Memorandum submitted by the Salvation
Army Trading Co Ltd (SATCoL) (Waste 05)
EXECUTIVE SUMMARY
1. Depending on the collection receptacle
second hand clothes may be classified either as waste or a donation.
This has nothing to do with Article 1(a) of the Waste Framework
Directive which provides that:- "waste" is " . . .
any substance or object . . . which the holder
discards or intends or is required to discard."
2. It has been conclusively reported that the
re-use of clothing in CO2e terms is more beneficial than recycling.
Since moving to "sorting original clothing abroad" significant
improvements to the environmental, social and economic objectives
have been observed.
3. The potential consequences of the inappropriate
application of the current definition of waste could be the cessation
of textile collections in the UK unless significant subsidies
were to be made to the industry.
4. We would ask that genuine "original"
charitable donations of clothing collected from recycling
banks or door to door bag collections are not classified as waste.
The arguments and statistics given clearly provide the evidence
for this.
5. SATCoL's requests for good quality wearable
clothes are identical on bags and banks.
6. The public believe they are donating
useful clothes to a "good" cause not discarding waste.
7. Our processing regime removes "contras"
which are not clothing.
8. Exporting "original" clothing
prior to sorting:—
(a) significantly benefits the environment
(b) achieves social objectives
(c) realises economic intentions
9. Moving to this more equitable approach
will encourage a greater diversion of clothing from landfill.
INTRODUCTION
10. In HM Treasury Sustainable Development
Action Plan[2]
we read:—"action to protect the environment must take
account of wider economic and social objectives." Rick Haythornthwaite
(chair of the Better Regulation Commission) wrote in the Guardian
in July this year:—"We all believe that recycling is
good for the environment, so it seems obvious that making use
of waste rather than just getting rid of it should be encouraged . . ..
Yet it is often far from easy to do so because of regulatory controls.
A balance is needed between protective controls and over regulation
that may inhibit any new ideas and the progress of re-use/recycle."
11. It is from these stand points as well as
the need to maintain a profitable enterprise, which conforms to
but is not restricted by regulation that we make this submission.
12. This submission only concerns the classification
of waste so far as textiles and clothing is concerned.
13. Confusion is widespread at present.
According to information received from the Environment Agency
clothing placed in a recycling bank is waste, yet that placed
in a plastic bag on the doorstep is considered a donation!
CONSIDER THIS
SCENARIO
14. A member of the public fills a bin liner
with clothes. Their wish is that it will be put to use helping
others. Within the bag there is an heterogeneous mix of garments—some
excellent quality, some less so—however, the householder
rightly believes that the industry experts will use all of them
to the best of their ability. The bag is taken to a Salvation
Army charity shop ie it is a donation. Unfortunately for the donor
the shop is overflowing with contributions and has no more storage
room. The shop staff, therefore, direct the benefactor to a Salvation
Army clothing bank about 100 yards away. During that short journey
the clothes mysteriously transform into waste. Nothing has changed.
The donor's intentions remain the same; the only difference is
in the receiving receptacle—a recycling bank rather than
a shop.
15. Interestingly the requests from The Salvation
Army charity shops and on the plastic bags and clothing banks
that we use are identical:—"Please provide good quality
men's, ladies and children's clothing including underwear &
accessories."
16. This is the first area of confusion.
CO2E BENEFITS
17. Referring to the Salvation Army Trading
Co Ltd, NIRI, Oakdene Hollins Ltd report entitled Recycling of
Low Grade Clothing Waste—Defra Contract Reference: WRT152,
submitted October 2006, we find that so far as CO2 is concerned
that reuse is of greater benefit than recycling.
Figure 1: CO2e Benefits of Closed Loop
Recycling / Reuse compared to Landfill Disposal[3]
18. This, then, leads to the second area
of confusion.
19. Which is better for the environment—to
sort in the UK or in the developing world where more items are
reused?
SORTING RATIONALE
20. For many years second hand clothing
has been exported to "developing countries". When this
unique humanitarian trade started, environmental issues had not
even been thought about let alone discussed. We, in the UK, collected
the clothes—often the residue from charity shops after our
own citizens had bought what they wanted—and then sorted
them before sending them overseas. In those days most of the exports
went to the African continent, and naturally, due to their climate,
they only needed the "light" weight items. The "heavy"
garments were then sent to the flocking and shoddy processors
(recyclers) in the UK. Some were also turned into wiper cloths
for British industry; indeed The Salvation Army manufactured their
own brand—Wipeouts!
21. At the end of the 1990's the statistics for
a typical sort were 63% re-usable, 30% sent for recycling, and
about 7% sent to landfill—mainly coat hangers, plastic bags,
single shoes and so on.[4]
TIMES AND
FASHIONS HAVE
CHANGED!
22. The east and the west are developing
free trade. The quality of clothes is decreasing. The manufacturing
base has moved eastwards. New markets with differing needs are
opening. The environment, and it's protection, is of major concern.
