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Select Committee on Science and Technology Minutes of Evidence


Examination of Witnesses (Questions 20-39)

Mr Neil Thornton, Mr Tony Pedrotti and Dr David Evans

27 NOVEMBER 2007

  Q20  Chairman: This was in May of this year. Has the unit been set up yet?

  Mr Thornton: Yes, it has. It works in my area of the department. On products and materials people are working hard on things like roadmaps and they are also looking hard at the priority waste materials that were referred to in the Waste Strategy. Again, one cannot think of these materials separately from the products. You cannot think of aluminium separately from window frames and soft drink cans; you cannot think of waste wood without thinking of furniture. You have to think the thing through. Yes, it is in place and we are looking forward to what they are going to say.

  Q21  Baroness Sharp of Guildford: We have been talking a lot about these various Directives but how does all this fit in with the Pollution Prevention and Control Regulations? What do those involve and who is bound by them? In your written evidence, you say that these regulations require measures to be taken to minimise the production of waste. What are these measures and how, again, do they fit in with what we have just been talking about?

  Mr Thornton: The Pollution Prevention and Control regime is a regime which exists in the UK but which, at the top end, is also consistent with the European Integrated Prevention Pollution and Control regime. Essentially, it is site based; so we are looking at the implications of manufacturing sites or sites where services are provided, like drycleaners, for example, to take the other extreme. The Environment Agency for the larger sites and local authorities for the smaller ones are seeking to minimise the environmental impacts of these sites. For the big sites, the big manufacturing sites, including petro-chemical plants and power stations and large landfill sites, we are concerned about all the environmental impacts—so emissions to air, water and soil/land. For the smaller, part B sites as they are called, the regime only covers impacts to air—so, for example, dry cleaning solvent, as you would imagine, is a potential environmental ill. In each case, the great thing about these regulations is that they are self-adjusting because the obligation on the regulated site is to use something called best available technique (BAT). The Environment Agency, let us take them as an example, would discuss with the site owner—and this would start at the design stage—what would be an appropriate level of emission, level of waste generation on site, for this kind of production process at this stage of the art. Further down the track, a new plant coming in five years later would have higher standards, because the best available technique, which in some cases is defined by the European publications, moves ahead, so you do not have to re-regulate the site. It is basically site based, emission based.

  Q22  Baroness Sharp of Guildford: And monitored by—

  Mr Thornton: And monitored by the Environment Agency or, as the case may be, the local authority.

  Q23  Baroness Sharp of Guildford: From the evidence we have received, this suggests that there is a lack of consistent data on life-cycle impacts of most products and materials. Given this lack of information, how can the data be generated in order to measure waste minimisation?

  Mr Thornton: You are right, there is lack of data, and, as I think I implied earlier, there is an almost infinite capability for information if you think of everything in the economy. Something called the Market Transformation Programme is a programme generating information about the performance of products and their lifecycle behaviour, designed by us and funded by us, to put information into the public domain about how products perform—notably energy-using products, but not solely—and what kind of trajectory of improved performance the technology and the way markets are going might look like generating over the coming years. That is very much intended to inform not just Government but the business community. That programme is quite widely used and is seen as an exemplar, I think, of good practice in the UK. Again, we are seeking to generate generics, information that others can use. If you are a major retailer or a major food manufacturer, you will want to know the performance of your own product and you have far more capability to do that than we have, so we would want to influence the business to want to know and then provide them with techniques, including, for example, carbon footprinting techniques, to help them generate information and improved performance for themselves.

  Q24  Chairman: Do you share this information with your European partners?

  Mr Thornton: Yes, we do. Indeed, the kind of work that the Market Transformation Programme has been doing goes wider than that. I forget the name of the institute but they host the way in which standards are being generated following up sustainable consumption and production at the world level. So we are seeking to inform, and that is an area where, I think, the UK is seen as performing well.

  Q25  Chairman: Maybe you could send us a note on that.

  Mr Thornton: We could certainly do that.

  Q26  Lord Lewis of Newnham: I am rather cynical of the whole concept of the carbon footprint approach. I realise it is a very important aspect in trying to assess the viability of certain processes and things of this particular nature, but it is so variable and so open to an element of subjectivity in interpretation. One only has to think of the whole situation over disposable nappies. That has been going on, to my knowledge, for 25 years, and every year you get a different answer. In our papers here we have now been told that you are reassessing this particular problem and we are going to get another answer out in December. I do not wish to be too cynical on this but it strikes me that the ground rules are not at all clear and, in point of fact, a given commodity can vary quite significantly depending upon the assumptions that are made; for instance, in transportation and things of this particular nature. How effective do you believe this is going to be? I am in the dilemma of believing that what you are doing is right but I am equally in the dilemma of thinking it is an impossible task to answer.

