Correspondence from Dixons Group plc to
the Permanent Secretary, Department of Environment, Food and Rural
Affairs, 18 September 2001
When we met at the Open Dining Club last week,
I said I would write to you about the new regulations affecting
the collection and management of end of life equipment and of
our concerns about the review of the Special Waste Regulations
and the changes to the Montreal protocol giving rise to the new
EC Regulation on Substances that Deplete the Ozone Layer. Since
we spoke a number of meetings have taken place with officials
in your department and the DTI. I am afraid that these meetings
give me no great comfort either that officials understand the
scale of the issue or that they are willing to assist us in finding
solutions to the conundrum before us, in particular the effect
that these new controls may have on the take back service that
we currently offer to our customers for large domestic appliances.
Over the last financial year the Dixons Group,
(which includes Currys, Britain's largest electrical retailer)
recovered 730,000 redundant white goods when delivering new products
to customers' homes. More than 300,000 of these were refrigerated.
At present, these redundant appliances are returned to our 18
local distribution centres. From there they are disposed of, mainly
through small sub-contracts whose core activity revolves around
the reconditioning and sale of appliances via export or recycling
for material recovery.
This service is important both to our customers
and to local authorities who would otherwise be responsible either
for collecting these items from homes (or worse, from wherever
they might be dumped) or for receiving them at municipal dumps
and managing their disposal. As I said last Monday, the new regulations
pose a very real threat to this service.
In the Review of the Special Waste Regulations,
waste electrical appliances containing CRTs, lead, mercury, CFCs,
HCFCs, batteries etc, will be classed as hazardous waste form
January 2002. At present, under "exemption number 28",
retailers who recover redundant end of life electrical products
for recycling do not require a waste management licence provided
the products are removed from our premises within a set time scale.
My colleague John Clare wrote to the Environment Minister, Michael
Meacher, to seek guidance as to whether this exemption would prevail.
The Minister did not reply but a letter from an official (Chris
Megainey) merely confirmed that the exemptions were under review
but not when the review might conclude nor that there would be
any time allowed between the conclusion of the review and the
deadline for implementation. I am sure you are aware of the time
it takes to obtain a hazardous waste management licence and the
time it might take to create facilities suitable for the storage
of hazardous waste if this is what the regulations require. (I
am told, for example that facilities required would include covered
closed storage with concrete floors. We have neither land, planning
permission, nor a budget for the building of such storage. I doubt
that our contractors have such facilities either.)
Your official's letter suggests that there may
be an exemption for the agencies that recover hazardous waste
although it is our understanding that European legislation specifically
forbids this.
That brings me to my second and major concern,
EC Regulation 2037/2000 on Substances that Deplete the Ozone Layer.
The UK's requirement under the first stage of Regulation 2037/2000,
to remove the CFCs from fridge compressors prior to export meant
that a number of countries which previously imported such fridges
for refurbishment and re-use no longer find it economic to do
so as they would have to be "re-gassed" in the importing
country to make them useable. As second-hand fridges can still
be obtained from other countries with the compressor. CFCs intact
these sources are now being used in place of the UK. As this has
removed an income stream from them a number of our former disposal
contractors have withdraw from the business.
The second stage, which requires the extraction
and treatment of CFCs in foam, will extend and deepen the impact.
There is no facility in the UK to recover and treat CFCs from
foam. Nor is it possible to create such a facility before the
implementation date in January 2002.
Our contractors are not prepared to end up as
the final holder of large numbers of fridges of which they cannot
legally dispose. Thus they have given us notice that they will
cease to collect these products from us after 30 November 2001.
Several have also served notice that if they cease to collect
fridges they will exit the business leaving us without a recycler
for cookers and washing machines and jeopardising that service
too.
Were we to continue to collect fridges after
that date our local distribution centres run the risk of being
overrun with products of which we cannot dispose. Even under the
current law we cannot hold these products longer than 28 days,
nor do we have the space to do so. Charging customers the true
cost of dealing with these products (say £30 a unit [plus
transport and storage costs] for foam removal in German facilities
or storing them somewhere for a year or so until a nearer facility
might be built, presumably with a similar unit processing cost)
would quickly cause them to reject the service.
Thus far my impression is that many local authorities
remain unaware of the burden that may fall upon them. They, like
us would have to find a disposal route as they will not be able
to stockpile and store these products indefinitely without extracting
the CFCs from the foam. Some have made it clear to us informally
that they will have difficulty in meeting their obligation to
accept domestic waste if they cannot dispose of the products or
if demand suddenly rises sharply.
As you can see action is needed swiftly. At
present we are able to provide this service as it is roughly cost
neutral. We need to secure a cost neutral route to secure its
future. As we discussed there could not be a better candidate
for "joined up government".
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