Memorandum by Charles Trent Ltd
Aylesbury Auto Salvage Ltd, Aylesbury, Car Transplants
Ltd, Nantwich, Charles Trent Ltd, Poole, Charlton Recycled Autoparts
Ltd, Cambridge, DA Autoparts Ltd, Dumfries, Delmo Services Ltd,
Wigan, Doncaster Motor Spares Ltd, Doncaster, Gowing Auto Salvage
Ltd, Newmarket, G W & G. Bridges Ltd, Crawley, Mitchell Car
Dismantling Ltd, Cheltenham, North East Motor Salvage Ltd, Sunderland,
Overton Garage Ltd, Aberdeen, Simpson Bros. Ltd, York, Tan-y-groes
Car Dismantlers Ltd, Cardigan, TL Harvey Ltd, Birmingham, Willingham
Car Spares Ltd, Hull, Universal Salvage Ltd.
In the absence of a more detailed breakdown
of what specifically you are examining, we have assumed that you
will be considering the impact of the ELV Directive (ELVD) upon:
car manufacturers, car component and material suppliers, car dismantlers,
car shredders, metal recycling sites and the public/consumer.
Although we understand that each of the appropriate
Trade Associations will be making individual representations,
and we are indeed members of two of them, we do not feel that
our views will be taken into proper consideration by these bodies
(for reasons outlined later). We would, therefore, like to take
this opportunity to make our own views, in respect to some of
the above points, quite clear.
At this stage we are unable to make in depth
analyses of the full economic implications of the three different
scenarios presented in the consultation document. Indeed we have
assumed that this Select Committee is not a substitute for official
responses to the consultation document and consequently have specifically
avoided many of the issues that will be dealt with in our own
official response to that particular document. The car manufacturers
will, I am sure, already have their own viewsthey are certainly
much better acquainted with the PRN system, as they are obligated
As we are not aware of the background of the
members of this committee we have taken the liberty of providing
some information, which may prove useful/interesting. In order
to make your task easier (and reading this report slightly less
onerous), we have split this paper into eight main sections.
|BVSF||British Vehicle Salvage Federation
|CARE||Consortium for Automotive Recycling
|ELV||End of Life Vehicle
|ELVD||End of Life Vehicles Directive
|MVDA||Motor Vehicle Dismantler's Association
|MRS||Metal Recycling Sites
|SRS||Secondary Restraint Systems
1. WHO IS
In terms of the number of ELVs processed annually Charles
Trent Ltd. is perhaps the fourth largest vehicle dismantler in
the UK. The largest is currently G W & G Bridge (of Pease
Pottage, about 12,000 ELVs), followed by Albert Looms Ltd, (of
Derby, 10,000 ELVs) and Universal Salvage plc (about 7,000 ELVs).
However, we are different from most of the other large ELV recyclers
in that we do not buy/sell repairable insurance category C and
D vehicles. This is the main income source for these businesses,
and generally subsidises the rest of the business. We process
only insurance category A and B vehicles, as well as ELVs from
the general public, motor trade, and abandoned vehicles under
local government authority disposal contracts. We do not sell
complete vehicles (of whatever category) at all. We currently
process about 6,000 ELVs every year for their spare parts. We
have one main processing facility in Poole (Dorset) with retail
facilities on site, and three additional "satellite"
retail shops in Southampton, Exeter and Dorchester. Up until June
of this year we also had a "ultra-modern" ELV processing
facility near Exeter, as well as a further retail depot in Plymouth.
The reasons for their closure are discussed later.
Our Poole facility is of about five acres, 95 per cent of
which is covered by an impermeable concrete surface, and has been
operating on the same site for 77 years. Charles Trent Ltd is
still a family business.
Our website (www.trents.co.uk) can provide a more detailed
picture of our business. There is also a considerable amount of
information available about the ELV recycling industry in general.
2. BACKGROUND TO
In general, when a vehicle reaches the end of its useful
life, by whatever means (accident damage, fire, flood, major mechanical/structural
failure etc) it passes from the last owner into the hands of either
a vehicle dismantler, a scrap yard or a shredder. The vehicle
may either be collected by a dismantler/scrap yard or delivered
to the appropriate premises by the last owner, depending upon
the particular conditions (inc. price) agreed.