  Mr Thornton: I certainly share with you the mild frustration at the various answers we have had on nappies. Maybe that can be taken in a positive way as showing that actually there is not a blindingly obvious answer in that particular area, so maybe that is not an area where we should all spend much of our time. The roadmap approach, attempting to identify the significant environmental impact of particular product types. Let us take milk, for example, you establish some interesting things, such as, for example, that a very high proportion of the environmental impact is arising right at the front end of the chain, on farms and in the intensive systems that are generating the feeds and the fertilisers and so on. It might not have struck one immediately when thinking about it that that is where the main impacts are. You are quite right: any individual life-cycle analysis is terribly sensitive to its boundary conditions and the set of assumptions people are making. We are seeking to work with the business community and economists and the academic community to get better methodologies out there. Carbon footprinting, for example; the British Standards Institute and the Carbon Trust are leading work, with our very strong support in the background, in trying to generate some methodologies that people can use with some reliability and some confidence.

  Q27  Lord Lewis of Newnham: In your written evidence you say that vehicle manufacturers are now required to re-use, recycle and even recover 85 per cent of the weight of their end-of-life vehicles and in the WEEE Regulations they are also required to finance the costs of collection of electrical products according to the weight of their products. I can understand the concept of weight, particularly in the case of motorcars because that corresponds to the energy you are going to use in manufacturing them, but is the development of lighter products therefore the best way to reduce waste? I am slightly concerned about that because I think, in general terms, it tends to point towards the use of plastics very often rather than metals and things of this particular sort. When it comes to recycling processes, plastics really are not very effective as a form of medium for recycling.

  Mr Pedrotti: The easy answer is no. It is not a case of weight being the be-all and end-all. On End of Life Vehicles, the reason why it is written in regarding the weight was that we already knew that about 75 per cent of the weight in the car was recovered immediately because of the metal content, but nothing else was happening. So in relation to any of the fluids, the plastics, it was just: "Well, that's gone. We'll just keep the metal, thank you very much." We agreed at the European level that that was not the best way of tackling the residual. Obviously the motor manufacturers and, indeed, the electronic equipment manufacturers are conscious of the way the public are reacting, so, if you are talking about energy efficiency from a vehicle point of view, one of the important things is obviously engine capacity but also the weight of the vehicle, but then there are safety considerations: you could make an incredibly light car, but as soon as you were to have a small bump it would disintegrate. There are all these challenges from a design point of view. Indeed, the recovery percentage on the ELVs is going to rise from 85 per cent to 95 per cent, which pushes, at the start, thinking about what they are putting in that vehicle, how it would be recycled, to try to challenge them to look to see if they could find markets for that residual product and not just say, "Oh, it's plastic, oops." Again on the weight of electrical equipment, the reason it is done on weight—and I know one of your questions touches on IPR—is because IPR is not that easy and so you have gone for the weight ratio. We did not want to have a system where I put 10 products on the market, so does he, mine are tiny, his are huge, and we are treated the same. The underlying principle obviously is to start thinking about the environmental impact of that product. Weight, at this moment in time, is the aspect we are driving the manufacturers to start thinking about. But the easy answer is not: Drive down the weight and you will have the environmental benefit at the end result. There is a lot more to it.

  Q28  Lord Lewis of Newnham: The Japanese are one of our major car manufacturers. How do we go about influencing them? They are extremely sensitive manufacturers to environmental conditions, I realise that, but do you have any Directives?

  Mr Pedrotti: Regarding that specific piece of legislation, we engage with all the motor vehicle manufacturers. We have very good relationships with vehicle manufacturers from wherever they come. Whether they are Japanese, American or European, the interesting thing is the engagement level. In a previous existence I had the benefit of going around with various ministers and visiting some of the plants. They showed a willingness to share their experience and how they were doing things for their vehicles, either from a design point of view or to show where their production side was stripping out waste and, shall we say, the indigenous market in the UK was not. They were quite willing to share that. The story went that when the minister asked why they were so comfortable to share that information the answer came, "You're British, you won't do it." Now, because of the work the department has done with the vehicle manufacturers, that is changing all the way through the supply chain. In the end result you get better product and much more efficiency and productivity out of it, but also the waste, particularly on the production side, is much, much, much reduced before you have even finished with the main product.

