Select Committee on Trade and Industry Appendices to the Minutes of Evidence


APPENDIX 11

Memorandum by Charles Trent Ltd

PRESENTED BY CHARLES TRENT LTD, ON BEHALF OF:

  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.

INTRODUCTION

  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 views—they are certainly much better acquainted with the PRN system, as they are obligated companies.

  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.

ABBREVIATIONS

BVSFBritish Vehicle Salvage Federation
CAREConsortium for Automotive Recycling
EAEnvironment Agency
ELVEnd of Life Vehicle
ELVDEnd of Life Vehicles Directive
EUEuropean Union
MVDAMotor Vehicle Dismantler's Association
nELVnatural ELV
pELVpremature ELV
MRSMetal Recycling Sites
SRSSecondary Restraint Systems


1.  WHO IS CHARLES TRENT LTD?

  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 THE CAR DISPOSAL INDUSTRIES: DISMANTLERS, SCRAP YARDS, SHREDDERS

  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 young—the 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 Recycling—a 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 unregulated.

  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 CAR DISPOSAL INDUSTRY AND THE ROLE OF THE ENVIRONMENT AGENCY

  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 be disadvantaged.

  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 invisible—it 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 sites—they 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 regulation—the 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 CHARLES TRENT LTD'S VIEW ABOUT 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 ELVD—from a business point of view because we see tremendous opportunities—but 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 alone—costs 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 THE VIEWS OF THE ELV DISPOSAL INDUSTRY(S)/TRADE ASSOCIATIONS?

  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 dismantlers—at 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 members—on 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 membership—better preparing the Industry and the Association for the arrival of the Directive.

  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 industry—that 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, HOW CLOSE IS THE UK ELV RECYCLING INDUSTRY TO THE 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 IT COST THE ELV PROCESSING INDUSTRY TO ATTAIN THE 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 Practice—which 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).





 
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