23. As a responsible company we evaluated the
emerging conditions. We noted that the "eastern" bloc
needed winter as well as summer garments. New jobs needed to be
created in these embryonic nations. Due mainly to the decline
in UK plc manufacturing base recycling of the un-wearable clothes,
in the UK, was in rapid decline.
Table 1: Breakdown of the UK recycled
textile market[5]
Application
| Volume
(Tonnes/yr) | Market Proportion
(%)
|
Mattress/Upholstery | 41,000
| 66 |
| Carpet Underlay | 6,800 |
11 |
| Automotive | 5,400 | 8.7
|
| Other | 8,800 | 14.3
|
| Total | 62,000 | 100
|
| |
|
A SOLUTION WAS
FOUND!
24. Our procedures would be modified as follows:
25. Firstly, so far as we are able, we ensure that all humanitarian
needs for clothes both at home and abroad are satisfied. Happily,
we receive much more than we can use in this way and so after
supplying our charity shops the remainder is transported to our
central transfer facility in Kettering. Here, each donation is
processed to remove bric-a-brac, books, & any waste or soiled
items; the rest of the garments are then re-packaged and loaded
onto trailers for transportation by sea and road to new markets
to begin their second life of clothing people. The funds raised
are then used to help finance the work of The Salvation Army in
the UK.
Table 2: Initial Processing of Clothing Donations
to The Salvation Army prior to Export[6]
Donations collected |
| July 2007 Kgs | August 2007 Kgs
|
| Clothing | 2,541,990
| 3,010,620 |
| Books | 45,290
| 56,050 |
| Total Collected | | 2,587,280
| 3,066,670 |
| Contras—recycled in UK |
| | |
| Metals | 970
| 1,329 |
| Glass | 50
| 51 |
| Pallets | 4,000
| 4,000 |
| Bric-a-brac | 2,500
| 2,500 |
| WEEE | 510
| 1,120 |
| Total Contras Recycled | |
8,030 | 9,000 |
| Discards (inc soiled clothes) |
| | |
| Unusable | 63,290
| 49,400 |
| | |
|
| Total available for Export |
| 2,515,960 | 3,008,270 |
| |
| |
THE RESULTS!
26. The "sort" statistics have improved significantly;
today in the Ukraine (one of our main export markets) 83% is reused
as clothing, 14% turned into wipers and only 3% is deemed unusable.[7]
27. Although this activity occurs abroad the benefits to the
global environment are legion.
28. Jobs, too, have in total increased—many thousands
are now employed processing the clothes in their own countries
and of course, here in the UK, our collection work force has expanded
to cope with the extra clothing placed in our clothing banks and
collection bags.
29. Interestingly, the improved efficiencies this has
brought to our organisation have helped reduce our overheads and
thus contribute even more funds to be used by The Salvation Army
for its social work in the UK.
30. This satisfies all 3 objectives defined in the HM
Treasury Sustainable Development Action Plan 2007.
Figure 2: Fate of Donated Clothing in 3 different countries[8]
LINE OF
REASONING
31. It is our contention that as an organisation we are
acting in the true spirit of sustainable development. In all situations
unless every single item is examined—and this is very subjective,
what is wearable to one person may not be to another—it
is impossible to ensure that they are all of wearable quality.
However, a balance needs to be struck between what is economically
viable, the effects on the environment, and the needs of people.
We believe that our approach provides, in today's "climate",
the most realistic and sustainable methodology to ensure that
this balance is obtained and maintained.
POTENTIAL ADVERSE
CONSEQUENCES
32. The consequences of classifying collected second
hand clothing as waste rather than donations could be catastrophic
to UK plc as well as to The Salvation Army.
i. significantly adversely effecting profitability and
possibly leading to employee "lay offs" or
ii. requiring significant government subsidies
(c) Deprive the "developing nations" of large quantities
of wearable/usable items. What to us is unwearable is still of
use to someone who has nothing.
PROPOSAL
33. Second hand clothing collected and processed in the
manner described should not be classified as waste. The public
believe that they are making a useful donation to our organisation
to be used to help others less fortunate than ourselves. Treating
such items as waste is an incongruity.
34. We would propose that genuine original charitable donations
of clothing are not classified as waste given the arguments
and the "sort" statistics provided in this submission.
Salvation Army Trading Co Ltd (SATCoL)
October 2007
2
HM Treasury Sustainable Development Action Plan 2007. Back
3
Recycling of Low Grade Clothing Waste-Defra Contract Reference:
WRT152, submitted October 2006-page 72. Back
4
Ibid.-page 34. Back
5
Ibid.-page 85. Back
6
Internal records. Back
7
Personal communication. Back
8
Recycling of Low Grade Clothing Waste-Defra Contract Reference:
WRT152, submitted October 2006 & personal communication. Back
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