  Dr Evans: You have to recognise that the treatment at the end of life is only one aspect of the desirability of any given product, so the regulations we have just been talking about are to make sure that if manufacturers put things on the European market, whoever they are and from wherever they come, whether they are Japanese, European or American, they have to have thought about the end of life as well as all the other things that make for a desirable product. Of course, in relation to vehicles, there has been a big drive, through the taxation system and all sorts of other things, to make people more conscious of the environmental impact as they drive, through the effect in terms of carbon dioxide. That is another way in which you can influence good, so to speak, environmental performance, but, once the car has been put on the market, you cannot do anything about the recoverability if they have put the wrong kind of plastics in at the outset. There is nothing you can do as a user to do anything about that. You have to get to the manufacturers at the outset, to try to get them to think about these things before they put goods on the market.

  Q29  Lord Haskel: There are of course conflicts here. As you have been pointing out, the lighter the car the less fuel it uses yet the more difficult it may be to dispose of it at the end of life. Somehow we have to bring all these things together. Is this the purpose of the technology platforms that you have mentioned? Is this what the Technology Strategy Board does? Somebody has to bring all this together. Do you leave it to the market to make a judgment or do you try to make a judgment?

  Mr Thornton: Our overall approach to a more sustainable economy, sustainable products, sustainable consumption, is very much to motivate the other players in the economy to provide them with information or techniques or methodologies that they can adopt. Sometimes we use rather heavier hands and we regulate them and we put economic instruments in place as well, but our approach is to try to get an economy that gets a virtuous circle running rather than a vicious circle, because we can see the consumer is "getting" all of this and is taking an interest. That is coming through in marketing terms to the manufacturers: the manufacturers see their corporate social responsibilities and carry out the plans. On a good day, one can feel that some of this can add up, but, you are absolutely right, there are some things that we have to put on the ground and the Technology Strategy Board is one of them.

  Dr Evans: The important thing to remember about the Technology Strategy Board is that we set it up to be of benefit to business. We did not set it up to deliver some of these regulatory objectives; we have other ways of delivering regulatory objectives. The reality is that we will only make change to the things that we use in society if we as consumers want to buy them. Manufacturers put in the market place things that are attractive to us. That is the place where we hope the Technology Strategy Board can operate, so that it can create incentives by supporting R&D, giving grants for R&D or providing support for technology transfer, to get the capability side, the scientists, engineers, technologists who have the opportunities in their minds but not yet in the products, into real products in the market place which will both meet the needs and expectations of consumers and be better for the environment. I do not think we can operate that in a command and control way. We can try to make sure the incentives are clear for successful businesses to invest themselves in the kinds of things that will go in the right direction. Technology support is one part. Another, which was emphasised again by the Commission on Environmental Markets and Economic Performance last week, is that of setting a long-term perspective for the environmental standards. Therefore, going back to the case of vehicles, creating at European level a clarity and confidence about the level of carbon emissions which will be acceptable in the year 2020, which will create an incentive so that then we can bring the plastics manufacturers, the vehicle manufacturers, the battery manufacturers, the component manufacturers, you name it, together to create the market to create vehicles which are attractive to consumers but which also perform better.

  Q30  Lord Crickhowell: A major change, I believe, in market practice over the last 20, 30, 40 years is that it has become almost impossible, economically, at any rate, to have anything repaired. If you have a minor breakdown in your domestic appliance, you are promptly told that the cost of repairing it will be more than the cost to buy a new product. That seems to be waste creating, to me. Are any of these regulations likely to have any impact on the cost to the manufacturers so that it is made as it used to be, so that, if your fridge broke down and even your camera, you would not be told, "There is no point in mending it because the charge is going to be enormous, much better to buy a new one"?

  Mr Thornton: I said earlier on that to some extent we do have to work with the market that is out there. There is no point in us travelling back to some different relationship between consumers and their time preference and manufacturers and so on. On the other hand, of course, you are absolutely right, the last thing we want is to encourage more of a throwaway society if that looks like having environmental disbenefits. The regulations we have been discussing quite a bit this morning, the Waste, Electrical and Electronic Equipment Regulations, do indeed make it much more expensive to the manufacturer of white goods if they are thrown away at the end of their lives, and therefore the cost of waste disposal, that economic calculation, changes—and of course it has the benefit, if they do end up in waste, that we recover as much as we possibly can, in terms of reuse or in terms of remanufacture or in terms of the materials. So it is not just having an economic impact, we are trying to close the loop of the materials as well. I think there is some influence—some.

