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

Correspondence from Dixons Group Plc to the Minister of State for the Environment 24 November 2000

  I am writing to you as a matter of urgency with regard to proposals to ban the export of appliances that contain CFCs.

  Dixons Group companies have for many years operated as responsible retailers by offering a service to their customers that allows for the collection of redundant appliances upon the delivery of new replacements. All products collected in this way are passed through a network of approved contractors who manage the recycling or refurbishment of the items in accordance with the law and the particular environmental and safety requirements of Dixons. Refrigerated appliances are just one group of products that are handled using this mechanism, a proportion of which are reconditioned and sold overseas where they are a valuable commodity that continue to be put to good use for many years.

  The new EC Regulation on Substances that Deplete the Ozone Layer (2037/2000) has been designed to prohibit the export of products containing CFCs. These may be found in refrigerated products that are over five years old. Current practice ensures that thee CFCs are removed from the compressor circuit and disposed of. However, the technology is not available in the UK to remove CFCs from foam.

  A consequence of the rigid application of this Regulation will be that our contractors will no longer be able to offer a route for the re-use of the refrigerated products that we collect. We will then have to reconsider our service proposition with regard to accepting such appliances from customers. Indeed, we understand that one electrical retailer has already taken a decision to no longer collect such fridges and freezers.

  The overall result of this approach will be that a currently well managed and environmentally responsible trade will be forced out of existence. This will lead to wholesale indiscriminate dumping which in turn will inevitably result in the release into the atmosphere of CFCs when such products are vandalised or crushed for disposal. It will ultimately be Local Authorities that are left to deal with this increase in problematic proposal.

  The urgency of this letter is because we understand you are soon to hold a meeting to ratify the ban. We must ask that, in the first instance, you consider the consequences of banning the export of CFC impregnated foam in refrigerated appliances in the light of the negative environmental consequences that will arise from it.

  We understand that while the proposed ban arises from an agreed EU regulation, most member states have yet to operate the ban to the level proposed by your Department. Indeed, we believe only one other member state has agreed to implement this proposal in a similar way. If the proposal is not applied consistently across the European Union then massive diversion will occur. However, even that option would not be left open to contractors in the UK.

  We would hope that further consultation can resume so that a practical phasing out plan can be agreed, one that will ensure the proposal achieves its aim of significantly reducing CFC emissions.

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