It is vitally important to differentiate between the roles
of the vehicle dismantler, scrap yard and shredder. The prime
business of a vehicle dismantler is to sell used parts and then
pass (sell) the remainder of the vehicle to a scrap yard (or direct
to a shredder); that of a scrap yard is to deal in bulk quantities
of commodity metals, maximising profitability by separating the
different metal types. An ELV is often densified (eg flattened,
for logistical reasons) by the dismantler and scrapyard prior
to transport to a scrap yard.
The shredder is the final stage in the destruction of a vehicle.
Here the ELV is fed into a giant "mincing machine" that
tears it into small fragments. Very powerful shredders can destroy
200 ELVs/hour. The ferrous metal fragments are then separated
out using powerful electromagnets, and the relatively light non-metallic
materials (such as plastic, foam, textiles etc) are "sucked"
off by a powerful vacuum (and sent to landfill). The remainder,
the non-ferrous metals (such as aluminium and copper etc) are
then recovered at a Dense Media Plant. The shredding industry
can typically recover more than 90 per cent of the metal from
an ELV entering its facilities. It is worth noting that, in contrast
to the vehicle dismantling and scrapyard sectors, the shredding
industry is relatively youngthe UK's first shredder wasn't
operational until the early 1970s.
Until relatively recently (within the last twelve months
or so) very few vehicles were thought to pass directly into the
hands of the shredder operators. However, the arrival of the ELVD
prompted some research and revealed that perhaps up to 40 per
cent of the ELVs arriving at shredder sites had not undergone
any processing at all (inc. depollution). This very high proportion
is partly due to the fact that shredder operators also own "feeder
sites"a national network of "tied" scrapyards.
In effect, this makes the largest shredder operators the largest
handlers of undepolluted ELVs in the UK. Strangely enough, none
of the shredder sites (and many of the traditional scrap yards)
have ever had to depollute vehicles. This is in marked contrast
to vehicle dismantlers (although not uniformly through out the
dismantling industry). Precisely how this major inconsistency
has managed to persist for so long is remarkable.
The ELV processing industry has always been highly fragmented.
The vast majority of companies are family owned, typically employ
less than five people and operate from small premises. Historically,
the industry has been based primarily upon the recovery and sale
of reusable spare parts from scrap vehicles, along with the sale
of commodity scrap metal. A large proportion of the industry (in
terms of businesses handling ELVs, rather than the number of ELVs)
continues to operate on a cash-in-hand basis often from very small
industrial units or household garages. This is the least regulated
sector and is the source of the enormous "black market"
in spare parts (many of which are thought to be stolen). In relatively
recent times, driven by insurance company disposal contracts,
larger more professional vehicle dismantling operations have developed.
However, nearly all remain family owned.
Although there is currently much debate about the prominence
of abandoned vehicles, the best available data suggests that of
the 1.8 million or so ELVs that arise every year in the UK, perhaps
about 120,000 are illegally abandoned. Whilst this is, in itself
a very large number (entailing significant costs for local government
authorities and hence law abiding council tax payers) it must
be borne in mind that the other 1.68 million do enter the disposal
system through conventional means. In the other words, over 90
percent are taken into the system by the last owner.
The number of businesses involved in ELV disposal is a subject
of considerable debate. One would have thought, in view of the
fact that there is a legal requirement to regulate this industry,
that the Environment Agency (EA) would be able to provide comprehensive
and reliable statistics. However, this seems not to be the case.
Despite numerous requests by the car manufacturers and the CARE
group (Consortium for Automotive Recyclinga co-operative
research venture formed as a response to the ELV Directive in
1995 between the car manufacturers, vehicle dismantlers and shredders),
no data has been forthcoming. Only very recently was the CARE
group able to obtain some fragmentary data about England and Wales
and even this did not originate via "official channels".
On top of this the figures used in the UK Governments August 10
Consultation document are hopelessly inaccurate.
The EA categorise licensed metal recycling sites (MRS) as
either vehicle dismantlers (category A19) or mixed MRS (category
A20). The latter do handle ELVs but also general scrap metal (eg.
white goods, construction waste, civic amenity site arisings etc.)