  Q31  Baroness Platt of Writtle: One does get the feeling, as a customer, that there is built-in obsolescence, that the item you have is going to be put out of date. That is extremely difficult to control, and I would not suggest you did, but, on the other hand, I can quite see that tax is a good measure, and the fact that the manufacturer has to get rid of the old product, but it is a temptation, is it not?

  Mr Thornton: Yes. Perhaps the area we have not talked very much about is also consumer attitudes. We are seeking to generate a consumer economy of citizenry who care as much as we do about the environment; that is, saying it is important to them and they will look to us to try to generate the policies that will help. We are doing a lot of work and we will be publishing work over the coming months on what does motivate different types of consumer at different points in their own lives, what their attitudes are to products and materials and the environment and so on. There are clearly some consumers who do feel that it is all a bit too fast, it is all too wasteful, who would like to hang on to products longer, and we are very keen to encourage that, but we also have to live with the fact that some are wanting to change fast and for them we need to encapsulate the price in that fast-moving product and we need to capture the materials and the products at the end of life as best we can.

  Q32  Chairman: In this armoury of weapons you have—and you use expressions like "incentives motivate designers"—could you point to instruments which are anything other than minimum standard hurdles or the kind of thing that would motivate the least-cost way of passing muster? It seems that you are very cautious. You know that carrots do not always work but you are not really very clear about which sticks you ought to be using to get to where you want to be.

  Mr Thornton: I think that is perhaps a little unkind. Let us take an example from the Commission on Environmental Markets' report last week. They are very keen that when Government sets standards for products, supposing we have all formed the view that there needs to be a standard for a product, that we at least set standards at levels that take account of the scope for innovation on the way to that date—so that we do not just build standards in five years' time that meet today's capabilities but that we take account of the fact that the world will move on. They are also very keen that Government should in public procurement set some challenging forward procurement commitments, so that the public sector can share the risk with the developer, as it were, saying, "We are going to want this kind of product some way off, in the medium-term, five years, and if you can deliver to this kind of standard we give you a guaranteed market." We are being encouraged to be more enthusiastic. We are working with those who have aspirations for a much better society—and obviously we work very closely with the green groups, the third sector—sharing their ambitions. We have a limited number of interventions that people are prepared to put up with us making but we are very keen to see more ambition generated in the economy. The more consumers come along with the story the more we can move ahead. Regulation is bound to be a balance between the impacts of the regulation and the intervention and the environmental benefits, but we are pushing the environmental benefits way up the order. I do not think you would have found these three departments five years ago quite as much in harmony in front of you—at least, appearing to be—as you do today because there is seen to be a mutual environmental benefit in eco-innovation, in products that respect the environment.

  Q33  Chairman: The implication in that response is that the ambition of the green groups, as you refer to them, are not really shared by the widget makers. The question really is how you get the aspirations of the green groups to become the accepted standards of the widget maker. I am not quite sure how you are doing this. If these guys do not really respond to the moral high ground because they are too busy dealing with the other regulations that come through.

  Mr Pedrotti: Obviously you have the tool, whether it is an economic instrument or legislative, but my area also covers corporate social responsibility and we have seen a change. Where a widget manufacturer sits there and says, "I don't care about the environment; all I am caring about is making my widgets and making a profit" you are starting to see business consumer buyers/purchasers or general public consumers stop buying that widget because they can start seeing the impact it is having and say, "I would rather buy it from this company because they do care about the environment." For the biggest companies, rather than the very, very small one, they know this in huge amounts now. You can think of a number of high-profile, negative publicity regarding, shall we say, manufacturers who are not using either environmentally sound approaches or socially ethical approaches, and, once this becomes public knowledge, you see a huge impact on their company's profits and the amount that people will sell. This is permeating down. It is not a case of small companies not engaged in it. My department, through the corporate social responsibility activities, is trying to encourage many more UK companies to open their eyes to this. It is not sledge-hammer tactics. We have to encourage them to go beyond regulatory minimum standards. At an international level, we are again working with BSI. There were around 350 delegates representing various different stakeholders at a meeting in Vienna recently trying to develop a corporate social responsibility standard, a global standard rather than just for the UK. The interest is there. As Neil said earlier, five years ago that interest possibly was not. I am quite encouraged that we are moving in the right direction.

