Packaging recovery notes will be issued by scrap dealers for the first time, following the release of new guidance from the Environment Agencies.
Businesses that recover scrap iron, steel and aluminium which meets end-of-waste criteria will be able to issue PRNs.
The guidance states:
Accreditation for Metal waste packaging and Council Regulation (EU) No. 333/2011 – ‘end-of-waste’
- We will only consider your application for accreditation on the basis of end-of-waste criteria specified in this Regulation for iron, steel and aluminium if your process will ensure the technical standards set out in the Regulation are met and you have a quality management system that has been verified by an independent body that has been accredited by UKAS.
- If you have an appropriate quality management system you must pass on a copy of the Statement of Conformity with any load of scrap metal recovered under the end of waste criteria.
- ‘End-of-waste’ scrap metal which has been recovered which is mixed with waste metals must be treated as waste and handled as a waste material.
Accredited businesses recovering scrap iron, steel and aluminium which meets the end-of-waste criteria
• You should check the accreditation status of the businesses you supply. If they are accredited under the Packaging Regulations, they will be listed on the public register of accredited reprocessors or exporters on the Agency’s website.
• If you supply another accredited business, you must tell them if ePRNs have already been issued on the loads of scrap metal you are supplying. You could choose to include this information on your invoices, or Statement of Conformity.
• If you are supplying businesses which are not accredited, but may themselves be supplying an accredited reprocessor or exporter, you should tell them if ePRNs have already been issued on the loads you are supplying, so that they can pass on that information. You could choose to include this information on your invoices, or Statement of Conformity.
Accredited businesses receiving scrap iron, steel and aluminium
• You must check with your supplier to see whether the scrap iron, steel and aluminium you are receiving has met the end-of-waste criteria and if ePRNs have already been issued on it.
• You cannot issue ePRNs or ePERNs on scrap metal youreceive if ePRNs have already been issued on it.
There is also guidance on what to do if packaging is mixed with scrap. It states:
Packaging mixed with scrap steel
The steel industry has well-established procedures for recycling steel, and packaging is often mixed with other scrap steel. It is not always possible to separate the packaging from the steel. The below percentages of packaging content in the steel scrap were originally supported by the British Foundry Association, the British Metals Federation and the United Kingdom Steel Association. A review is planned of these percentages. If you handle the grades of steel listed below, you can issue ePRNs or ePERNs for the percentages set out in the right-hand column.
Grades of scrap steel Percentage of waste packaging in the scrap steel
1 and 2 (mixed) 0.55
For example, if you export 1,000 tonnes of fragmentised steel, you can issue ePERNs for up to 47 tonnes of waste packaging. We will accept these percentages of waste packaging listed above without you having to provide any extra proof of the amount of waste packaging that makes up the load.
You must still keep to the percentages shown above if you handle loads made up of 100% of:
- 210-litre drums;
- 25-litre drums;
- baling wire; or
- banding and strapping.
Other grades of scrap steel and waste packaging are not covered by this document.
If you want to apply a percentage of packaging waste to other grades of scrap steel, you will have to justify the percentages by providing samples that we accept. You should agree the sampling methods with us as part of your sampling and inspection plan. We will assess each sample you provide separately.
Packaging mixed with scrap aluminium
The aluminium industry has well-established procedures for recycling scrap aluminium, and packaging waste is often mixed with other scrap aluminium. It is not always possible to separate the packaging from the non-packaging element.
The Aluminium Packaging Recycling Organisation (ALUPRO) has worked with us to set percentages which you can use to assume how much packaging waste is in scrap aluminium.
If you handle the grades of aluminium listed below, you can use ePRNs or ePERNs for the percentages set out in theright-hand column.
Scrap grades Percentage of waste packaging in the scrap aluminium
Old rolled aluminium 13.6
Mixed aluminium alloy cuttings 9.3
New pure aluminium 6.2
New scrap of one aluminium alloy 9
For example, if you export 1,000 tonnes of new pure aluminium, you may issue ePERNs for up to 62 tonnes of waste packaging.
We will accept these percentages of waste packaging listed above without you having to provide any extra proof of how much packaging there is in each load of scrap you receive.
Other grades of aluminium are not covered in this document. If you want to apply a percentage of packaging waste to other grades of scrap aluminium, you will have to justify the percentages by providing evidence that we accept. You should agree the percentages with us as part of your sampling and inspection plan. We will assess each application separately.
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