There are apparently about 1800 licensed MRSs (785 category A19
sites, and 1005 category A20 sites). On top of this there are
about 1700 Waste Management License Exempt MRSs, although no data
is available as to whether these handle ELVs (and if so how many)
or not. The EA estimate that a further 8-10 percent of sites remain
Research by the used parts location service Find-A-Part (on
the basis of the number of companies that advertise in Yellow
Pages and local newspapers) suggests there may be up to 4500 companies
that sell spare parts from ELVs. This obviously excludes bulk
commodity metal recycling sites like shredders and scrap yards.
3. REGULATION OF
The motor vehicle dismantling and scrap metal recycling industries
are regulated under the Scrap Metal Dealers Act 1964, The Environmental
Protection Act 1990 (Part II), The Waste Management Licensing
Regulations 1994 etc. Compliance with legislation is (supposedly)
monitored and enforced by the Environment Agency.
Despite the introduction of much environmental legislation
in the last 20 years or so, the regulation of the waste industry
seems to have evolved almost on an "ad hoc" basis over
the years. Even the metal recycling industry effectively has at
least four tiers of regulation: unregulated, three different types
of Waste Management License (pre-1994, 1994-98, post-1998 Library
of License Conditions), License Exempt. One could be forgiven
for thinking that as the licensing system was updated over the
years, the licenses (and operating conditions) for existing facilities
would also be updated. But this appears not be (uniformly) the
case. For example, Charles Trent Ltd. has been operating continuously
on the same site in Poole for 77 years and has the very latest
type of license. Many other dismantlers less than ten years old,
however, have the pre-1994 or pre-1998 types. Sadly, successive
Governments have singulary failed to fundamentally overhaul the
regulatory system. Perhaps the most worrying aspect of this is
that indications are the ELVD will be implemented in the UK by
further additions to the existing fragmented system, creating
another tier of complexity. It seems that the opportunity, afforded
by the implementation of the ELVD, to comprehensively overhaul
the system is to be wasted yet again.
Furthermore, due to the fact that the Government has left
framing this legislation so late (we have, after all, been aware
of this legislation for almost 10 years), we are now deeply concerned
(for many practical reasons, such as shortfalls in ELV handling
capacity and increased incidence of abandoned vehicles) that there
will be blanket authorisation/"permitting" of all/most
existing sites. On the basis of EA performance to date it may
prove difficult to upgrade the standards of the industries once
authorisation is granted (one only need consider the difficulties
the EA has had in enforcing the existing regulations). The net
results will be that, yet again, professional businesses will
The role of the EA in regulating the metal recycling industry
has been much criticised, although it must be said that this also
seems to apply to much of the rest of the waste industry. The
fault cannot be laid entirely at the door of the EA. The EA simply
has not been given the resources it needs to accomplish the task.
Furthermore, we have been told (unofficially) that there will
be no extra resources available to the EA to implement and enforce
the ELVD). The waste industry (including the metal recycling industry)
has also vehemently opposed all attempts at regulation. The reason
for this is entirely understandable. For generations the wealth
that this industry generated was enormous but effectively invisibleit
operated strictly on a cash-in-hand basis (and at the fringes
much of it still does). Regulation obviously means much tighter
control and greater financial accountability.
The function of the EA has also not been assisted by the
fact that its role seems to be regarded as of low priority. It's
staff appear poorly trained, paid and motivated, with little practical
experience in the industries they are regulating, producing entirely
predictable results. There also seems to be remarkably little
formal dialogue between the EA and the industries concerned (certainly
the vehicle dismantling industry); even internally, the EA appear
to have problems of communication. A typical example of the poor
communication between the EA and industry is the 1998 EA clampdown
of unregulated metal recycling sites. Although the launch of the
campaign was surrounded by much publicity, including advertisements
in the recycling "press" and presentations at various
meeting (eg the BVSF annual general meeting in April 1998) no
interim or final reports were forthcoming. Indeed, evidence "on
the ground" suggested that little was actually accomplished
in environmental terms (we know of many such sites that continue
to flourish). Apparently the view was taken that it was better
to adopt the "softly-softly" approach and issue paperwork,
than actually demand that these business operate to the conditions
that they were supposed to. At the end of the campaign the EA
could claim that they had "captured" however many previously
unregulated operations. Never the less, this appears, by-and-large,
to have been a paper exercise. Indeed, we were recently informed
by a local EA officer that it wasn't their role to close non-compliant
sitesthey were to inform, educate and guide operators.
