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


Memorandum submitted by the British Soft Drinks Association (BSDA)

  The British Soft Drinks Association is the national trade association representing the interests of the UK's manufacturers, factors and franchisors of soft drinks. Member companies make up over 90 per cent of the industry, supplying still and carbonated drinks, fruit juices and bottled waters with annual consumer sales in excess on £7.8 billion.


  Although the use of CFC's as a blowing agent in insulating foams ceased in 1994 (with the use of HCFC's continuing for several years after), BSDA members own over 400,000 pieces of affected equipment currently in the marketplace. They comprise mainly display refrigerators, vending machines and soft drinks dispensing systems, installed in a diverse range of outlets from garage forecourts and corner shops to cinemas and public houses. BSDA members are incurring the costs and disruption caused through the misunderstanding, misinterpretation and poor consultation by Government of EC Regulation 2037/2000.


  The lack of forewarning and information to industry has resulted in member companies being unable to budget for future waste disposal costs. Some reprocessors are still unable to provide costs for the disposal of implicated plant. This hampers business planning and puts additional burdens on UK industry, which is still unsure as to the total cost of compliance. This also raises questions as to the economics of refurbishing equipment and may impact on the purchase of new plant.

  Members only discovered the full implications of the Regulation by word of mouth, when some companies were denied access to waste reprocessing facilities in September 2001. This was a clear oversight by Government department in identifying those industries affected by the Regulations.

  The first discussion forum open to owners of commercial/industrial equipment took place between DEFRA/DTI and affected parties in November 2001, some 13 months after implementation of the Regulations for commercial equipment.

  BSDA members are concerned about Government's failure to understand the implications of the Directive on commercial users of refrigeration equipment.

  Over a year after the Regulations came into force, there still exist no reprocessing facilities in the UK, forcing industry to bear otherwise avoidable costs for the storage of waste equipment.

  Recent developments have demonstrated a lack of coordination within Government. This led to the Environment Agency not being present at both commercial/industrial user meetings last year, delaying information important for industry planning. With a UK reprocessing standard (such as the German RAL standard) still not approved by Government, there will undoubtedly be further delays in addressing the much publicised 'mountain' of spent equipment awaiting disposal.

  There appeared to be confused communication between DEFRA, the Environment Agency and Local Authorities. This led to inconsistent guidance being offered by the Environment Agency and Local Authorities on important storage and handling issues.


  The soft drinks industry supports measures to protect the environment where appropriate. However Government clearly agreed to a Regulation in Brussels without a full understanding of the issues. An inadequate consultation process has left industry to absorb excessive costs and devote valuable resources to an otherwise preventable fiasco.

  BSDA will be seeking to set up meetings with the relevant parties on a regular basis, and helping to ensure that Government Departments are better briefed when assessing the impact of draft EU Regulations and those whom it affects. Earlier involvement of industry in the consultation process may have led to this unwelcome situation being avoided.

British Soft Drinks Association

22 February 2002

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