Memorandum by the Association of Charity
Shops (RC 19)
INTRODUCTION 1. The
Association of Charity Shops welcomes this opportunity to contribute
to the debate about waste management in the UK. The Association
of Charity Shops is a member organisation which represents, supports
and acts for charities which operate charity shops. At March 2007,
the Association had around 270 member charities, ranging from
the very largest national charities to local hospice charities.
Together, they operate 6,800 charity shops across the UK. In 2006,
charity shops raised £110 million for vital charitable causes.
Over 91% of charity shops' income derives from the sale of donated,
secondhand (ie reused) goods.
2. In addition to raising funds, charity
shops offer key learning and development opportunities through
volunteering to many who might otherwise remain socially excluded.
Charity shops are supported by over 120,000 volunteers nationwide.
3. Charity shops play a key role in waste
minimisation—over 250,000 tonnes of textiles and other goods
are reused or recycled through charity shops each year. Goods
sold through shops or passed on for reuse elsewhere do not enter
the waste stream. Given this role, and the wide geographical coverage
of charity shops—on more or less every High Street, and
easily accessible by the overwhelming bulk of the population—the
sector plays a significant but often unrecognised role in sustainable
waste management and promotion of the Government's waste strategy.
CONSIDERATION
4. There are four key areas where the sector's
contributions and role are relevant to the wider waste management
issues under consideration by the Committee:
(a) charges for the collection of waste from
charity shops;
(b) the provision of facilities at civic
amenity (CA) sites;
(c) the unintended consequences of direct
charging for householders' waste; and
(d) policies on recycling and reuse credits.
Each of these has implications for the effectiveness
of the sector, not only in its key role of raising funds, but
also in terms of its contribution to environmental gains.
Charges for the collection of waste from charity
shops
5. Schedules 1 and 2 to the Controlled Waste
Regulations (SI 1992 No 588) (as amended) class waste from charity
shops as household waste, for which a collection charge only may
be made. However, a significant number of waste collection authorities
(WCAs), particularly in England, incorrectly charge for the collection
and disposal of this waste. In some cases, the imposition of incorrect
charges for disposal can double a charity shop's waste bill. Although
robust estimates are difficult to make, a typical charity shop
might spend £400 per year on waste collection services. The
imposition of incorrect disposal charges adds a further £400.
We estimate that, across the UK, these unfair charges may be costing
in the order of hundreds, as opposed to tens, of thousands of
pounds each year. By contrast, the tonnages diverted from the
waste stream by charity shops save authorities in the order of
£6 million per annum in landfill taxes avoided, at current
prices.
6. In February 2006, Dr Alan Whitehead MP
wrote to all English WCAs on our behalf to enquire about their
policies. Following this, and similar approaches by the Association
to WCAs elsewhere, we launched an intense campaign to persuade
individual authorities to change their policies to charge correctly
for charity shop waste, ie for collection only. In parallel, our
members have lobbied their own authorities. In September 2006,
officials at DEFRA agreed to write to WCAs to remind them of their
responsibilities under the current legislation.
7. A significant number of authorities have
responded positively to this campaign, and 50 have changed their
policies. However, despite our campaign, and despite DEFRA's write-round,
a much more significant number continue to overcharge, many are
obfuscating and some simply ignore the arguments. A list of 107
authorities in England, which are, or may be, overcharging is
at Annex A.
Charity shops reduce waste through reuse and
recycling, and encourage an environmentally and ethically sound
shopping culture. Nothing that can be reused or recycled is put
out to waste.
We believe it is incumbent on local authorities,
as emanations of the state, to respect and apply the law. In these
cases, many are not doing so. Overcharging for waste by authorities
diverts money and other resources from charity shops' primary
aim of raising funds for their parent charities and fails to recognise
the significant contributions they make to waste reduction. Many
local authorities' policies give precedence to short-term financial
considerations rather than the longer term benefits of working
in partnership with the voluntary and community sector to reduce
waste. We urge the Committee to agree that this is unacceptable.
Facilities at, and charges for using, local authority
civic amenity (CA) sites
8. Currently, local authorities must only
accept waste at CA sites from "residents" of an area
free of charge. For all others, it is entirely for each authority
to decide what waste to accept, from whom, when and at what cost.
This means that very different arrangements and charges apply
even between neighbouring authorities. To our knowledge, as few
as 36 English Waste Collection and Disposal Authorities offer
free or concessionary facilities for charity shops at their sites.
Regular research over the past four years for the Association
shows that over 70% of charity shop visitors (donors and purchasers)
live within three miles of their favoured shop. Thus, items given
to charity shops are likely to have come from local residents.
9. As noted above, charity shops will not
put out to waste anything that can be reused or recycled—it
does not make economic sense for them to do otherwise. However,
because charity shops receive a proportion of donations which
cannot be resold or recycled, it is inevitable that they produce
waste, some of which will be bulky. In the absence of charity
shops, many donations would have gone to landfill as waste. Waste
from charity shops, therefore, is only the unuseable residue of
reuse and recycling efforts. The value of recognition of these
efforts was summed up by the Minister for Local Environment Quality,
in his letter of 7 March to Chief Finance Officers. Mr Bradshaw
noted that waiving tipping fees helped "to promote constructive
partnership working with the sector".
We believe that, given the contributions charity
shops make to waste prevention, coupled with the domestic origin
of much of this waste, the Committee will agree that these charges
may be seen to penalise the promotion of reuse. We invite the
Committee to press HMG to continue its encouragement to authorities
to waive charges, and to issue supporting guidance.
