Correspondence from the Global Atmosphere
Division, Department of the Environment, Transport and the Regions
to Dixons Group plc, 5 January 2001
EC Regulation 2037/2000
Thank you for you letter of 5 December. I am
sorry that you have not had a reply before now, but I have been
out of the office for much of December at the Montreal Protocol
meeting in Ouagadougou in West Africa.
I am disappointed that you have not recognised
the steps Government departments have taken to lessen the impact
of Regulation 2037/2000 on the trade in second hand fridges. As
soon as the implications of the full effect of the export ban
in Article 11 had been realised we called a meeting with the trade,
at which Dixons was represented by Vivien Williams. This meeting
resulted in a series of very unusual steps: Customs and Excise
supported by DETR and DTI, agreed not to prevent exports until
we had been able to consider the matter more fully within Government.
We decided to continue this approach until 8 January under the
old control regime to give the trade time to adjust; from that
date fridges will have to be de-gassed before export, but exports
will be allowed to continue despite the CFCs remaining in the
foam. All of these measures are pragmatic responses to the concerns
of the trade and we continue to explore avenues available to us
to try and ameliorate the effects for the Regulation on this trade.
We took these steps because we realised our
consultation process on the Regulation had missed the trade, despite
including both the refrigeration and white goods trade associations.
We have sympathy with the many small businesses who are not always
able to follow changes in legislation and, in this case, appear
not to be members of trade associations. Unfortunately neither
business nor Government seems to have appreciated the implications
of this part of the Regulation.
Regulation 2037/2000 (Article 16) also requires
Member States to recover (and, in the case of CFCs, destroy) controlled
substances in domestic refrigerators from 31 December 2001. The
UK is required to report to the European Commission by that date
on the facilities available for the recovery of controlled substances.
We are urgently looking at the best way to implement
the requirements of EC Regulation 2037/2000. You can be assured
that we are now fully aware of the extent of the trade. We will
continue to keep the trade informed of any changes to the way
in which the Regulation is to be implemented.