In its Waste Prevention Programme for England published last December the Government committed to providing clarification on the application of the definition of waste for re-use and repair activities. Defra is now seeking to clarify the application of the definition of waste for reuse and repair activities, by calling on stakeholder to give their opinions in order to examine our sector’s issues.
The Furniture Re-use Network welcomes the intention and opportunity to review the impact and the manner in which waste is defined and is interpreted in the case of reuse – this is something we have discussed with Government departments and the Environment Agencies since the turn of the century.
We’d suggest that the Government is right in having pointed out in the consultation that the barriers are more to do with interpretation rather than the legal definition of waste itself.
Craig Anderson, the CEO of FRN said “Reuse is primarily not about waste; it is about a product continuing to be used through a secondary consumer – it just so happens that sometimes the product was found in the UK waste stream”.
The end user has defined the product as either being waste or non-waste; that is what we have to work with, and that is how it should continue. The reuse sector that FRN represents has already jumped what we term the “hurdles” of the waste regulations and the sector complies with them – interpretation is critical not the change of regulatory requirements or definitions because they are perceived as “barriers”. If you change the definition you may open up the reuse market to a sham reusers and the illegal trade in what used to be waste.
FRN suggests that handling waste comes with a duty of care to ensure it is treated correctly and compliantly; reuse of waste or reuse of products follows and undergoes the same principle activities – treatment of this type of waste or product is checking, testing, repairing and assuring the product is fit for purpose and fit for reuse. The only difference is that if the product was waste, it is traceable as waste until it can be signed off and is ready for the shop floor again. A reputable reuser treats the product, whether it’s waste or not, in the same way - because they understand the product has a new market and those that understand that market want to protect it from bad practice.
Craig pointed out that “We are all for an easier life for our reuse sector, but at the same time we need to look at the risks of potentially hazardous products and hazardous waste being abused by disreputable organisations in the waste sector – we need better regulation not deregulation”.
In order to fully examine the issue Defra is asking for general feedback from stakeholders on specific examples and experiences where the definition of waste has acted as a barrier to re-use and repair activities – for FRN this was a hurdle not a show-stopper and we have already crossed that problem, what we need now is a consistent interpretation of these regulations across all stakeholders.