Let’s enhance metal recycling

For the last 10 years, many organizations including my own have been trying to convince politicians, bureaucrats and regulators that environmentally-sound metal recycling is good. It has been an uphill battle. While we are making progress, there remains a large divide between those who undertake environmentally-sound recycling and those who seek–usually inadvertently–to discourage it.

The problem stems from an international definition of ‘waste’ developed more than a dozen years ago as part of the Basel Convention, which unfortunately includes not only wastes going to final disposal, but also materials going to recycling. Subsequent international agreements and Canadian regulations have adopted a similar definition, causing valued resources with recycling potential to be treated like wastes, often as hazardous wastes. The practical effect of these regulations is to limit market access, impose added transportation and administrative costs and attach a negative stigma to materials recognized as valuable resources in other jurisdictions. In consequence, the regulations hamper the investment and growth of an economic and environmentally-viable recycling industry in Canada.

Here are some key messages for Canadian governments to consider as we enter the last phase of regulatory reform that governs recycling in Canada.

Federal and provincial government policies support recycling, while federal regulations create barriers. The October 2000 Government of Canada Action Plan 2000 on Climate Change recognized the potential contribution of metal recycling to reduce greenhouse gas emission intensity, and expressed the federal government’s intention to “reduce emissions by enhancing metal recycling processes and practices”. Current regulations that define valued recyclable materials as hazardous wastes discourage suppliers outside of Canada from choosing Canadian recyclers, such as Noranda’s Horne smelter in Rouyn-Noranda, Qu. Added costs limit the ability of Canadian recyclers to compete, and reduce the economic incentives for recycling, discouraging investment in R&D and infrastructure.

The minerals and metals industry is one of Canada’s most productive industrial sectors, and a major contributor to the country’s ongoing economic prosperity and diversity. It is one of the few Canadian industries to operate in all provinces and territories. It is also one of the few industrial sectors where Canadian knowledge, technology, expertise and corporate leadership dominate internationally.

Recycling conserves natural resources, reduces pressure on landfills and incinerators, avoids adverse impacts of primary extraction and reduces smelter releases to the air and water. Increased metal recycling should be a preferred strategy to reduce the greenhouse gas emission intensity of smelting and refining.

Metal production and recycling are globally competitive and capital-intensive businesses. Economic operations require processing rates that cannot be sustained if recyclable materials originate only from domestic sources. The continued development of the recycling infrastructure in Canada creates long-term jobs and enhances the capacity to manage domestic wastes in a sustainable manner. Measures that increase the cost of recyclable materials or limit access to recyclable materials only serve to discourage recycling in Canada, encourage disposal, and shift investment and jobs to jurisdictions that do facilitate recycling.

Other jurisdictions recognize the value of recyclables and have created exemptions from regulations that impede recycling, or have adopted regulations specifically to encourage recycling. Domestic regulations must reflect the regional pattern of trade in recyclable materials. Many materials are exempted from waste regulations in the United States, Canada’s major trading partner, under Universal Waste rules that are specifically intended to facilitate recycling. Qubec and Ontario also exempt certain shipments of recyclable materials from waste regulations in order to encourage recycling. Federal regulations continue to discourage recycling by controlling shipments of valued resources in the same manner as hazardous wastes.

Current restrictions on trade in recyclable materials could be challenged under the North American Free Trade Agreement or through the World Trade Organization, because Canada has failed to adopt the least trade-restrictive measures that could meet national policy objectives.

Canada also has obligations to consider impacts on internal trade. Domestic controls on interprovincial shipments of recyclable materials constitute barriers to internal trade. Such barriers reduce the efficiency of the internal market, impair the ability of recyclers to compete for recyclable materials and increase costs for other businesses. Controls encourage disposal and increase costs for provinces and municipalities.

In conclusion, current regulations governing recycling in Canada are inconsistent with the government’s climate change position, The Metals and Minerals Policy of the Government of Canada: Partnerships for Sustainable Development and trade policies. Current proposals for interprovincial regulations and amendments to the Export and Import of Hazardous Wastes Regulations do not address the barriers to recycling in Canada.

The survival of certain Canadian metal recycling facilities, smelters and refineries hinges on expanding business through improved access to domestic and imported recyclable materials. The viability of refined metal users that depend on those suppliers is also at stake.

Cindy Thomas is manager of recycling at Noranda Inc., based in Toronto, Ontario.