APPENDIX 2
Memorandum submitted by the British Soft
Drinks Association (BSDA)
The British Soft Drinks Association is the national
trade association representing the interests of the UK's manufacturers,
factors and franchisors of soft drinks. Member companies make
up over 90 per cent of the industry, supplying still and carbonated
drinks, fruit juices and bottled waters with annual consumer sales
in excess on £7.8 billion.
INTRODUCTION
Although the use of CFC's as a blowing agent
in insulating foams ceased in 1994 (with the use of HCFC's continuing
for several years after), BSDA members own over 400,000 pieces
of affected equipment currently in the marketplace. They comprise
mainly display refrigerators, vending machines and soft drinks
dispensing systems, installed in a diverse range of outlets from
garage forecourts and corner shops to cinemas and public houses.
BSDA members are incurring the costs and disruption caused through
the misunderstanding, misinterpretation and poor consultation
by Government of EC Regulation 2037/2000.
BSDA CONCERNS
The lack of forewarning and information to industry
has resulted in member companies being unable to budget for future
waste disposal costs. Some reprocessors are still unable to provide
costs for the disposal of implicated plant. This hampers business
planning and puts additional burdens on UK industry, which is
still unsure as to the total cost of compliance. This also raises
questions as to the economics of refurbishing equipment and may
impact on the purchase of new plant.
Members only discovered the full implications
of the Regulation by word of mouth, when some companies were denied
access to waste reprocessing facilities in September 2001. This
was a clear oversight by Government department in identifying
those industries affected by the Regulations.
The first discussion forum open to owners of
commercial/industrial equipment took place between DEFRA/DTI and
affected parties in November 2001, some 13 months after implementation
of the Regulations for commercial equipment.
BSDA members are concerned about Government's
failure to understand the implications of the Directive on commercial
users of refrigeration equipment.
Over a year after the Regulations came into
force, there still exist no reprocessing facilities in the UK,
forcing industry to bear otherwise avoidable costs for the storage
of waste equipment.
Recent developments have demonstrated a lack
of coordination within Government. This led to the Environment
Agency not being present at both commercial/industrial user meetings
last year, delaying information important for industry planning.
With a UK reprocessing standard (such as the German RAL standard)
still not approved by Government, there will undoubtedly be further
delays in addressing the much publicised 'mountain' of spent equipment
awaiting disposal.
There appeared to be confused communication
between DEFRA, the Environment Agency and Local Authorities. This
led to inconsistent guidance being offered by the Environment
Agency and Local Authorities on important storage and handling
issues.
CONCLUSIONS
The soft drinks industry supports measures to
protect the environment where appropriate. However Government
clearly agreed to a Regulation in Brussels without a full understanding
of the issues. An inadequate consultation process has left industry
to absorb excessive costs and devote valuable resources to an
otherwise preventable fiasco.
BSDA will be seeking to set up meetings with
the relevant parties on a regular basis, and helping to ensure
that Government Departments are better briefed when assessing
the impact of draft EU Regulations and those whom it affects.
Earlier involvement of industry in the consultation process may
have led to this unwelcome situation being avoided.
British Soft Drinks Association
22 February 2002
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