Direct charging for housholders' waste—unintended
consquences
10. Over many years, charity shops have
been seen by some householders as a convenient "dumping ground"
for unwanted goods, regardless of their condition. Although the
Association and its members have gone to considerable lengths
to encourage members of the public to donate only good quality
(ie sellable or re-usable) goods, a proportion of donated goods
remain in poor condition. A sample of waste which had to be dumped
from just one charity shop included single shoes, broken toys,
torn books, broken hangers and used toiletries. These items are
often left outside charity shops when they are closed, and can
cause a nuisance and health and safety hazard to staff, volunteers
and others.
11. We believe the introduction of direct
charging for residual household waste runs the risk that this
dumping—"fly tipping by stealth"—might increase.
There is a risk that direct charges will not change individual's
behaviour to the good. Rather, many might be tempted to find other
routes to reduce the chargeable element of their waste, including
fly tipping. The Jill Dando Institute for Crime Science, for example,
reported that three times more people had considered fly-tipping
as had actually fly-tipped.[8]
The temptation is clearly there. The potential consequences for
charity shops of this temptation becoming action are significant.
This will only increase the financial and operational burdens
on charity shops, which will have to sort and arrange (and pay
for) the collection of this waste.
12. There is widespread public support for
charity shops—80% of the population have donated to charity
shops, and around two thirds have bought from them.[9]
This generosity is the bedrock of the success of the charity retail
sector. However, we are concerned that appropriate measures should
be in place:
(a) to ensure the minority of householders
are encouraged not to use charity shops as dumping grounds; and
(b) to encourage local authorities to apply
the spirit of the Clean Neighbourhoods and Environment Act and
work in partnership with charity shops to reduce the nuisance
this waste might cause.
We believe charity shops may become unwitting
victims of fly tipping by stealth by a minority, and urge the
Committee to press HMG to take these issues fully into account
in its Impact Assessment of any proposal to introduce direct charging.
Payment of recycling and reuse credits
13. As at March 2007, we believe only 87
English authorities pay recycling credits, and 57 pay reuse credits
to reuse groups. Many of these pay one type of credit, but not
the other. The value of recycling credits varies considerably,
from £3 per tonne to £53 per tonne (the average is £36
per tonne).
14. Payments of these credits can come in
one of two forms—waste disposal credits, to reflect disposal
costs avoided, and collection credits, to reflect savings on collection
costs. The Secretary of State has powers to introduce a duty on
authorities to pay waste disposal credits. He currently has no
such powers in relation to waste collection credits.
15. The system for paying waste recycling
and reuse credits to third parties is currently an opt-in system.
There is no obligation on authorities to pass on savings from
waste prevention measures to those who take these measures. The
Government expects waste authorities, however, to consider all
applications for third party credits where there are benefits
for a particular area, and would consider it unreasonable for
an authority to avoid paying credits where there is a clear contribution
to waste management in an area. Government expects authorities,
therefore, to be pre-disposed to paying credits.[10]
Mr Bradshaw's letter to Chief Finance Officers urged authorities
to support fully third sector efforts to prevent waste, including
"giving full consideration to paying recycling and reuse
credits to third sector organisations..."
16. Despite the Government's expectation
that authorities will be "pre-disposed" to pay credits,
the Association has anecdotal evidence that applications for recycling
credits are being dismissed out of hand.
17. Charity shops play key roles in both
recycling and reusing waste. Where donations cannot be sold for
reuse (as non-waste), charity shops will pass on as much as possible
for recycling (as waste). A number of Association members also
operate textile and other banks (whose contents are classed as
waste and are reused or recycled).
18. We believe the payment of credits could
be a powerful waste prevention tool. It has no cost, save minor
administrative costs, and not only encourages waste reduction
measures, but also helps local authorities meet demonstrably their
recycling obligations. Currently, reuse of waste does not figure
in calculations for these obligations. However, it appears that
relatively few authorities have embraced credits as a way to address
local waste issues, or as a means to demonstrate their own performance
in waste management.
We believe the credits system has been less
effective than it might have been, not least because so few authorities
are willing to pay credits, and because some have failed to embrace
the spirit, as well as the letter, of the scheme. To that extent,
we invite the Committee to agree that this voluntary system has
not worked, and that HMG and, in due course, Parliament should
consider whether a mandatory scheme is needed.
CONCLUSION
19. The charity shops sector plays a vital
role in preventing waste, encouraging a culture of reuse, and
recycling, a contribution which is under-recognised by many municipal
authorities. Unnecessary administrative and financial burdens
hinder the sector's efforts. The consequences of a direct charging
regime for householders' waste might also have the unintended
effect of further undermining these efforts. With the exception
of the credits system, many of these burdens can be removed by
simple administrative measures, and a willingness by local government
to work in partnership with charity shops.
20. The Association of Charity Shops, and
our members, are keen to continue to provide an environmentally
and ethically friendly way of shopping, which raises vital funds
for charity. We hope the Committee will support the actions called
for in this submission. We will be happy to provide further information
or clarification.
8 Fly-Tipping; Causes, Incentives and Solutions-The
Jill Dando Institute for Crime Science (www.jdi.ucl.ac.uk/downloads/publications/research_reports/fly_tipping/JDI_FlyTipping_ResearchReport.pdf) Back
9
From research commissioned by the Association from nfp Synergy-2007 Back
10
See DEFRA's "Guidance on the Recycling Credits Scheme",
April 2006. Back
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