  Q34  Baroness Sharp of Guildford: It seems to me that you are right in terms of saying that the consumer is a very big lever here. I also think that consumers are extremely receptive to these ideas. You only have to look at what is happening to plastic bags in supermarkets to see how quickly the consumer moves on something like this. Coming back to the point Lady Platt made about products these days not being reusable—the throwing-away society that we have—as I understand it, if, for example, we need a new toaster, which you can buy for something like £10 or £20—they are extremely cheap these days—we are not encouraged to take the old one along and give it to the sales outlet for recycling. I think they are now put into a special pot at the recycling tip with the local authority but would it not encourage the manufacturers if in fact the retail outlet had the responsibility for taking them in? Then, if they were repairable on the spot, these things could be done there.

  Mr Pedrotti: Under the WEEE Regulations retailers have two approaches. If you place electronic equipment on the market, you have either to become a member of what is called the Distributor Take-Back Scheme—which is the retail industry saying, "We don't want that approach. We don't want people bringing their toasters back to us, thank you very much. We do not know what to do with it or how to handle that amount of waste" in which case the Distributor Take-Back Scheme has put together a funding package to support local authorities so that retailers can say, "We don't take it back at this store but if you go to your civic amenity site, they will take it back"—or there are other retailers who are saying, "We are going to do that. We will collect it from your doorstep if we are delivering you a large domestic product and take the other one away or you can bring that toaster back." The idea that they would then repair it for you and hand it back, I doubt. But they will take that and sell you another toaster, thank you very much—and a telly and anything else while you are in there.

  Q35  Lord Howie of Troon: You mentioned working with green groups earlier on. I confess that made me feel slightly uneasy. By their nature, the people in green groups tend to be enthusiasts and just now and again they suffer from tunnel vision. I wonder just how cautious you are in dealing with them and even how sceptical you are.

  Mr Thornton: Our job obviously is to work with the whole of society to try to reach societal results that make people on balance feel better about the outcome. That means we have to talk to hardnosed manufacturers and we have to talk to people with a stronger environmental bent than even we in Defra have. That is rich and right, I think. We have to be open and sceptical to every opinion, including, I hasten to say, our own. I think the key thing is to make sure we get them all in the room. David has referred, in relation to, I think, the Knowledge Transfer Networks and the technology platforms, to the fact that getting everybody in the room together can be very healthy, even if only to see what they say to each other. We do not have a special set of approaches to any particular sub-set of the economy, but, if we are going to do the right thing by the environment, it will be very odd if we were not listening to those who have the strongest environmental instincts. We will always be sure that the regulatory reform end of my colleague's department will keep an eye on us not overdoing it and will make sure that we do reach a balanced result at the end of the day.

  Q36  Lord Crickhowell: Up to now we have been dealing mainly with regulation and exhortation, but this is a Science Committee so I come now to brief references that have been made to innovation. Are we being held back at all by the lack of use of available technologies and available materials? What is being done and what can be done to make sure that designers, manufacturers and everyone have got the latest technologies and we really are in the forefront of the use of such technologies?

  Dr Evans: I am sure that as a very general proposition the answer to your question must be yes, that we are both not creating nor using as much new technology as we should in order to be successful in UK business both in reducing waste but also in terms of economic performance. Then you have to ask what the Government is doing to try to improve that. At one level you go back to the big investment that the Government makes in the core science and technology capability of the country through sustaining universities' laboratories, through training lots of people who go through them, but then you look at the specific activities we have been doing under the Technology Programme, which was with DTI but is now the responsibility of my Department, Innovation, Universities and Skills. Most of these activities are delivered through the new Technology Strategy Board which came into existence in July this year and they can be thought of under two broad group headings. First, support for collaborations in R&D grants to companies to collaborate with other companies or universities or other technology institutes. We have had a number of competitions over the last three years which have been directly related to improving the waste and environmental performance generally of British business, and I can go through them if you want to. That is the first category. The second category is we promote Knowledge Transfer Networks which, as their name implies, bring together those who are knowledgeable about technologies with potential users. There are three specific Knowledge Transfer Networks relevant in this particular area. There is the Integrated Pollution Management Knowledge Transfer Network, the Materials Knowledge Transfer Network and the Resource Efficiency Knowledge Transfer Network.

