SWR3

Legislation Committee No 1

Response to the Consultation on the Proposed Shipment of Waste for Recovery (Community Involvement in Arrangements) (Wales) Measure

Novelis Recycling

Please find below a response to your consultation from Novelis Recycling.  Novelis Recycling is part of Hindalco Industries Ltd. the world's leading producer of rolled aluminium products and the global leader in aluminium can recycling.  Since 1989 Novelis has invested approximately £60 million in building Europe's largest dedicated used aluminium beverage can (UBC) recycling plant in Latchford (Warrington), and the associated consumer awareness and collection infrastructure. The plant produces ingots for the beverage can manufacturing industry and has the capacity to recycle every aluminium drink can sold in the UK (approx. 80,000 tonnes - equivalent to five billion cans).  

Novelis Recycling (formerly Alcan Aluminium Can Recycling) was established to develop the infrastructure for aluminium can recycling in the UK by working with private, public and community sector collectors of UBCs. The company purchases UK-sourced aluminium cans and foil for recycling and is committed to developing and supporting aluminium collection programmes - helping entrepreneurs, community businesses, local authorities and waste management companies to maximise the potential of the valuable aluminium they collect.

Thank you for the opportunity to respond to this consultation. We would welcome the addition of Novelis UK Ltd. to the list of consultees for any future related consultations.  Our responses to questions in this consultation are confined to those that directly interface with the business of Novelis UK Ltd.

As a fully licensed, responsible and committed reprocessor of used aluminium beverage cans we support the transparency and openness that is the intent of the proposed measure

1.Do you think that the proposed Measure will achieve the desired aim of improving transparency and openness in the way that Welsh local authorities deal with recyclate?  

Overall the proposed Measure should serve to improve the transparency and openness of recyclate management.  It will undoubtedly also serve to unearth further loopholes and obfuscation from certain elements in the UK waste management industry.

2.Do you consider that the proposed Measure is the best means of improving transparency and openness in the way that Welsh local authorities deal with recyclate?  If not, which other approaches should be used?

This appears to be the most practical way of achieving the policy aims and should prove the most acceptable to the UK waste management industry.

3. Are there additional powers that could be included in the Measure to further promote this approach in local authorities?

No

4.Do you consider that the implementation of the proposed Measure would lead to residents encouraging local authorities to use recycling facilities that are closer to the source of the recyclate, than those that are further away?  Do you agree that publication of the required information will lead to increased interest, and therefore participation, in recycling?

Overall yes, but it has to be accepted that there will be a minority of Welsh residents who may see the fact that some of their recyclate material is (legitimately) exported overseas for reprocessing as a disincentive to participate.

5.What unintended consequences, if any, could arise from the implementation of the proposed Measure?

As described in point 4 above. There is some anecdotal evidence to suggest that MRFs occasionally transfer material (sometimes rejected) between themselves.  In this instance, as with multi-LA inputs, I can imagine that there will be a claimed 'difficulty’ in reporting according to the measure.  This could potentially increase the drive toward MRF to MRF transfers and multi-LA supply contracts.  The latter of which is not in and of itself a bad thing.

6.What do you estimate the costs of complying with the proposed Measure to be for your organisation?  Do you consider these costs to be excessive?

Negligible.

Whilst it is not clear from the wording of the draft legislation (legal wording is never easy to interpret!), I remain concerned that the intent of the proposed Measure could be lost if there is not a clear understanding on the meaning of the terms used.  For example there needs to be a clear definition of processors, who may handle, sort, bale etc the material as against the ultimate reprocessors whose role is defined in Annex llB of the Waste Framework Directive

Finally, the proposed Measure needs to be prepared and responsive to the frequent and rapid market changes that might mean that recyclate is sold to multiple reprocessors during the course of any given year.  Again it would be disappointing if the intent of the measure was lost because respondents were able to suggest that market conditions were such that multiple and continually changing outlets were used.

I wish you every success with this measure.

Andy Doran
National Manager, Novelis Recycling