Memorandum submitted by the Association
of Charity Shops (Waste 07)
EXECUTIVE SUMMARY
Introduction
1. The Association of Charity Shops is a
member organisation which represents, supports and acts for charities
which operate charity shops. In 2007, the Association has around
270 member charities, ranging from the very largest national charities
to local hospice charities. Together, they operate over 6,700
charity shops across the UK. In 2007, charity shops will raise
more than £110 million for vital charitable causes. Over
91% of charity shops' income derives from the sale of donated,
second-hand (ie reused) goods.
2. 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, the
sector plays a significant but often unrecognised role in sustainable
waste management and promotion of waste reduction.
Key issues
3. On the definition of waste, we strongly believe
there is a fundamental flaw in the Waste Framework Directive and,
to a lesser extent, subsequent UK policy, in that they effectively
exclude the reuse of non-waste as a component of any waste reduction
strategy The charity shop sector in the UK has demonstrated over
many years that this is an effective means to stop waste arising.
The Directive, on the other hand, only recognises reuse in terms
of the reuse of waste.
4. On proposals for financial incentives to recycle,
as a key player in waste reduction, the sector welcomes measures
to further reduce waste. However, the Government's proposals are
not workable, may prove to be counterproductive and may damage
the charity shop sector. In particular, we believe these proposals
will lead to an increase in flytipping, with direct effects on
charity shops. Charity shops are already used by some as a convenient
"dumping ground" for their waste, under the guise of
"donations". This will merely increase if there is a
financial incentive to reduce waste put out for collection.
5. On approaches to waste minimisation, we believe
the pan-European approach in the Directive does not recognise
the value of reuse of goods (as opposed to waste) in preventing
waste, and that the aspiration of creating a "recycling society"
is short-sighted. The UK has the resource available to take the
lead in promoting a culture of reuse, through the charity shop
network.
6. There are over 7,000 charity shops in
the UK, on virtually every High Street. The UK is unique in having
such a network. Staff and volunteers in charity shops have unparalleled
expertise in promoting reuse and in separating waste for recycling.
The role of charity shops in waste reduction is often unrecognised,
particularly by both central and local Government.
MEMORANDUM BY
THE ASSOCIATION
OF CHARITY
SHOPS
Introduction
7. The Association of Charity Shops welcomes
this opportunity to contribute to the debate about the waste strategy
for England. The Association of Charity Shops is a member organisation
which represents, supports and acts for charities which operate
charity shops. In 2007, the Association has around 270 member
charities, ranging from the very largest national charities to
local hospice charities. Together, they operate over 6, 700 charity
shops across the UK. In 2007, charity shops will raise more than
£110 million for vital charitable causes. Over 91% of charity
shops' income derives from the sale of donated, second-hand (ie
reused) goods.
8. 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.
9. 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 waste reduction.
10. The Association broadly welcomed the
Strategy's re-inforcement of the widely-accepted "waste hierarchy"
(below), and the commitment that "most products should
be re-used or their materials recycled". However, we
were very disappointed that the reuse of goods which have not
become waste seems, in fact, to have an almost negligible role
in the Government's proposals. This omission—which is also
seen on the wider EU stage, in the Waste Framework Directive and
CEC's Thematic Strategy for the Prevention and Recycling of
Waste—represents, in our view, a missed opportunity
to reduce waste arisings in the first place.
Consideration
11. There are three key areas in the Committee's
terms of reference to which we would like to contribute: the definition
of waste, proposals for financial incentives to recycle and approaches
to waste minimisation.
Definition of waste
12. Waste is defined as "any substance
or object... which the holder discards or intends or is required
to discard"[9].
This definition, and the types of substances covered by the definition,
are very wide indeed, and have been interpreted as such by the
European Court of Justice. The ECJ has concluded that this definition
does not exclude an intention to immediately reuse a good[10].
13. In its last correspondence with the Association,
the Environment Agency for England & Wales confirmed that
it considers that donations to charity shops are not waste.
14. We strongly believe that the focus on
waste is so pervasive in the Directive that it can only consider
reuse in terms of the reuse of waste. This effectively excludes
the reuse of non-waste as a component of any waste reduction strategy.
The principal debate about waste, therefore, becomes what to do
with it, and the focus is recycling.
15. We—of course—welcome measures
to reduce waste, and recycling has an important role in this.
However, an overriding focus on creating what the Commission describes
as "a recycling society" will not, in our view, address
key issues of preventing waste and avoiding additional environmental
costs. Recycling does not provide incentives to reduce waste arising,
and many recycling processes are costly and resource intensive
(to the extent that it is widely accepted that—in the waste
hierarchy—there may be circumstances where energy recovery
is preferable to recycling). Reuse of goods through charity shops,
on the other hand, does prevent waste being created in the first
place, does not involve significant "recovery" operations,
and provides the opportunity and incentive for consumers to reduce
demands on raw materials through their purchasing decisions. Re-use
of clothing saves 29kg CO2e per kg of clothing compared to recycling
and 33kg CO2e compared to disposal.
