Petition against the implementation of a Ban on the Export of Scrap Metal from South Africa

The proposed ban, by the government of South Africa on the export of scrap, is being justified by the South African government as the only feasible option to effectively address the theft of infrastructure materials affecting the South African economy.

We ask that you sign the petition here below, if you are in support of the viewpoints expressed by RASA - the Recycling Association of South Africa.

https://www.petitions.net/petition_against_the_implementation_of_a_ban_on_the_export_of_scrap_metal_from_south_africa?s=96936035

Whilst this appears to be a sound and well considered decision, which most South Africans would support, as everyone is affected by the theft of infrastructure, which results in power outages, stopped trains etc, it appears from deeper reading, of all the documents referred to in the draft proposals, that all is not as it seems.

Firstly the SAPS have recorded year on year, for the past three years, a decrease in the cases of infrastructure theft and have successfully ramped up their ability to investigate, apprehend and prosecute the criminal elements involved in infrastructure theft.

Secondly, it also appears that the only benefactors of the proposed ban, would once again be a select group of companies, who already have a government enforced benefit of being able to buy scrap at between 20% to 30% less current market prices (under the PPS). These companies are also largely funded by government development loans.

Its little wonder to discover that these same companies sat in on the research phases for these policies and significantly contributed to how the draft policy was developed.

Thirdly, government realised that it could not logically impose a complete ban to have the aim of directly benefitting these companies, without facing possible repercussions from our International Trade partners. Some of these companies have already faced and been successfully prosecuted for anti-competitive behavior and collusion.

And thus it was determined that it would be cloaked in the disguise of a ban to address infrastructure theft.

A cause that the entire South Africa and the world would support without any further questions.

Little thought has been given to the ultimate consequences of this plan, nor has it actually included collaborative efforts of any of the people who will be affected by it, Metal Recyclers, their employees, businesses that generate scrap through the normal course of trade and waste pickers.

And those, whose futures now stand in uncertainty, do not believe that government will hear their voice. Nearly 1 million people, who earn a direct income from legitimate metal recycling, stand to be affected and the general consensus is that government does not and will not hear their voices.

That whatever government decides to do, it will do, irrespective of how many more people become unemployed or further impoverished.

The waste picker's, who collect cans, to feed their families, will no longer be able to do so. Yet the wealthiest of companies will directly gain a significant financial advantage in being able to source their supply materials at rock bottom prices, in comparison to market prices.

If measures are to be put in place to address infrastructure theft, alternative, workable solutions should be considered which will have a less detrimental impact, with more positive results, such as the use of microdot technology, RFID, a theft alert system to enhance and support the already effective policing and ensuring successful prosecutions. This, along with building strong co-operative relationships between law enforcement and business will ensure that the criminality aspect of infrastructure theft can be effectively addressed.

Please support us in asking government for the opportunity of :-

a) an extension of the given 21 days to review and process the volume of information and documentation, including all the reference documents, referred to in the notices. Notice 1210 of 2022 refers to 31 References, with Reference (2) constituting of 73 pages with 29 references and Reference (3) constituting 91 pages.

b) effective consultation with the nearly 1 million people, who earn a direct income from legitimate recycling, or their representatives, and/or organisataions representing them.

Source documents, referred to by government in the proposed draft ban are :-

1. http://www.thedtic.gov.za/wp-content/uploads/TIPS-Measures-to-prevent-theft-of-scrap-metal.pdf 

2. Genesis_SA-Policy-Options-Reduce-Metal-Theft.pdf (thedtic.gov.za) 

These documents are used in the drafting of the proposed ban, and outline its true objectives, as well as the parties that were, as well as were not, involved in the planning of the implemetation of the proposed ban.

We aim to submit this petition, along with a written submission to government, as requested by the 26th August 2022.

Direct submissions can also be made to:-

"Members of the public and interested/affected parties are to submit their written
representations and comments within a period of 21 (twenty-one) days from date of
publication of this draft notice to the Director-General of Trade, Industry and
Competition, marked for the attention of Mr. Mahendra Shunmoogam, either by email:
scrapmetalpolicy2022@thedtic.gov.za or hand delivered: at 77 Meintjies Street,
Block A, 1st Floor, Sunnyside, Pretoria, 0132."

Kindly email nancy@rasa.org.za for any further information, or supporting documents.

RASA - Recycling Association of South Africa    Contact the author of the petition