We are very seriously at odds with this approach. Many professional
companies such as ours made significant investments, prior to
the introduction of the Waste Management Licensing regime, to
ensure that we legally complied. If these other businesses still
haven't managed to reach the required standards seven years down
the line, what makes the EA/ Government think that anything will
change in the future?
In a similar way, we seriously question the validity of the
EA's system of measuring success in regulationthe number
of site visits performed. Shouldn't the emphasis be placed upon
the quality of the visit? The idea that an industry such as ours
can be regulated simply by one or two brief site visits annually
is alarming. In this respect, something that must not be overlooked
is the threat to EA officers of intimidation/physical abuse. Unfortunately,
the old image of car breakers/scrap yards still holds true in
many cases, especially at the fringes of the industry. Any threat
to this sectors lucrative livelihood will be met with a forceful
(and very possibly physical) response.
4. WHAT IS
THE ELV DIRECTIVE?
Charles Trent Ltd fully support the aims and objectives of
the Directive, and most of the means by which these are to be
achieved (as published in the official text dated October 2000).
Since we first became aware of this (at the time, potential)
legislation almost 10 years ago, we have been eagerly awaiting
the arrival of the ELVDfrom a business point of view because
we see tremendous opportunitiesbut also from an environmental
point of view because we actually put many of the Directives requirements
(such as impermeable surfaces, depollution equipment, computerisation
etc) in place many many years ago.
These statements may well come as something of a surprise,
coming as they do from a "car breaker". However, unlike
most vehicle dismantlers we do not have a "blinkered"
view of the ELVD and its impacts upon our business/industry alone.
We understand (at least some) of the implications for the environment,
the consumer, the car manufacturer, the dismantler and the metal
recycling industry as well as the implications and benefits (or
otherwise) of the various options/mechanisms required.
We believe the idea that a manufacturer (of any description)
should be able to make and sell a product without considering
the implications of its use and final disposal is lacking in any
vestige of corporate social responsibility. Car manufacturers
already consider in-use considerations of fuel consumption, exhaust
emissions etc and we see end of life disposal considerations merely
as an extension of this.
We believe that "producer responsibility" is ethically
and morally justifiable. However, we believe that such responsibility
should not be restricted to the producer alonecosts should
be shared with other sectors that handle vehicles (both public
and commerce/industry), in proportion to the benefit derived.
Many studies have indicated that the greatest impact of motor
vehicle lies in the "use" (as opposed to manufacture
and disposal) phase and as such the user (consumer) must have
some degree of responsibility towards eventual disposal. We think
producers should be predominantly liable but that users should
also contribute. However, we see no reason why the non-motoring
public should have to financially support the motorist (even though
it already does in other respects). For these reasons, we believe
there should be a disposal "fee" or "premium"
incorporated into the price of a new car. After all, we know that
£100 on the price of a £10,000 vehicle (ie 1 per cent)
will not make the slightest difference to the purchaser (for example,
the cost of having metallic paint on a car is typically over £500!)
The responsibility for ensuring that a vehicle, at the end of
its useful life, enters the "authorised" disposal route
must lie with the last owner. This means that there has to be
an effective incentive/disincentive for the last owner (something
that doesn't currently exist).
5. WHAT ARE
ELV DISPOSAL INDUSTRY(S)/TRADE
There are three main Trade Associations in the ELV recycling
sector. These are:
1. The Motor Vehicle Dismantlers Association (MVDA).
Founded in 1943, this supposedly represents the interests of vehicle
dismantlers. Of the estimated 4,000 businesses dismantling ELVs,
the MVDA has about 220 members. Most of the members are very small
businesses, many of which are Waste Management License Exempt.
