Correspondence from Dixon's Group plc
to the Global Atmosphere Division, Department of the Environment,
Transport and the Regions, 5 December 2000
Re: EC Regulation 2037/2000
Following your recent memo regarding Regulation
2037/2000 on the export of second hand fridge's and freezers,
I am disappointed to see that you have chosen to ignore our point
of view. As we predicted, our current contractors are beginning
to close down and go out of business (please see the annexed letter
as an example). We envisage that by the end of this week, eight
of our distribution facilities will be without an onward scrap-processing
contractor as the impact of the Regulation continues to bite.
As a consequence of the distinct lack of practicable
processing routes available to us, the most likely scenario now
is that Dixons Stores Group will alter its service proposition
with regard to accepting such appliances from customers. Ultimately,
the costs associated with correctly processing these appliances
will rest with local Governmenteither as local authorities
are required to step up their bulky collection services, or as
more appliances are recovered having been "fly-tipped"
in hedges and fields. The recovery route will effectively have
been shifted from one that is well-defined and environmentally
sound to one that is irresponsible and random.
Alternatively, with re-use seemingly off of
the agenda, material recycling will be the last remaining option.
Therefore, we await your decision on the level of treatment necessary
for foams containing ozone-depleting substances, and we hope that
in this instance you will bear in mind the lack of processing
facility available in the UK for these materials. The costs that
will result from a requirement for this level of treatment will
be high for the consumer to inherit and high for local Government.