Currys plc EWCE0005
Written evidence submitted by Currys
Introduction to Currys
Currys is the UK’s largest retailer of technology products and services, helping everyone to enjoy amazing technology from over 300 stores across the UK, as well as online. We are committed to giving tech a longer life and encourage our customers to repair and reuse their electrical items as much as possible. When technology reaches the end of its life, we are there for our customers to help them dispose of it responsibly. We have been doing this successfully for decades, and have Europe’s largest repair centre in Newark, where we employ over 1,000 specialists. Given our leading position in the UK, where we handle around 44% of all retail WEEE (we are one of only three tech retailers who offers a recycling service), we are uniquely placed in helping the Government achieve its goals on WEEE. If all retailers were to offer a collection and recycling service at a similar level to Currys, the total volume of recycled WEEE goods would hit the current targets.
Submission
Below is a summary of Currys’ position on the latest proposals from DEFRA on improving the rates of WEEE recycling regulations.
Electronic waste is the world’s fastest growing waste stream and is expected to grow to nearly 75 million tonnes by 2030. Currys fully supports Defra’s mission to collect and safely handle more electronic waste, thereby reducing its harm to the environment. This is core to our business strategy.
We already operate a scaled and successful solution that meets the needs of our customers, the planet and is sustainable for our business. We’ve invested in building the UK’s most comprehensive retail, repair and recycling network. This facility gives tech longer life and retains its full value and use for as long as possible. We repair products for customers, we refurbish and resell or re-use products and we repurpose the parts from end-of-life products. To-date we have recycled over 1m tonnes of tech since 2010. This investment allows us to deliver services at scale. 12% of UK’s entire tech recycling is facilitated by Currys. We have over 300 e-waste drop off points, 1450 drivers collecting from customers’ homes, hundreds of vans bringing 2500 WEEE collections to Newark every day and 900,000 large appliance WEEE collections annually. Our approach confirms Currys as the number 1 WEEE retail recycler in the UK. 44% of retail WEEE is handled by Currys, with 59,000 tonnes of e-waste collected for re-use and recycling, or 1.6m items . We’ve also raised awareness of the e-waste issue through our marketing initiatives, recently unveiling our first-ever gaming experience ‘Trash Tycoon’ created in the popular game, Fortnite, to urge Gen Z to recycle tech responsibly.
However, Defra’s proposals put all of this at risk at our current scale. Our biggest concern is that Defra’s proposals penalise responsible businesses such as Currys. Our view is that if we are no longer able to charge for recycling, the cost of this service will make it more challenging for us to offer the same level of recycling output that we currently do. We believe an unintended consequence of these proposals would be to ‘level everyone down’ to a lesser standard. The best way to achieve meaningful change in society is to encourage innovation and competition from commercial organisations, coupled with support and appropriate frameworks from Government that help consumers to be more responsible..
In reviewing the proposals outlined in the consultation, we strongly disagree with the current proposal for the free collection of large appliance WEEE, which would take away the retail industry’s ability to cover the costs of providing this service without passing on additional costs to consumers. We firmly believe that this would be unfair to retailers like us who collect large appliance WEEE today and will ultimately lead to the unintended consequence of fewer collections in the UK, not more.
We do, however, support the small mixed WEEE proposals. We agree with bringing OMP’s into scope given the UK electricals industry is dominated by online only players representing two thirds of the industry, who sell the vast majority of small-box items. Based on available data, ten million white goods were sold in 2022. Almost three million of those products were sold by those who do not collect or recycle old units. One retailer alone represents 30% of the UK technology market yet offers no WEEE recycling. The same applies to online marketplaces and kitchen retailers. We also want retailers without stores to contribute more, with more collection points and better funding for household Local Authority collections. We also firmly believe in the importance of introducing effective and impactful marketing and communications for this to cut through with consumers.
While we support the principle of producer funding, we do so on a very limited basis, as it is important to restrict it to what is effective and necessary only. This minimises the level of the 'consumer tax' created and prevents wider and unnecessary costs being passed to the consumer. Producer funding should only be a consideration where it's the only viable way to address specific and evidenced issues.
Large, Bulky WEEE
From our discussions with Defra, the proposed method of removing our ability to charge for the collection of large, bulky WEEE and sharing the cost between producers and retailers will mean that both parties will have to inflate their prices, passing this cost on to all customers. This is bad for customers, bad for business and therefore, particularly in the current economic circumstances, something we should all strive to avoid.
The costs for providing our collection and recycling service are currently shared in an open and transparent way to customers so they know what they are paying for and can make an informed choice. By making recycling collection a free obligation without any method of funding it, the proposals turn a visible and discrete cost into an ‘invisible tax’ – the cost of which is borne by everyone:
In a nutshell, business will not be able to absorb the costs of free large appliance collection and handling and they will need to be passed on to consumers through increased prices. And because it is a cost (vs a commercial opportunity) companies will look to minimise or avoid it. In summary, we believe it will drive all the wrong behaviour.
It will be treated as an expense and an obligation by all the businesses involved, in effect a ‘bad’ cost and as with other such costs, management teams will be required to reduce this expense as much as possible. This is a real risk and represents a substantial own goal.
