Speaking at the Chartered Institution of Wastes Management’s Waste Definition seminar in London on 11 July, CIWM Chief Executive Steve Lee highlighted the need for clarification on the point at which waste is ‘recovered’ so that materials did not continue to be treated needlessly as waste, with the costs and additional bureaucracy that this could bring.He commented: ‘The definitions for ‘waste’ and ‘discard’ are firmly fixed in case law and will not be revisited through the proposed review of the EU Waste Framework Directive. There is much more scope to review the definition of ‘recovery’.
It is clearly important that the regulatory framework is not weakened in terms of protecting the environment, so ‘recovery’ needs to be tied into fitness-for-purpose quality specifications, which will help to create consistency and certainty for both industry and regulators.’
Several speakers highlighted the fact that there were already documents in existence that could be used, and Mervyn Jones from WRAP described how they were working on getting quality protocols agreed with SEPA, the Environment Agency and Defra.
Speakers also made the point that it was damaging to markets if recovered materials were needlessly disadvantaged against virgin materials with the same characteristics, and the use of recognised standards was one way of overcoming this problem.
Dirk Hazell of the Environmental Services Association stressed the importance of certainty in facilitating investment: ‘Obviously if a material is classed by law as waste today and infrastructure is built to deal with it, if the material is declassified tomorrow the infrastructure will itself be wasted. When something is defined as waste, clear regulation, signalled well ahead of implementation, is a pre-requisite for necessary investment.’
Sam Boileau of Denton Wilde Sapte highlighted the confusing outcomes of case law which did not provide organisations with a clear picture of how to proceed in the future.
In his concluding comments, Steve Lee said that industry needed to develop powerful, coherent arguments on how these issues should be tackled ‘to influence Government and EU priorities for the development of fit for purpose recovery standards. One of the key issues was to prioritise the most important ‘wastes’ to re-define as ‘raw materials’. In a straw poll conducted at the conference, 65% of respondents felt that aggregates and refuse-derived fuel were the issues most urgently in need of attention (39% and 26% of respondents respectively).
