The Recyclers Association of South Africa (RASA) has written to the Minister of Forestry, Fisheries and the Environment calling for an urgent inter-departmental review of the Price Preference System (PPS) following the publication of the Draft National Circular Economy Action Plan (NCEAP) on 1 June 2026.

The NCEAP establishes South Africa’s first comprehensive 10-year national framework (2026–2036) to transition from a linear “take-make-dispose” economy to a regenerative circular model. It commits to keeping strategic materials in circulation at their highest value, formalising 60,000–90,000 waste reclaimers through a Just Transition with service-level agreements benchmarked against the National Minimum Wage (R30.23 per hour), and positioning South Africa as the primary AfCFTA secondary materials processing hub.

Despite the direct relevance of scrap metal to these objectives, the metal recycling sector — comprising formal SMEs and the estimated 400,000 informal waste pickers who form the foundational collection network — was not consulted during the development of the NCEAP.

Even more concerning is the ongoing operation of the Price Preference System administered by the International Trade Administration Commission (ITAC) under the Department of Trade, Industry and Competition (DTIC). The PPS continues to function in direct conflict with the NCEAP’s core principles by imposing a 30% price preference discount, requiring sellers to bear the full cost of inter-provincial transport (creating geographic market segmentation), permitting selective offers and protracted “reasonable engagement” processes that frequently result in permit declines, and suppressing gate- level prices for steel scrap to levels that render recovery economically irrational for waste pickers.

“Government has now published a national circular economy roadmap that explicitly recognises waste reclaimers as essential to keeping materials in circulation and commits to their formalisation at fair wages,” said Geoff Borrajeiro, Chairperson of the Recyclers Association of South. “At the same time, the PPS — a system ITAC itself publicly admitted was flawed 21 months ago — continues to suppress prices at the very first mile of the circular economy and blocks the circulation of materials the NCEAP says must be prioritised. This is not coherent policy. It is jurisdictional overreach by DTIC on a waste stream whose management properly falls under DFFE’s mandate in terms of the National Environmental Management: Waste Act.”

Scrap metal is defined as “waste” under NEM:WA. The Act vests primary authority over waste management, the waste hierarchy, and measures to promote reuse, recycling and circularity in the Department of Forestry, Fisheries and the Environment. The PPS, while framed as an export control measure, operates in practice as a price-regulation and waste-flow instrument that directly impedes the circular economy and just transition objectives now formally adopted in the NCEAP.

RASA has called on Minister Aucamp to:

1. Direct an urgent inter-departmental review of the PPS in light of the NCEAP, with a view to suspending or substantially amending those elements that undermine circularity, price discovery at the collection gate, and the just transition for waste reclaimers;
2. Establish a joint DFFE–DTIC task team, including representation from metal recycling associations and waste picker organisations, to ensure coherence between trade/export measures and the national circular economy framework; and
3. Ensure that the final NCEAP explicitly addresses scrap metal and ferrous waste streams as a priority material flow and mandates a review of all existing trade measures that impede circularity.

The new Circular Economy Inter-Ministerial Committee (CE-IMC) — to be co-chaired by DFFE, DTIC and DSTI — now carries an explicit mandate to drive the Just Transition for waste reclaimers. RASA argues that the continued application of the PPS is incompatible with this new governance architecture.