  Lord Lewis of Newnham: Could I return to WEEE or do you want to continue?

  Chairman: Sorry, were you going to ask anything else, Lord Crickhowell?

  Lord Crickhowell: No. I think it would be very useful to have those details spelt out for us and the evidence behind it.

  Q37  Lord Lewis of Newnham: This refers to something you have already covered. Basically we are talking about the RoHS Regulation which is really concerned with hazardous waste involved with WEEE type equipment. As you rightly pointed out, one of your problems is that so many of these present gadgets are coming from all over the world and to know what the composition of some of them is must be quite a problem for you. Presumably if it contains things like chromium VI or mercury, things of this nature, you then have to dispose of it in a hazardous waste site rather than putting it into a normal landfill or processing it in the other ways that you should do it. How do you go about doing this? Presumably you have a blacklist of things that are undesirable. If you take so many of these electronic things, are they all analysed for the potential hazardous waste components in them?

  Mr Pedrotti: I will answer the second point. The way we went about this was as soon as that Directive was being negotiated regarding the tolerance levels, regarding certain substances, mercury for argument's sake, the action that my colleague, Steve Andrews, took was to go out of, shall we say, the Whitehall area and start talking to electronic manufacturers in the UK and then Europe, bringing together people in Europe and asking, "How is this actually going to affect your business? What are you going to start thinking about doing?" Then he went to the Far East and China. If you had read the press before the regulations came in, we were going to hit this cataclysmic, "no-one can sell any electronic products because there is not anything that is compliant", but that did not happen, primarily because we had taken steps to make sure that those manufacturers wherever they came from were aware of these new regulations and had time to adapt their practices so that they did not keep putting products on the market beyond the point where that Directive and the regulations kicked in. Our enforcement body, the National Weights and Measures Laboratory, will take products and test them to see whether they are above those tolerance levels. I can give more detail if you want. So far they have not found huge amounts of non-compliant products. I would argue the work we have done has enabled us to get to a position where people are complying.

  Q38  Lord Lewis of Newnham: We have the classical example, do we not, if I remember correctly, that if you are to take a printer with a cartridge, if you are to put the cartridge into your waste bin that would be hazardous waste but if you leave it within the printer and put the printer in the waste bin it would no longer be classified as hazardous waste.

  Mr Pedrotti: The Hazardous Waste Regulations, and the joys of, I have not got that much experience on. We did have an issue about what components were classed as hazardous, whether it was a printer, battery, et cetera. The main thing for me regarding RoHS and WEEE and its relationship with the Hazardous Waste Regulations is we have got to work with the manufacturers at the point that they are designing and thinking about designing their products so that we mitigate as much as possible the environmental impact. I am not too sure on the hazardous waste side.

  Mr Thornton: Just on hazardous waste, the specific example you cite I am not familiar with the answer to, but if you wanted me to look into it I could certainly do that. As a general principle, there is the so-called "duty of care" on somebody who is holding a material which is about to become waste and to dispose of it in accordance with the regulations. The Environment Agency would look extremely sharply at any business that was mis-describing or showing ignorance of the materials that it was disposing of in a business situation and the obligation is on them to know whether they have or have not got hazardous wastes and to handle them appropriately and, as you rightly say, dispose of them to a facility or a waste management contractor who is competent to handle hazardous wastes. In relation to our own households, wastes are not usually regarded as hazardous as they pass from us into the system. They are treated as hazardous once they reach somewhere where they can be sensibly handled by a local authority, so, for example, a civic amenity site. I think it is there in the definitions and it is a matter of good sense because householders cannot sensibly deal separately with different materials. We are seeking to encourage and educate householders about the major kinds of materials, like paints, batteries and so on, where it really would be much better practice if they were to separate them out from their black bag without actually criminalising them if they were to fail to do so.

  Q39  Lord Lewis of Newnham: I sympathise totally with your approach, and I am sure that is the right way to be dealing with it, but if we just refer back to an earlier point which also illustrates where I have difficulties. You were talking in your WEEE Directive about the fact that you have delegated to local authority the central point for collection but I live in Cambridge and if I want to get rid of something I have got to get in a motorcar and go to the outskirts of Cambridge in order to deposit this thing. It is much easier to open the bin and shove it in.

  Mr Thornton: It is the case that some local authorities—


 
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