Correspondence from Dixons Group plc to
the Secretary of State for Environment, Food and Rural Affairs,
19 October 2001
DRAFT STATUTORY
INSTRUMENT ON
ENVIRONMENTAL PROTECTION
(CONTROLS ON
OZONE-DEPLETING
SUBSTANCES) REGULATIONS
2001
I am responding on behalf of the Dixons Group
plc to the draft Statutory Instrument (SI) published by your Department
on 5 October. Our particular concern is the affect these new controls
may have on the take-back service that we currently offer to our
customers for large and of life domestic appliances.
As you know the Dixons Group is Europe's largest
specialist retailer of consumer electronic and electrical products.
The Group has more than 1,250 stores across the UK, the Republic
of Ireland, the Nordic region and Spain and trades in the UK and
Ireland as Dixons, Currys, PC World and The Link.
Over the last financial year the Dixons Group
recovered 750,000 redundant white goods when delivering new products
to our customer's homes. More than 300,000 were fridges. At present,
these redundant appliances are returned to one of our 18 local
distribution centres, from which point we sub-contract their disposal,
mainly through relatively small subcontractors whose core activity
revolves around either the reconditioning and sale of appliances
or recycling for material recovery. Although retailers have no
obligation to take back redundant products from customers, we
feel that this is a valuable service and relieves local authorities
of a considerable burden.
The first stage of implementation of Regulation
2037/2000 has already had an impact on those sub-contractors who
exported refrigerated white goods for re-use. The UK's requirement
to remove the CFCs from the compressors prior to export means
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.
The second stage, which requires the extradition
and treatment of CFCs in foam, is likely to have a greater impact
as it effectively prevents export for re-use. Again there has
been little guidance on this issue despite the looming implementation
date.
As you will be aware, currently there are no
extraction facilities to remove CFCs from foam in the UK, nor
is it likely that such facilities could be built in the UK in
under a year. Even if such facilities were in place, a cost-free
waste collection and management system (as is the case now) would
need to be put into place before the second stage of the regulations
are implemented.
Our fear is that the impact of the regulation
could undermine the viability of recovering and recycling of white
goods. If electrical retailers were forced to withdraw this service,
local authorities would inherit the responsibility for which they
have little or no provision.
It is therefore the view of the Dixons Group
that the regulations on Ozone-Depleting substances should not
be implemented on 1 January 2002 and should be postponed until
extraction facilities and a cost free waste collection and management
system are in place in the UK.
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