Until recently there were few minimum standards for acceptance
of membership and this led to widespread contempt of the Association
within the upper eschelons of the ELV disposal industry. This
has been addressed, to some extent, within the last two years
by latest Chairman Mr John Hesketh and will (hopefully) be continued
by the new Chairperson (yet to be announced) and the new Secretary
Mr Duncan Wemys. However, the membership of the MVDA by no means
represents the lowest tier of vehicle dismantlersat least
they are regulated to some degree and have had enough foresight
to invest in their own Trade Association. We have been members
of the MVDA since at least 1956 and are closely associated with
perhaps a dozen or so of the most professional members. Never-the-less,
the Association argues strongly against the notion of big improvements
in the environmental performance of its memberson the basis
that it must be "all encompassing" in its views (ie
maintain standards at an absolute minimum). Although we and a
number of other companies have tried many times over the years,
we believe that the MVDA leadership should have been much more
proactive in the past in raising the standard of its membershipbetter
preparing the Industry and the Association for the arrival of
2. The British Vehicle Salvage Federation (BVSF). In
part, dissatisfaction with the MVDA led, in 1998, to the formation
of the BVSF by the larger insurance contracted agents. As this
type of business historically had little or no regulation at all,
the number of operators is unknown. However, there are suspected
to be literally hundreds of such companies. The BVSF currently
has about 75 members, and these (generally) represent the larger
more professional sector of the industry. Although the BVSF installed
much more rigorous checks upon prospective members, no attempt
was made to physically audit member's sites. The significance
of this is that it would almost certainly have led to the expulsion
of some members. Perversely, the BVSF (with some notable exceptions)
has taken a very similar line to the MVDA in fighting for absolutely
minimal improvements in site and operation standards, again simply
to protect members interests.
3. The British Metal Recycling Association (BMRA, formed
as a result of the merger of the British Metal Federation and
the British Secondary Metals Association in June 2001). The BMRA
is completely different from the previous two Associations and
represents the interests of the metal shredding and scrap metal
industrythat is companies that deal in commodity scrap
metals derived from ELVs (and other items such as white goods,
construction scrap etc). The number and range of members is unknown
to us. However, we do know that the BMRA is dominated by the two
largest metal shredding companies. Between them they have perhaps
60-80 per cent of the UK shredding and dense media plant capacity.
It is important to note that the shredder companies, although
regulated by the same Waste Management Licensing regime as vehicle
dismantlers, have never been required to remove any fluids, batteries
or tyres from the vehicles they process.
As is always the case, each of these three different Trade
Associations has slightly different views, representing as they
do different sectors of the ELV processing industry. Not surprisingly,
each also seeks to protect the interests of its members.
Charles Trent Ltd is a member of both the MVDA and BVSF.
We also work very closely with the BMRA. However, our own views
differ significantly from the official views of all three Associations.
In general, it is true to say that all three Associations have
fought long and hard both to resist the ELV Directive and the
views of the car manufacturers. Having said that there are a number
of companies within each Association that have very similar views
to our own.
From the above, it should be easy to understand why those
businesses that have striven to become increasingly professional
in their operation, have been continually thwarted and frustrated
by their own (and the other) Trade Associations. In a particularly
cruel twist of fate, the very Waste Management Licensing system
that was installed to achieve the much-needed improvements has,
in practice, served to penalise the professional operator.
Without being melodramatic, the uneven playing field created
by the inconsistent and inadequate regulatory system has probably
been the single biggest factor preventing companies making the
required investment; in the absence in improvements in enforcement
action (and in face of existing competition) it would simply be
financial suicide. Even some of the larger professional businesses
have held back from investment so far on this basis.
6. AT PRESENT,
UK ELV RECYCLING INDUSTRY
ELVD REQUIRED STANDARDS?
The areas of the ELVD with major implications for the ELV
disposal industry are predominantly located in Article 6 Annex
1 (Minimum Technical Requirements for Treatment in accordance
with Article 6).
Looking through the requirements of Annex 1, it becomes clear
that very few of the requirements are satisfied completely by
the existing ELV disposal industry. However, it must be emphasised
that it can be difficult to gauge compliance when even some of
the most fundamental definitions remain to be clarified.
Annex 1(1). Sites for storage prior to depollution
Very few businesses storing undepolluted ELVs have impermeable
surfaces. In the absence of clarification from Government/EA,
we assume impermeable surface equates to concrete. In most cases,
storage is on bear earth.
Annex 1(2). Sites for treatment
Many ELV disposal operations do have a small area of concrete
for ELV processing. However, in practice processing is not restricted
to these areas.
These areas are rarely serviced by appropriate drainage systems.
Many ELV disposal operations do not even bother to remove
batteries, and where they do, collection and storage is random
and inappropriate. For example, shredders do not routinely remove
batteries from ELVs at all. Many ELV processors that do remove
batteries store them outside in a pile on the bare earth open
to rain and dirt. We are only aware of one site where battery
electrolyte neutralisation procedure is in place.
