, substance, or by-product that cannot be used, reused, repaired, reprocessed, repurposed, recycled or used for energy.’ Put simply, until it is landfilled, that item, product, material, substance, or by-product is still a resource because it still has a value.

Given the potential volumes arising, it is very concerning that the Strategy makes scant reference to waste streams other than single-use and packaging plastics. These other streams represent a large percentage of the waste arisings in the UK. For example:

• The UK recovers around 12 million tonnes of scrap metal for recycling every year. This compares to the 4.7 billion plastic straws, which equate to around. 2,000 tonnes
• On average, BMRA members process 665,000 tonnes of durable plastic derived from end-of-life vehicles and waste electrical and electronic equipment (WEEE) alone yet durable plastics were not considered in the Strategy’s Circular Economy for Plastics.

We believe that Government should be celebrating and better supporting sectors that are leading the way in recycling, including metals. For example, the overall recovery rate for ELVs, which contain 1,000s of components and made from dozens of different materials, is around 92%. For plastic bottles, which only have three polymers, the rate sits around 35%. If Government truly wants to meet many of its objectives and targets, it should be asking serious questions of waste management companies.

We agree, however, that there also needs to be a review of extended producer responsibility (EPR) schemes and associated waste regulations such as packaging to ensure they are all fit for purpose. For example, we believe that any packaging reform should use the opportunity it creates to address the capture and disposal of gas cylinders, which are a serious health and safety concern across the waste industry.

Whilst the Strategy sets out a series a commendable objectives and targets, there is little detail on how many of them will be achieved, let alone funded.  We are very concerned that its aspirations for tackling waste crime may be unachievable due to the lack of knowledge, people and funding.

Focusing on ten waste exemptions to reduce illegal activity will not tackle waste crime effectively, not least because exemptions do not attract fees and charges so there will be no monies, other than Grant-in-Aid funding to police this sector.

Without a ‘root-and-branch’ review of how the waste sector is permitted and monitored by the Environment Agency and beyond, it will be exceedingly hard to fund and tackle waste crime, including the proposed Joint Unit for Waste Crime. Alongside an overhaul of the waste carriers licensing system, Government, or rather the Treasury, should allow the EA to using a proportion of permit monies to tackle illegal operators. BMRA also believes that oversite of all permits should be given to the EA, which would mean removing responsibility for issuing scrap metal dealer licences from Local Authorities.

Finally, that the strategy does not offer any real support for developing the market for secondary resources onshore. Currently, BMRA members export over 80% of metals recycled to be processed elsewhere because there are not enough foundries or smelters operating to buy this material. The same is currently true across nearly all waste streams. Unless businesses are supported through fiscal measures such as tax relief, as recycling rates increase that material, be it metal, paper or plastic, will continue to be exported destroying any proposed resource security.