Select Committee on Communities and Local Government Committee Written Evidence


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


 
previous page contents next page

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

© Parliamentary copyright 2007
Prepared 11 October 2007