“The metal Recyclers Association of South Africa (MRA) expressly opposes a scrap metal export ban because it will not resolve the problem of infrastructure theft and it will certainly be the cause of numerous unintended consequences, that will harm a multitude of people and businesses, including not only the formal metal recycling sector and also the informal sector waste collectors, but also all generators of metal waste (scrap metal), including large-scale industry such as the mining, construction and manufacturing sectors.”
In a 10-page letter submitted to The Department of Trade, Industry and Competition (the DTIC), these are comments made by the MRA on the DTIC draft policy proposals on measures to restrict and regulate trade waste, scrap and semi-finished metal products to limit damage to infrastructure and the economy and draft policy directives and notices – GG NO.47202 of 5 August 2022.
Unfortunately the notice in the Government Gazette of 5 August 2022 was published too late to be in the August 2022 issue of Castings SA but you were made aware of the important notice via email. Trade and Industry Minister Ebrahim Patel published the proposals and called for public comments and representations on the proposed measures within 21 days, before final decisions are taken. To view the notice go to: https://www.gov.za/sites/default/files/gcis_document/202208/47202gen1210.pdf It’s headed: Invitation for comment: Draft policy proposals on measures to restrict and regulate trade in ferrous and non-ferrous metals waste, scrap and semi-finished ferrous and non-ferrous metal products to limit damage to infrastructure and the economy.
In the MRA’s comments they do commend and support the ban on cash for scrap metal, regulation of semi-finished products, increased policing and enhanced regulation of scrap metal dealers, recyclers, foundries, mini-mills and mills and the requirement for registered buyers to only purchase copper scrap and semi-finished copper from registered sellers. However, they say, consideration must be given to accommodate sales by private citizens who are not regularly engaged in such trade, such as the example of a farmer disposing of redundant copper water piping or copper electrification cable.
The MRA also supports the imposition of an import permit and registration system for scrap metal processing and smelting equipment, although we note that this equipment is already in the country and low-tech “tabletop furnaces” can be readily manufactured locally.
The MRA do give many reasons and supporting facts as to why they believe there should not be a ban on the export of scrap. They also give their solutions as to how to improve the policing element of the proposal.
In conclusion the say that: “The most feasible interventions are more policing, preserving and creating employment; not a general scrap metal export ban which will compromise employment.”
The full MRA comment on the draft policy can be found at https://mra.co.za/mra-comment-on-the-draft-policy-26-august-2022/.