Select Committee on Environment, Food and Rural Affairs Appendices to the Minutes of Evidence


Memorandum submitted by the British Retail Consortium


  The British Retail Consortium [BRC] represents the whole range of retailers, from the large multiples and department stores through to independents, selling a wide selection of products through centre of town, out of town, rural and virtual stores.

    —  Retail accounts for 5.2 per cent of the whole UK economy.

    —  Retail accounts for 11 per cent of the UK workforce.

    —  In the 12 months to March 2001 the industry created 105,100 net new jobs.

  Attached is a chronology of events prepared by the British Retail Consortium on the implementation of the Ozone Depleting Substances Regulations 2000 in the United Kingdom. [1]

  The aim of this submission is not to recount the events of the last two years but to draw to the Select Committee's attention a number of issues which the BRC believes the Select Committee should consider, including:

    —  Reinstating retail take-back schemes for fridges and freezers;

    —  Impact on investment in retail, hotel and hospitality refurbishment;

    —  The impact on the UK implementation of the European Waste from Electric and Electronic Equipment (WEEE) Directive; and

    —  Incorporation of the European Hazardous Waste List into the UK Special Waste Regulations.


  Firstly, it is important to understand that every retailers' take-back system have historically operated differently. In broad terms, the large retailers have collected old fridges, freezers, washing machines, tumble dryers and cookers from customer's houses when delivering new products from regional depots. Old products were returned to regional depots where recycling/refurbishing contractors collected them. These contractors separated products for refurbishment, export, resale or recycling. Independent retailers have historically had relationships with local refurbishment companies.

  Alongside these services many manufacturers have delivered new products (ordered from retail stores) direct from their warehouses and collected old products at the same. These account for approximately 250,000 fridges and freezers a year. These companies need to be involved in any discussions on reinstating take-back systems. They have not been fully consulted to date.

  Retailers have offered these customer services and accepted the costs of collection and transportation. Recycling/refurbishing contractors have removed old product from sites free of charge or at low cost, although we understand that many are now seeking payment as the potential income from recycling has reduced or ended. Several have withdrawn from the industry and we believe may not re-enter. Retailers are not seeking finances for the collection of old products but in order to reinstate services they need a free, legal disposal route for the products they collect.

  In November 2001 UK manufacturers and contractors stopped offering retailers collection services as there was no legal disposal route, of any scale, available to them. Retailers had no choice but to stop offering this service to customers. However, reinstating these services when disposal routes come on line will not be simple. Many contractors have gone or will go out of business before plants are built. Moreover, the economics have changed forever with the ending of the export market.

  Prior to the implementation of the ODS Regulations approximately 70 per cent of fridges/freezers were exported for second use, 15 per cent were refurbished for resale within the UK and 15 per cent were sent for disposal/recycling. Thus 85 per cent financed the disposal of 15 per cent.

  However, the position is now radically different. With no export market open and no projected increase in the UK second-hand market the sale of 15 per cent refurbished fridges cannot support the disposal of 85 per cent of the fridges collected.

Moreover, it has become apparent that the export/refurbishment market for fridges has financially supported the collection and disposal of cookers, washing machines and tumble-dryers, thus collection services for these products are now also under threat.

  These contractors have played an integral role in the retail collection and best use of large white goods in the UK but their business models have been radically altered. This must be addressed for the refurbishment/recycling collection systems to come back on line. If it cannot be made economically viable for these contractors to continue to operate then an alternative infrastructure involving local authorities will be required.

  Any solution must take into account the varying needs of retailers both large and small.


  It was confirmed by DEFRA in December 2001 that the ODS Regulations have in fact applied to commercial refrigeration equipment since November 2000 in the same manner as for domestic fridges and freezers. Commercial refrigeration equipment includes fridges, freezers, vending machines and cold rooms in shops, pubs, hotels and restaurants.

  Businesses that are refurbishing are finding it very difficult to agree the removal of old refrigeration equipment. This will have severe financial implications for UK plc as refurbishments worth £100 million are delayed or even postponed whilst suitable storage/disposal routes are found for large volumes of commercial refrigeration equipment. There are very good health and environmental reasons why replacement of old equipment should not be delayed.


  The BRC has argued strongly for the last few years that in-store retail take-back as originally proposed in the WEEE Directive is the worst possible environmental and economic option for the collection of diverse electronic waste streams. The BRC and our members were relieved when amendments were introduced to the Directive, which allowed for alternative systems to in-store take-back.

  The BRC believes that the systems in operation in the UK until November 2001 with collection of large white goods through the home delivery networks and small electrical goods at local amenity sites would have ensured that the significant contribution made by UK retailers would have enabled the UK to have exceeded its national target. It is imperative therefore that any solution to the current fridge crisis should take account of this forthcoming Directive and ensures that the both economic and environmental implications are properly evaluated. Any solution should not be a short-term solution.


  The UK Special Waste Regulations are being reviewed to take account of changes to the European hazardous waste catalogue. As a result, more waste types will be classified as hazardous waste, including waste electrical appliances which contain CRTs, lead, mercury, CFCs, HFCs, batteries etc. This includes many items from televisions to single fluorescent tubes.

  Currently, Exemption 28 of the Waste Management Licensing Regulations allows retailers to take back electrical goods and store them on site for up to 28 days before sending them for recovery without the need for a waste management licence. However, once categorised as Hazardous Waste, this exemption will cease and there is currently no other applicable exemption, which would mean that any retailer taking back end-of-life products would require a full hazardous waste management licence. This would be extremely costly, impractical and would undermine all the aims of the WEEE Directive.

  Moreover many waste sites and local authority sites are not currently licensed to take hazardous waste and do not having the requisite planning permissions.

  The United Kingdom is supposed to have implemented the Hazardous Waste list into UK law by 1 January 2002. The implications of this change of regulations could be far more severe than the current fridge crisis

British Retail Consortium

27 February 2002

1   See memorandum submitted by Dixons Group plc, Ev 30. Back

previous page contents next page

House of Commons home page Parliament home page House of Lords home page search page enquiries index

© Parliamentary copyright 2002
Prepared 20 June 2002