On the issue of fly-tipping the desired outcome of lowering unlawful dumping of large appliances by 10% in the UK is also not likely to be achieved with these proposals. We estimate that fly tipping is between 0.8 and 1.6% of total WEEE collection that is currently happening in the UK. This is 0.005% of the total UK large appliances sold.
We agree there is a real need to address fly tipping and reach those individuals who dump appliances. There could be a myriad of reasons for their illegal behaviour regardless, we would strongly argue that it cannot be the responsibility of the retail industry to provide solutions for criminal acts.
Small mixed WEEE: Decreasing the quantity of small mixed WEEE that gets in the residual waste stream
We are fully supportive of this element of the proposals including the idea of setting up a kerbside or customer home collection programme funded by producers - including online marketplaces. However, there is a genuine concern that a large amount of e-waste continues to be hoarded at home. Our research shows that only 10% of customers currently dispose of small mixed WEEE in the general waste, 20% do not trust kerbside programs to handle their devices and data, and 20% of customers would like their electronic waste to be re-used vs recycled.
Therefore, it’s important for all retailers to play a role in collecting and handling e-waste so we do support the increase of appropriate collection points within retailers. All retailers should participate and do their part, preferably supporting solutions that enable re-use as well as recycling. If retailers cannot offer a collection point system, because, for example, it’s too operationally complex or they do not have any stores, we recommend that they provide 1:1 collection upon delivery or find another mechanism for collection, for example, through lockers and partnership with other store operators. They could also join the household kerbside scheme and help with both the promotion and operation of the scheme. But all retailers of small mixed WEEE must do something to make it easier and address the practical barriers that affect customer behaviour today.
We’d also like to draw your attention to an article that our CEO Alex Baldock wrote on this matter, which first appeared in The Times newspaper on February 5th, please see it below.
Make recycling electricals free and we all will pay the price
A government proposal that retailers can no longer be allowed to charge to take away old electrical appliances sounds great, but it is not what it seems.
When something that used to cost money is now free, what’s not to like? On the face of it, a new government proposal that retailers can no longer be allowed to charge to take away old electrical appliances sounds great, all the more so when it’s to help the planet, as well as people’s pockets.
For sure, the proposal targets a real problem. The UK consistently misses its waste recycling targets. Who wouldn’t support more recycling? We at Currys certainly do.
Great objective, then, but there’s a problem. The proposal won’t work. It will lead to less recycling, not more, and it’ll mean higher costs for consumers and more burden for business.
Yawn, a dull tale of old fridges, I hear you say — but before you turn the page, there’s something bigger at stake here. This is about business’s role in society, about how government can harness the private sector to social ends.
Is this simply a smokescreen for a retailer to wriggle out of doing the right thing? Hardly. At Currys, we’re happy to repair and recycle millions of old fridges, laptops, mobile phones and televisions. We account for nearly half of all retail technology recycling in the UK and have built Europe’s largest electricals repair centre in Nottinghamshire.
Customers seem to like the service we provide. It’s big and growing. They pay a small fee for us to take away their old kit, knowing that it’ll be dealt with responsibly. If customers don’t want to pay us, they can use another provider or pay their council to take it away. But it’s not an easy service to provide. It takes investment and know-how in vans, trucks, people and facilities. That’s why it’s not free.
Businesses aren’t charities. We have to provide a service that’s good enough that customers will pay for it. We have to treat colleagues well enough to want to work for us. We have to pay the taxes that fund schools, hospitals and aircraft carriers. And there has to be enough left over for shareholders. Everyone must get their share, or none of it works.
This is an especially fine balance for already-overburdened retailers that, on a good day, might make £3 of profit for every £100 we sell (compared with £15 profit for a utility, for example), retailers that already account for 10 per cent of all business taxation despite being 5 per cent of the economy.
Government wants to harness business for social ends. We love it. But we can’t do it for free. Making an adequate profit is our licence to invest in even more recycling and repairs. Instead, these proposals give an incentive to good businesses to do the bare minimum, to do less recycling. If you load extra costs on to retailers, we’ll have to pass them on to customers. Don’t penalise us (and competitors such as AO) for having invested in recycling; instead, tackle those (such as Amazon) that don’t offer the service at all, that merely sell products and forget about them.
The prime minister knows all this. He’s been to see our repair and recycling centre for himself and lavished our colleagues with praise for their sterling work in building a business that benefits customers’ pockets and the planet. The problem is the gap between what the government says and what is actually happening.
There is a better way. Government needs to go with the grain of business in dangling the carrot of tax incentives to do more recycling. And, by all means, set retailers recycling obligations and targets, with penalties for those that miss them — the stick. That’ll ensure that everyone has to pull their weight.
Business can be a powerful force for good, purpose and profit can go hand-in-hand, but that’s achieved by harnessing business to social ends, by incentivising the social outcomes we seek, not by penalising businesses doing the right thing, not by meddling in matters best left to individual consumers and businesses and not by pretending that anything comes for free.
April 2024