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


Memorandum submitted by the British Retail Consortium


  1.  The British Retail Consortium [BRC] represents the whole range of retailers including the large multiples, department stores and independent shops, selling a wide selection of products through centre of town, out of town, rural and virtual stores:

    —  The retail sector is 7 per cent of value added.

    —  The retail industry employs 2.8 million people in the UK, as at December 2001. This accounts for 11 per cent of the UK workforce, equating to one in nine jobs.

    —  In the 12 months to December 2001 the retail industry created 91,500 net new jobs.


  2.  The European Commission published a revised European Waste Catalogue and hazardous waste list in February 2001. This added around 250 waste types to the hazardous waste list, including waste electrical appliances that contain CRT's, lead, mercury, CFCs, HCFCs, batteries. This means that a whole range of end-of-life products will now be classified as hazardous waste are items of equipment including-fluorescent tubes, computers, toasters and fridges-and will have therefore have to be treated as hazardous waste following the stringent regulatory requirements of the Special Waste Regulations 1996. Many of these products are used by a wide range of business sectors traditionally not regarded as producers of hazardous waste.

  3.  The BRC fully supports the need for these end-of-life products to be safely disposed of so as to avoid environmental harm but is concerned about the serious implications of their reclassification as hazardous waste.


  4.  A large proportion of Waste Electrical Equipment (predominantly large white goods) is currently collected by retailers when delivering new products. Many retailers, both large and small, provide this service free-of-charge to customers.

  5.  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/recycling without the need for a waste management licence. However, once categorised as hazardous Waste, exemptions of this kind will not be valid as it is illegal in Europe to hold or treat hazardous waste under an exemption. This will mean that any retailer taking back end-of-life electrical products will require a hazardous waste licence. If this approach is taken it could extend to retail distribution centres, warehouses, yards and possibly even the stores themselves. This will be extremely costly and burdensome from an administrative point of view especially for small independent retailers who only take back a small number of products.

  6.  The BRC finds it hard to reconcile the likely outcomes of these changes with the development of the EU Directive on Waste from Electrical and Electronic Equipment which will require the take-back, handling and storage of electrical products via "a yet to be devised" system.


  7.  End-of-life products that are currently handled as controlled waste will soon have to be treated as hazardous waste. Thus environmental, health and safety legislation that applies to hazardous waste management sites is complex and detailed. In handling hazardous waste, retailers will be required to ensure that all health and safety legislation is met. This will require the training of large numbers of staff to a high level in order to safely allow them to handle hazardous materials.


  8.  From reading the text of the EU Landfill Directive it appears that for the purposes of disposal the new definition of hazardous waste will apply from August 2002, almost certainly before the changes to the special waste regulations are amended and fully implemented into UK law. From this date, landfill regulations will prohibit the landfill of hazardous waste except at sites classified as 'hazardous landfill'.

  9.  The BRC is concerned that without any clear guidance from the relevant authorities confusion will reign as to which point in the waste generation and management chain the new classifications should apply. Will a fluorescent tube currently not classed hazardous in the UK be able to enter the waste stream as normal or will the Landfill Directive changes require it to be recognised as hazardous despite the UK not having implemented the full changes? This is extremely important for both the waste management industry and waste producers as guidance may result in the need to change systems, procedures, paper-work and introduce additional employee training.

  10.  The lack of consideration for all forthcoming regulations affecting waste electrical and electronic equipment as a whole will once again lead the United Kingdom towards adopting over complicated, expensive and fragmented policies that each target only one aspect of the waste stream concerned. This approach will fail to deliver the best environmental solution.

British Retail Consortium

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Prepared 26 July 2002