In general, the only storage tanks for ELV-derived fluids
are for fuel and engine oil (because none of the other fluids
are routinely drained). However, in the vast majority of cases
these containers do not meet environmental or Health and Safety
requirements. In particular, petrol storage is highly problematic.
The argument that ELVs do not contain fuel is nonsense. Evidence
suggests that on average about five litres of fuel is recovered
from each ELV. This is normally drained by either siphoning out
through the fuel filler or by hammering a chisel through the petrol
tank and draining the fuel into a bucket. Fuel is then stored
in whatever container is close at hand. In view of the fact that
(we understand) it is illegal to store more than 15 litres overnight,
most of these businesses are operating illegally. Other oils may
be recovered if the vehicle is extensively dismantled (eg the
so-called premature pELVs from insurance contracts). Otherwise,
the fluids spill onto the ground when the vehicle is finally processed.
Annex 1(3). Treatment operations for depollution
As mentioned many do not actually recover batteries at all.
SRS (airbag and seat-belt pretensioner) components are not
currently deployed by any ELV processor. Although the number of
SRS components currently found in ELVs is low (they are restricted
to the pELVs), it is growing rapidly. By 2010 we expect the vast
majority of ELVs (inc. nELVs) to contain SRS components.
As mentioned very few ELV fluids are currently recovered.
There are perhaps just a few dozen companies in the UK that have
a formal depollution routine in place. In general, those oils
that are recovered are stored in the same container. No UK businesses
currently recover shock absorber fluid or remove mercury-containing
components, and virtually none brake fluid, coolant, windscreen
wash fluid, power steering fluid etc. These all simply fall onto
the ground when the vehicle is finally crushed.
It should be noted that, in contrast to some vehicle dismantlers,
virtually none of the scrap metal or shredding industry carry
out any of the above actions.
Annex 1(4). Treatment operations to promote recycling
Although catalysts are comparatively rare on ELVs these are
usually recovered because of their value either as functional
units or for scrap value (for the latter in the region of £8-£20/unit,
although this is subject to considerable market variation).
Most dismantlers and scrap yards do already make some attempt
to remove some non-ferrous metals, again simply due to their value.
The shredding industry discourage this because it reduces the
value of the ELVs to them (non-ferrous is metal much more valuable
than ferrous metal).
Many vehicle dismantlers (and the vast majority of scrap
yard and shredders) do not remove tyres from ELVs; these are usually
shredded along with the rest of the vehicle (and hence are ultimately
landfilled). There is not a single ELV processor in the UK that
removes any glass or plastic for material recycling (although
some may be removed for sale as replacement parts).
So, through this brief examination, we can see that many
aspects of the ELVD that apply to the ELV disposal industries
are not currently in place. Indeed our own view is that this will
not be achievable (in practice) within the next five years.
7. WHAT WILL
THE ELV PROCESSING
ELVD SPECIFIED STANDARDS?
Many of the economic implications of this Directive still
remain to be elucidated, as a result of delays in the interpretation
of crucial terms within the Directive text. Despite repeated requests
to the DTI, DETR (DEFRA) and the EA, some of these (such when
precisely does a car become an ELV, what is the definition of
an impermeable surface, what constitutes appropriate in relation
to areas of impermeable surfaces etc) have yet to be clarified.
With this in mind, we have to ask how on earth is industry expected
to make provisions for the Directive when guidance from the authorities
is so scarce?
In late 2000/early 2001, the CARE group performed an in-depth
analysis of the status of the UK ELV processing industries (with
respect to Article 6 Annex 1) and the potential costs associated
with achieving the Annex 1 standards. This six-month project capitalised
upon the considerable experience of the CARE members within the
ELV dismantling and shredding industries.
The CARE group devised a detailed audit protocol (based upon
a pre-existing Code of Practicewhich is currently being
updated and extended in co-operation with the Environment Agency)
for ELV processing sites (dismantling, scrap yard and shredding
sites), allocating scores and weighting to each of the questions
posed and answers given. A wide range of vehicle dismantling,
scrap yard and shredder sites were then visited and audited to
this protocol, and the results analysed. Table 1 provides some
characteristics of the various industry classes examined. This
led to the generation of a "traffic light" document
(see Table 2), with red areas denoting complete non-compliance,
amber where progress towards compliance was being made, and green
where there was pre-existing compliance. The results clearly illustrated
that none of the businesses included in the study were more than
75 per cent Annex 1 compliant (and some much less than this).