16. Reuse of goods which have not become
waste, such as through charity shops, sits right at the top of
the waste hierarchy, straddling "prevention" and "reuse".
As such, it is—by definition—to be preferred to reuse
of waste and to recycling as a waste reduction tool. We believe
that the absolute focus on waste in the Directive means that opportunities
have been missed to promote a culture of reuse of goods at the
European level, and are concerned that this opportunity should
not be missed at national level.
Incentives to recycle
17. The Association made a response to DEFRA's
consultation document Incentives for recycling by households
earlier this year. Given charity shops' role in promoting
ethical and environmentally sound shopping, we would welcome workable
and complementary measures to address waste issues in the UK.
However, we had, and still have, significant concerns about the
unintended consequences of the Government's proposals. Firstly,
we are concerned that—if there is a perception that "incentives"
are in fact charges for waste services—there will be public
and political pressure for additional charges for other waste
streams (such as for chargeable household waste). Given that charity
shops already pay reasonable charges for the collection of their
waste, any such increase would be unfair and counterproductive,
given the vital role shops play in promoting waste reduction,
reuse and recycling, not to mention damaging to shops' principal
purpose, which is to raise vital funds.
18. Secondly, there is no incentive in the proposal
for householders to increase recycling—rather, the incentive
is to reduce what is put out for collection. We are concerned
that this might be achieved by displacement of waste, rather than
by efforts to reduce it. The Select Committee on Communities and
Local Government's report on Refuse Collection[11]
noted that other countries with similar incentive schemes experienced
periods of increased flytipping, albeit sometimes on a short term
basis. However, no other nation has the same network of charity
shops that the UK has (as the Strategy itself notes on page 96),
and therefore the potential for flytipping under the guise of
"donating" to a charity shop. This "flytipping
by stealth" already exists, and might be exacerbated by a
scheme which introduces a financial incentive to displace waste.
The Jill Dando Institute for Crime Science noted that three times
as many people had considered flytipping as had actually done
so[12].
And our members already suffer from "dumping" of un-saleable
items outside their premises despite clearly stated messages and
posters that donations should only be made during shop opening
hours.
19. Any increase in this fly tipping will
impose costs on shops having to sort, arrange for and pay for
this waste to be collected. Flytipping by stealth may also harm
public perceptions of shops, because of potential waste "mountains"
accumulating outside shops. At the same time, some local authorities
are already reluctant to meet their duty of care and participate
in clearing up this waste, and dealing with an increase in this
waste may further strain shops' relationships with their Waste
Collection Authorities.
20. We believe the Government's proposals,
as drafted, will—at least in part—create an incentive
to displace, rather than reduce or recycle, waste and that charity
shops will be a focus for an increase in "flytipping by stealth".
Approaches to waste minimisation
21. As noted above, we believe effective
waste prevention measures must include the promotion of the reuse
of goods which have not become waste.
22. There are over 7,000 charity shops in the
UK, and the Association's members operate over 6,700 of these.
It is the only sector able to truly claim to have a "shop
on every High Street". More than 120,000 volunteers and 10,000
paid staff in charity shops have unparalleled experience and expertise
in promoting reuse of goods and materials. This is a huge sector—in
terms of numbers of volunteers, the sector is larger than the
entire social economy network of reusers and recyclers throughout
the rest of Europe. We believe the contribution shops make to
reuse should be recognised more widely and encouraged as a key
plank of any waste reduction strategy.
23. Encouraging reuse via charity shops
has a range of advantages and benefits:
— There are no costs to residents
— Donated goods will be reused through
shop sales, or—if at all possible—passed to responsible
recyclers
— There is key added value to charities
from the sale of donations
— The carbon footprint of reuse through
charity shops is negligible
— Charity shops are conveniently located
on most High Streets
— Some charities carry out planned
house to house collections, and all will be happy to arrange to
collect
— Donations passed on for recycling
could count towards LA recycling targets
— Of donations made to charity shops,
very little ever ends up in the municipal waste stream
24. We firmly believe that reuse of goods
and materials that have not become waste should be seen as a key
mechanism to minimise waste. The network of charity shops in the
UK is well placed to make a significant contribution to this.
CONCLUSION
25. Charity shops exist to raise vital funds,
principally through the sale of donated goods. This means they
play a major role—on the High Street and accessible to all—in
promoting the value of reuse of goods and materials. 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 will be happy to provide further
information or clarification.
Association of Charity Shops
October 2007
9 Council Directive 75/442/EEC on waste, as amended-the
"Waste Framework Directive". Back
10
In, for example, Zanetti et al, joined cases C-206&7/88
& C-359/88. Back
11
Fifth Report of 2006-07: HC 536-I. Back
12
Fly-tipping: Causes, Incentives and Solutions: Jill Dando
Institute of Crime Science/University College London, 2006. Back
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