Guidance on ASR focuses on UK regulations

A document from the British Metals Recycling Association (BMRA) focuses on obligations connected to a United Kingdom Environment Agency (EA) statutory guidance statement released in 2024 but with a pending deadline this March.

The BMRA document, titled “Landfill Guidance for Shredder Operators,” is aimed at those metal recyclers who shred and process end-of-life vehicles (ELVs), household appliances and other recyclable metal items that also yield metal shredder residue (MSR) or auto shredder residue (ASR) that typically is landfilled.

It was prepared and issued by England-based BMRA in response to the U.K. EA’s regulatory position statement (RPS) 314 statutory guidance, titled “Accepting metal shredder residues and postshredder treatment residues (PSTR) at landfills.”

The four-page BMRA document created in response has been designed to highlight current and future options for treatment and disposal of MSR and operators’ regulatory requirements. That includes not only clarifications on the situation in England, but also a reminder that the shipment of ASR or MSR beyond the United Kingdom is subject to strict waste shipment controls under the Transfrontier Shipment of Waste Regulations.

The approximately October 2024 RPS 314 announcement, which notably applies to England and thus not necessarily Northern Ireland, Scotland or Wales, was issued with the notification that the agency intends to withdraw this RPS March 31.

“If that happens, many MSRs would only be allowed to be landfilled at sites permitted for hazardous waste,” BMRA Technical Director Howard Bluck says. “We are working closely with EA colleagues to consider the impact of this, as we believe much of this material is unlikely to meet hazardous waste landfill waste acceptance criteria.

“It is important for shredder operators to understand the classification of their MSR and any business and financial implications that this may have when disposing of this material.”

Also pertinent to MSR or ASR disposal in England is the EA’s RPS 274, a rule pertaining to storing and physically treating hazardous metal shredder residues that the EA updated last March.

Shredder residue generators and handlers had been required to apply for a variation to any existing permits by April 1, 2024, to be eligible to continue storing and processing MSR on-site.

In addition, the March 2025 RPS 274 statement from the EA spells out several conditions shredder operators or other handlers of ASR must comply with in England. Those conditions include keeping records for three years to demonstrate compliance with the RPS and, on the staffing front, having the correct level of technical competence to cover accepting and physically treating hazardous shredder residues.

The October 2024 RPS 314 guidance from the EA, meanwhile, urges recyclers to check back with the EA website regarding the looming March 31 deadline and to be particularly mindful of ASR and MSR handling and disposal methods after that date.

The announced and pending regulatory changes have prompted BMRA to encourage its current and prospective members to maintain close contact with the association to help remain in compliance with rules surrounding ASR.

BMRA's most recent guidance document is available to all shredder operators in the U.K. and can be obtained by contacting it at admin@recyclemetals.org.