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

Correspondence from Dixons Group plc to the Minister of State (Environment), 10 August 2001


  I am writing to seek guidance from your Department on what measures the government intends to take following the review of the Special Waste Regulations and the changes to the Montreal Protocol giving rise to the new EC Regulation on Substances that Deplete the Ozone Layer.

  Our particular concern is the effect that these new controls may have on the take back service that we currently offer to our customers for large domestic appliances.

  Over the last financial year the Dixons Group, (the parent company of Currys) recovered 730,000 redundant white goods when delivering new products to our customers' homes. More than 300,000 of these were refrigerated. At present, these redundant appliances are returned to one of our 18 local distribution centres, from which point we subcontract their disposal, mainly through relatively small sub-contractors whose core activity revolves around the reconditioning and sale of appliances or recycling for material recovery.

  Although retailers have no obligation to take-back redundant products from customers we feel that this is a valuable service. We are worried about any threat to this service that could be a consequence of the new regulations.


  As a result of the review, we understand that waste electrical appliances containing CRTs, lead, mercury, CFCs, HCFCs, batteries etc, will be classed as hazardous waste from January 2002. While we accept the need to control materials and substances that are hazardous to human health and the environment, we are concerned at the possible implications of increased licensing requirements both for our facilities and stores and those of our sub-contractors.

  At present, retailers which recover redundant end of life electrical products for recycling are exempt from requiring a waste management licence provided the waste products are removed from our premises within a set time-scale (Exemption number 28). We have found it difficult to obtain clear guidance on whether this exemption will remain appropriate for our operation once the definition of special/hazardous waste is expanded. Indeed the advice given by DEFRA and the Environment Agency thus far seems to contradict each other.

  While DEFRA suggests that our current exemption does not cover special waste, implying that we would need a special waste licence, the Environment Agency (EA) advise that the current exemption has been amended to cover ordinary and special waste. The EA suggest that if that proviso remains in place the replacement of the term "special" with "hazardous" would not require a further licence. Clearly, if this change is to take effect from January and licences are required, time will be needed to apply for licences and for these applications to be processed. It seems, at present, that those involved in managing this waste stream will have to wait until late in the year before DEFRA and the Environment Agency make clear their expectations.

  Clearly the discovery, late in 2001, that a licence is required from January could seriously disrupt the service that we provide our customers. This would be particularly disruptive given that the January sale period is among the busiest times of the year for the sale, delivery and recovery of this type of product.


  The first stage of implementation of Regulation 2037/2000 has already had an impact on those sub-contractors who export refrigerated white goods for re-use. The UK's requirement to remove the CFCs from the compressors prior to export means that a number of countries which previously imported such fridges for refurbishment and re-use no longer find it economic to do so as they would have to be "re-gassed" in the importing country to make them useable. As second-hand fridges can still be obtained from other countries with the compressor CFCs intact these sources are now being used in place of the UK.

  The second stage, which requires the extraction and treatment of CFCs in foam, is likely to have a greater impact. Again, there has been little guidance on this issue despite the looming implementation date.

  At present there is no facility in the UK to recover and treat foam containing CFCs. It is now unlikely that such a facility could be created before the implementation date for the regulation in January 2002.


  Our fear is that the combined impact of these two regulations could undermine the viability of recovering and recycling white goods. If electrical retailers were forced to withdraw this service local authorities would inherit a responsibility for which they presently have little or no provision.

  Looking ahead, it is hard to foresee how these controls would facilitate the implementation of legislation on Waste Electrical and Electronic Equipment.

  Finally, we would urge a cross agency and department approach to these issues. At present it appears that the impact of legislation affecting this waste stream is not being examined as a whole but rather by a series of different directorates within DEFRA and other departments in isolation.

  We would, therefore, welcome an early dialogue between those currently involved in managing this waste stream and Government and subsequent guidance from your Department on implementation of these regulations.

previous page contents next page

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

© Parliamentary copyright 2002
Prepared 18 April 2002