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Recycled materials

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Silky
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Recycled materials

Post by Silky » Tue Nov 03, 2015 12:59 am

Hi all,
We currently collect material from our customers & third parties, that we recycle and used in our products. As this material is not waste for us do we need a waste transfer note? It is waste to our customers, so should we be giving them a WTN?
As you can see I'm a bit confused to say the least, so any guidance would be appreciated.
Silky

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David68
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Re: Recycled materials

Post by David68 » Tue Nov 03, 2015 10:56 am

Hi Silky

This is not waste, this is material that is to be used for a process. The material is being used not discarded.

The Environmental Protection Act defines waste as

“Waste” means any substance or object in the categories set out in Schedule 2B to this Act which the holder discards or intends or is required to discard.

What materials do you use?

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Re: Recycled materials

Post by jonsi » Tue Nov 03, 2015 11:31 am

It isn't waste...it is a By-product of their process and a raw material for yours. I would give them a collection note (so they can balance their books) but no need to record it as Waste. If you did you'd need a Waste Carriers Licence (assuming that you collect), they'd need a Waste Producers Licence, you might need a Waste Disposers Licence, Environmental Permits etc. etc.
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Re: Recycled materials

Post by dave247 » Sat Nov 07, 2015 12:21 am

So what is the difference between taking waste plastic and turning it into a polymer which can make something. It is still the other persons waste so they need the trail.
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Re: Recycled materials

Post by David68 » Sat Nov 07, 2015 7:59 pm

It is the word discard. If you sell a by product to another company, you are selling a product not disposing of waste. Semantics maybe.
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Re: Recycled materials

Post by abarnett » Mon Nov 16, 2015 8:55 am

If the plastics are a byproduct of the original companies process, and they would be chucking it out if you weren't collecting it, then it is waste IMO.

The fact that it is a raw material for your process is irrelevant. The comparison is a paper mill taking recyclable paper - it is collected as waste from the originator but ends up as a raw material for another process.

You won't need a WTN as you are using the plastic in your process but the original company would need a WTN to account for what they have done with the plastic.

You may require a waste carriers licence depending on your circumstances - I'd check with your relevant environmental agency as some exemptions do apply.

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Re: Recycled materials

Post by Keith1983 » Mon Nov 16, 2015 9:49 am

In the industry I used to work in the waste metal material from our machining processes was classed as waste by us, the company getting rid of it. We did have transfer notes and the appropriate producers licence and the company that collected it had waste carriers licences? It's a bit of a minefield this one. Do you have a local EA office you can ask for advice?
So when the whole world is safe..............what are we going to do then?

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Re: Recycled materials

Post by Silky » Mon Nov 16, 2015 11:03 pm

Thanks everyone for you input.
We do have EA exemptions to both store & process on site. The customers sending or bringing back their waste do not seem bothered if they have WTN's or not. I keep telling them they should take the WTN I offer as they need to hold documentation relating to where there waste was disposed of, most don't want them. As long as I hold a copy on file I guess I'm covered.

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Re: Recycled materials

Post by Sue Halewood » Tue Nov 17, 2015 8:51 am

There are now regulations in place that allow waste to be converted back to a product, these are known as the "End of Waste Regulations". I would suggest you contact your local Environment Agency office for advice regarding this as the regulations are currently a bit vague.

As for collecting the material however I am afraid you will still have to be registered as a Waste Carrier and issue Waste Transfer Note as the consigner needs them for their own records

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Re: Recycled materials

Post by Sue Halewood » Tue Nov 17, 2015 8:59 am

We have the occasional client who doesn't want a Waste Transfer Note but the drivers are instructed "No signature, no collection". If the consigner then chooses to throw the note in the bin that is their problem, so long as we have a signed copy.

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