Using scrap metal when manufacturing MEEE

This guidance is relevant if your business uses scrap metal in manufacturing or assembling machinery or electrical and electronic equipment (EEE).

What you must do

Check if you need a permit, licence or exemption

If you store, treat, recover or dispose of waste scrap metal, you may need a pollution prevention and control permit, waste management licence or registered exemption. Some waste activities are exempt from licensing. For example, you may need to register a waste exemption with your environmental regulator to use contaminated scrap.

In Scotland, clean scrap metal off-cuts from metal manufacturing processes are considered to be a by-product rather than waste in some circumstances. Read the SEPA position statement to find out if waste regulation controls apply to your scrap metal off-cuts.

SEPA: Regulatory position statement on clean scrap metal offcuts (Adobe PDF - 161KB)

Check if your scrap metal is contaminated or hazardous

Examine all scrap material you buy or use to check if it is contaminated or hazardous.

Contaminants include radioactive materials, plastic, rubber and oil. For information on how to check for radioactive sources, see our guidance on radioactive substances.

Some of your scrap metal may be classed as hazardous/special waste. For example, metal in waste oil filters, spent battery casings, metal containers with hazardous contents or mercury in fluorescent tubes.

You must comply with special controls for hazardous/special waste. For more information, see our guidance on hazardous/special waste.

Comply with import and export regulation

If you transport scrap metal into or out of the UK, you must comply with regulations on the international shipment of waste. For more information see our guidance on importing and exporting waste.

Good practice

Be a good operator

Set up a scrap management system. This will help you identify and separate out contaminants such as radioactive materials, plastic, rubber and oil.

Use non-chlorinated cutting fluids for all applications, especially where you might recycle the scrap material.

Prevent land and water pollution

Store your oil-contaminated scrap on concrete pads.

Install drainage systems in your storage areas that are isolated from your general drainage and are fitted with an oil interceptor or an alternative water treatment system.

Get your oil interceptor inspected and serviced regularly.

Check if you need permission from your environmental regulator or your < water company or authority to discharge the wastewater from your oil interceptor.

GPP 3 Use and design of oil separators in surface water drainage systems