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- Position on access to secondary raw materials - February 2004

- EU regulatory barriers to recycling


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POSITION PAPERS

Non-ferrous metals are defined as metals that contain a little or no iron; that category includes aluminium, copper, zinc, lead, nickel, gold, silver, platinum, titanium, manganese, magnesium, etc... Together with metal alloys made of a combination of two or more metals.

Non-ferrous metals are vital in today's industrial society.
Whilst their existence has been known for thousands of years, the important characteristics and the value of non-ferrous metals have only been identified and fully recognised since the Industrial Revolution. Today they fulfil many vital functions; they serve mankind in the production and transport of energy, they are essential for the manufacturer of safe and reliable vehicles, equipment and machinery; and they possess aesthetic qualities that can be used for artistic and creative purposes.

Centuries of recycling tradition.
Those unfamiliar with the recycling process can mistakenly believe that recycling is a new phenomenon brought about through legislation and public opinion. This view is incorrect and is damaging to this well established industry. The recovery and recycling industries are centuries old. In their current form, their origins can be traced back to the Industrial Revolution. These industries are made up of a large number of private companies which have been engaged in recovering, processing and marketing raw materials for many generations.

A modern and sophisticated industry.
Non-ferrous metal scrap companies obtain the materials from a wide variety of sources including industrial plants, car dismantlers, municipal authorities, demolition, food and beverage containers, construction, etc... They use heavy machinery and equipment and need large plant and storage spaces together which large transport fleets to deliver their raw materials to smelters and foundries ready to process. The metal scrap processor or recycler has to identify the metallic components and to sort and prepare them according to strict chemical and physical specifications in environmentally sound operations, before they can be converted into new metallic products - closing the recycling loop. Strict specifications have been drawn up by scrap processors and their customers in order to identify and categorise secondary raw materials before further transportation and consumption.

The benefits of recycling.
It is widely agreed that while most metals and the minerals from which they are produced are abundant in the earth, they are a resource that needs to be managed with regard to the possible needs of future generations. The ideal of Sustainable Development with its three pillars (its Economic pillar; its Social pillar; its Environmental pillar) is fully supported by EUROMETREC which practically ensures sustainability by carrying out the recycling of non-ferrous metals.
Once scrap metals are recovered (i.e. diverted from the "waste stream") and prepared according to recognise commercial specifications they do become a true raw material. Non-ferrous scrap provides a limitless resource that can be recovered, processed and recycled into new products over and over again. They represent "a mine above ground". They are a vital source of raw materials meeting the needs of industry worldwide. They conserve and protect the earth's precious natural resources, raw materials and energy.
Recycling conserves energy. The energy used in converting minerals into metals is never lost. The energy content of the metal remains intact no matter how long the interval between the original production and the return to use after recycling. For example producing one tonne of aluminium from recycling saves up to 95% of the energy needed to produce the same amount from its primary ore, bauxite. The savings for other metals are just as impressive. For lead up to 80 % can be saved, for zinc 75% and for copper up to 70%.

Recycling rates
Metals in effect are not consumed, but rather used and then recycled after use. Over half of the metals produced today in Europe come from secondary production and therefore from recycled material. This makes the European recycling sector the largest in the world, driven primarily by the intrinsic value of the metals. Recycling rates for metals are very high and continuously increasing. With such high values it is important to ensure that the calculation used is done properly - it must be made by determining what could have been recycled at any one time against what has been recycled at that time ( in contrast the often used comparison of the utilisation of recycled material against the utilisation of virgin material is no indicator of the efficiency of recycling). Metals recycling is a huge success story and does not need intervention by legislators to improve its performance.

Scrap Specifications
All 'old scrap' (end-of-their life metal containing products) and 'new scrap' (generated during the production of metallic products) are recycled into new products without any reduction in the intrinsic properties of the metal being re-utilised; this being the main objective of the non-ferrous metals recycling industry.
For the sale or purchase of metal for recycling, the quality is always clearly specified in contracts or associated refereence documents by the sellers and buyers, and the inspection, sampling and testing procedures for determination of composition agreed. Consequently the quality specifications refered to in the purchase contracts meet the need of the buyer. Specifications have been in use by industry parners for many years (the oldest we have on file date from the 1920's). These Specifications have been drawn up by a process of consensus between sellers and buyers and reflect the scrap types arising nationally and internationally.
The quality of scrap metal may be defined by reference to the composition of the standardised initial product from which it is derived, for either 'new scrap' or 'old scrap'. Some scrap qualities have been standardised by the CEN Technical Committees, for example some titanium and some copper scraps for direct melting. Standards for aluminium scrap, zinc scrap and lead scrap are currently being drafted. These scrap standards will not gain much support within the scrap recycling industry as the voting process within the Working Groups and Technical Committees for drafting these standards overthrows the consensus process used over the last century to draw up specifications.
Meanwhile specifications which refer to the origin, the physical form and the chemical composition of the scrap lots are found more fair, practical and useful for trading non-ferrous metals.

International trade
Like most other raw materials, secondary non-ferrous metals are traded internationally. Worldwide movements of non-ferrous metals fluctuate according to many variables: consumer demand, existing production capacities, price of primary metals and ores, quotations on the metal exchanges in London or New York, currency exchange rates, processing and labour costs, freight costs, export quotas or import duties, etc... The non-ferrous metals trade and recycling industry depends on free trade; it is driven by supply and demand.

REACH
REACH - Secondary materials and products recovered from wastes

  • Position paper in EN - FR - DE (PDF)
  • Presentation in EN - FR (PDF)

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EU regulatory barriers to recycling

The waste definition.
European legislation characterises metals as wastes when they are discarded. The concept of discard used by the legislator fails to distinguish between discarding wastes to landfill or to incineration, and the beneficial recovery and recycling of secondary materials. Even scrap that does not change ownership, which arguably has not been discarded, has been classified as waste by European legislators. This erroneous characterisation has led to restrictions in the movement of these scrap secondary raw materials within the European Union, since waste is subject to Regulation 259/93 regarding its shipment within, into and out of the European Union. The competitiveness of the European non-ferrous recycling industry is damaged by these waste laws while at the same time competing trading blocs, such as Japan or the USA, have granted exemptions to secondary raw materials in order to facilitate their accessibility to their own recycling industries. The European legislator should consider the use value and the destination of the material as the determining factors to distinguish recyclables from waste. Secondary raw materials to be recycled should be regarded as valuable inputs to industrial processes and should not be defined or regulated as waste.

Fair access to Secondary Raw Materials
Non-ferrous secondary raw materials are internationally traded because they are a valuable sources of metal units. In the interest of fairness access by any nation to these secondary raw materials should be transparent, though detrimentally regulations and tariffs are still being used by some countries to obtain a competitive advantage i.e. to better access to these materials. Trade barriers also have the effect of driving down recycling rates by interrupting the recycling chain or even by braking it. The EU authorities should safeguard the competitiveness of the European non-ferrous metals recycling industry by fighting against trade restrictive practices which distort fair access to secondary raw materials and those bad practices that disrupt the normal operation of the markets thereby hampering the competitiveness and development of the European recycling industry.

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