Michael,
Whilst your warning may be a timely one, and one which anyone dealing in metals should give careful thought to, I think you may have become slightly paranoid.
I went to the relevant government website. The 2012 rules amend the Scrap Metals Dealers Act 1964, but it seems the definitions of what constitutes a scrap metal dealer is unchanged. The Interpretation provisions of the latter act state:
9 Interpretation.E+W
(1)For the purposes of this Act a person carries on business as a scrap metal dealer if he carries on a business which consists wholly or partly of buying and selling scrap metal, whether the scrap metal sold is in the form in which it was bought or otherwise, other than a business in the course of which scrap metal is not bought except as materials for the manufacture of other articles and is not sold except as a by-product of such manufacture or as surplus materials bought but not required for such manufacture; and “scrap metal dealer” (where that expression is used in this Act otherwise than in a reference to carrying on business as a scrap metal dealer) means a person who (in accordance with the preceding provisions of this subsection) carries on business as a scrap metal dealer.
Note that this excludes "a business in the course of which scrap metal is not …bought except as materials for the manufacture of other articles and is not sold except … as surplus materials bought but not required for such manufacture.
Thus a firm selling surplus bought-in stock is not a scrap metal dealer within the meaning of the act. Interested parties can find the test of the 1964 act at
**LINK**
However, if you are in the metal business and sell metal, you should check for yourself and take advice if in doubt.
David
Edited By David Littlewood on 05/12/2012 22:39:55