DoE PROJECT 10B WATER ECONOMY Report 11727/5
Report No DWI0709/5
SUMMARY AND RECOMMENDATIONS
A programme of twenty four personal interviews and three telephone interviews was carried out with key personnel in different sectors of the UK sanitary ware industry, to assess the potential impact on the industry of relaxing regulatory requirements.
Two main issues emerged which centred around reduction of flushing volumes and the introduction of discharge valves.
It was generally agreed that prospective changes to regulatory requirements from those in the byelaws would open up the UK market for foreign importers, especially of products with push button discharge valves. However the extent to which this would be so varied with the type of respondent. Thus, manufacturers considered that the market would be "flooded with cheap imports," whereas distributors and importers tended to see the change as more a continuous trickle rather than a flood. In fact it appears that products from abroad are already entering the WC market and will continue to do so, despite our "local" product differences, such as the prohibition of the discharge valve.
Most of the bathroom industry report that they are in any case currently experiencing great difficulties achieving reasonable profits, fighting, as they are, a continuous price battle.
BSRIA's conclusions are that it will therefore be better for the industry to make a change sooner and with good warning, while the opportunities still exist to compete successfully at home and overseas, rather than to leave it too late. Thus, although m anufacturers claim that prospective changes to regulatory requirements would result in significant commercial costs for them (which appear to be the main grounds for objecting to them), alternative marketing strategies could turn these perceived threats from abroad into opportunities. This is so especially given that excluding foreign products, through regulation, is by no means guaranteed to halt the threat, but is likely only to slow it down somewhat. Those that would suffer most from letting discharge valves into the UK would be Thomas Dudley (and to a lesser extent Derwent Macdee). Thomas Dudley in particular depend for much of their business, on discharge valves being excluded so that they can provide a service for importers, advising them how best to adapt their product to a British market.
Reduction of flushing volumes would seem to incur rather more costs on the part of the manufacturers than would allowing discharge valves into the UK. Pans need to be redesigned and manufactured better, in order to flush effectively with syphons at lower volumes. BSRIA however believes it is possible to do so, judging from experience of foreign products flushing on less water. However there is evidence that the major UK suppliers are still working on getting their 71/2 litre designs right and, while they remain less than adequate, more water is often used as systems are flushed twice.
Because of the costs to manufacturers in redesigning pans and seats (which is more costly than redesigning cisterns for discharge valves), BSRIA recommends that the DoE communicate any final required maximum volume at the outset, of any changes revised, rather than introducing reductions piece meal, where possible. It would minimise the costs of any redesign work, if changes can be made all at once.
Possible suggestions for DoE to adopt when making changes to the regulatory requirements are: