You are on page 1of 16

Cost impact of WEEE evidence trading

Project Report for Hewlett Packard by 360 Environmental

1.Executive summary
a. The current UK WEEE market works within a system of opaqueness whereby those that pay the price of compliance generally have very little idea of the actual costs, the infrastructure involved and the margins that are extracted by that infrastructure. b. This paper has analysed that market based on information supplied by a range of participants, most of who contributed on the basis of commercial confidentiality. c. The paper has looked initially at the impact of ransom price profiteering in 2007 and then at the cost to producers of the current evidence system. d. The key findings are that: i. Whilst excessive ransom pricing is seen as the primary cost issue, of much greater significance for producers has been the wider disconnect between the market for evidence compared to the actual cost of collection, treatment and recycling of household WEEE. ii. Producers are paying a price for evidence that has remained relatively consistent over the last three years despite increased collection and treatment efficiencies and rising commodity values. iii. This price now relates primarily to perceived trading values rather than actual costs. iv. Commodity values and excess treatment capacity have driven down the cost of processing WEEE over the last three years to a point where the net cost of collecting and treating WEEE has become better than cost neutral. v. Producer Compliance Schemes (PCS) have increasingly moved towards dependence on the collection point waste management operators to manage household WEEE at a fixed cost. vi. The benefit of reduced cost by waste management operators has not been passed back to PCSs and producers. vii. Local Authorities generally now leave it to their DCF waste management operators to manage their PCS contracts. viii.Current measures by the Environment Agency to tighten contractual trading positions between PCSs are likely to inhibit sharp price increases for evidence, but are also likely to protect the current high costs of evidence.

1.Glossary
a. PCS Producer Compliance Scheme b. DCF Designated Collection Facility UK infrastructure of free collection points for consumers, usually Local Authority Civic Amenity Sites. c. AATF Approved Authorised Treatment Facility d. AE Approved Exporter e. LA Local Authority f. LDA Large Domestic Appliances g. GDL Gas discharge lamps

1.Background

a. The implementation of the WEEE Directive in the UK in 2007 was achieved following extensive debate between Government Departments and industry over the most cost effective way to achieve the key requirements of the Directive: Adequate infrastructure of free disposal for end users Collection rate of at least 4kgs per head Financing of all collected household WEEE by producers a. The system that emerged required producers to take responsibility for the financing of collection, treatment and recycling of all household WEEE on a collective basis through a market share approach. b. This required producers to join PCSs which would be required to demonstrate that they had evidence of their market share of collection and treatment of WEEE by contracting with Local Authorities for the management of WEEE at DCFs. All household WEEE collected would require evidence of treatment and recycling to be issued by AATFs. c. The expectation was that PCSs would look after the interests of their members by taking physical control over the collection of WEEE and driving down cost. However, by requiring all evidence to be purchased and by enabling PCSs to take on more WEEE than they needed for their own obligations, the Government opened up the potential for profiteering. d. One scheme in particular, saw the opportunities for over-collection and entered into an agreement with a large waste management operator to gain access to surplus evidence that could then be sold at a price the was significantly above the cost of collection and treatment. e. Although robustly challenged by other schemes, the legal requirements of the Regulations forced acceptance of this position which has since led to the market price for evidence dictated by trading values rather than actual cost. f. A status quo has emerged that now sees the majority of evidence provided to PCSs though arrangements agreed with the waste management companies that operate the DCFs. The price they will charge for evidence tends to reflect the perception of the market position and the opportunity to create margins rather than the reality of cost. g. The UK system relies on last minute trading to balance obligations. The requirement to buy what is available has led to instances of excessive profiteering for these final trades as the holders of spare evidence know that someone somewhere has to purchase. An attempt by the UK Environment Agency to control this profiteering through the need for pre-agreed contracts to cover surpluses and shortfalls has helped to limit the ransom extremes. But these measures do not apply any controls to general pricing and the differentials between cost and price continue to flourish

1.Project aim
a. The purpose of this project was to estimate the cost impact on producers of the UK market share mechanism and project this forward under a potential recast scenario. 1.

UK WEEE evidence costs

a. The cost of evidence is made up of a number of elements: Haulage costs from DCFs to AATFs including the costs of containers AATF gate fees/value The perceived market price for evidence a. The difference between the charge made to producers for evidence and the actual costs in generating it is generally split between a number of participants: 2

The waste management companies that operate collection facilities The PCSs The Local Authorities The AATFs a. There appears to be little sign of a direct relationship between evidence costs and gate fees. b. The graph below shows the change in the representative amount charged (or paid) by AATFs for WEEE received over a weighbridge. These are known as the gate fees/values.

Fig.1 Average payments or charges made by AATFs for WEEE c. Haulage costs have stayed relatively stable over the period with increased fuel costs being offset by increased efficiency.

Fig.2 Average value of WEEE to collectors taking account of AATF and transport charges

d. The combination of gate fees/value and logistics costs are the net costs/values for those that collect the WEEE at DCFs. e. Therefore the cost of evidence should show similar decreases to the increased value/decreased gate fees. Clearly, this has not occurred. f. The graph below shows the cost comparison between these prices and the charges for evidence where nv is the net value or cost of the material taking into account collection costs and gate fees/values.

Fig.3 Showing the difference between the cost of generating evidence and the charge made for evidence for each WEEE category/group. g. Overall, this produces a /tonne differential as shown below.

Fig.4 Value extracted by the disposal/compliance chain taking account of the costs and revenues shown in Fig.3

1.Cost estimates for 2007


a. Taking the total tonnage of WEEE collected in 2007 from published EA data, a calculation has been made of the total cost to industry for evidence based on average prices that were being charged by PCSs based on their own costs and the cost of trading, but excluding the extreme costs. 4

b. A calculation has then been made applying the extreme costs at the time across the full tonnage. c. It is estimated that ransom pricing might have accounted for 10% of the tonnage in 2007. A calculation has therefore been applied assuming that 10% has been charged to producers at extreme prices. d. Appendix 1 shows the table of estimated costs derived from supplied data. e. These indicate that for 2007, the following applies: Average cost for collection and treatment across all categories 73/tonne Average cost for evidence at normal market rates - 118/tonne Average cost for evidence at extreme prices - 182/tonne Average cost for evidence assuming 10% at extreme prices - 136/tonne

1.Cost estimates for later years


a. The impact of extreme pricing was particularly felt in 2007 and 2008. In later years, the general dynamics of the market have changed to the extent that they have less impact. There is less traded evidence with a higher proportion collected by those that need it. The requirement for contracted agreements between PCSs, whilst not generally being price specific, has dampened excessive pricing. Those that initially imposed the extreme prices have been less aggressive in their attitude. More profit is probably being extracted at market prices for evidence. a. However, it is clear that those with the highest surplus do still try and trade at prices approximately 25% higher than the normal market position. The prices below are known trading requests made by one compliance PCS in 2011 for 2010 compliance.
LDA Market price PCS A Increase 15 20 33.3% Cooling 140 180 28.6% Displays 240 300 25.0% Mixed 135 170 25.9%

Fig.5 Comparison of evidence pricing b. The prices provided by producers have demonstrated that there has been little change in the amount that PCSs charge their members. c. As there is no market indicator mechanism, producers have no means of comparing their prices. This is exacerbated by the different methods of charging - some PCSs opt for a market share price and others charge on the basis of EEE placed on the market. The range of prices provided by producers on request indicates a general consistency of average price across the PCSs although with some significant variation each year between the PCSs. The table below shows the range of prices received.

2007 Large Household Appliances Sm Household Appliances all IT and Telecom Equipm s ent Consum Equipm er ent Lighting Equipm ent Electrical and Electronic Tools Toys Leisure and Sports Medical Devices Monitoring and Control Automatic Dispensers Display Equipm ent Cooling Appliances Gas Discharge Lam ps 217 119 153-183 152 95 111-216 5-15 115 93-147 73-140

2008 10-20 140 88 102-132

2009 12 122-157 60-90 70-186 123

2010 12-15 120-133 92-151 61-124 110-151 86-151 95-180 110

160 95

143 95

225

225 103 2506

225 179

Fig.6 Range of evidence prices charged by Compliance Schemes from producer survey d. Trading between PCSs generally takes place at a perceived market level on the basis that whatever the evidence has cost to produce, a PCS does not want to lose out on potential revenue by trading at a lower price. Evidence has tended to be traded at the following prices across all the years that the WEEE Regulations have been operating: LDA - 15-20 Cooling - 140-180 Mixed - 100-140 Displays - 220-300 a. Reuse value has increased as a proportion of the extracted value since the Regulations began. A value for 10/item has been included for cooling, LDA and displays with an overall value of 300/tonne for small WEEE. b. For 2010 collected volumes, this would suggest that, assuming the average gates fees/values and transport costs shown in para 5e are applied across the UK and there is no reason to believe that these should not be the underlying positions then a net margin of approximately 57m was achieved as the sum of: Total value of evidence charges made to producers Total value paid by AATFs for household WEEE received (or gate fee charged) Total value paid for WEEE sent for reuse The cost of haulage from collection points to treatment and reuse facilities

Fig.7 Estimated make up of revenues and costs for 2010 WEEE showing net value extracted a. Overall, it shows that in 2010, the combined value of material and reuse was positive with a speculated figure of 8m. This compares with a negative figure based on the same criteria, but adjusted for average material net values of 12m, a swing in one year of approximately 20m.
Av. Collection cost per tonne -40 -85 -40 -80

Gate fees/values LDA Cooling Displays Mixed

2007 110 0 -125 15

2008 135 10 -94 34

2009 95 0 -106 26

2010 160 15 -38 46

2011 175 20 -22 91

Fig.8 Treatment facility gate fees/values and collection costs used to calculate overall revenues

1.Margin
a. As discussed in 5. above, the management of WEEE under the Regulations has lprovides different margin opportunities for each sector. s. b. AATFs The AATF sector has significant over-capacity in the UK and is therefore being tightly squeezed. Suppliers are well aware of commodity fluctuations and expect to benefit from any increase in values. Some AATFs are therefore seeking alternative ways to gain additional margin and there is evidence that there are some working with waste management companies to manage a Local Authoritys WEEE for that company and then to split the additional value they get by selling the evidence. For example, in one authority, the AATF was selling cooling evidence to the PCS that had the arrangement with the Local Authority at 160/tonne where it only cost 80/tonne to collect and treat the material. The 80 7

a.

a.

a.

a.

margin was then split with the waste management company contracted by the LA to manage their CA sites. Local Authorities Pre-WEEE, local authority CA site contracts included a charge for cooling and display equipment while their contractors kept the value of the scrap metal. Many local authorities were and some still are required to compensate their waste management contractor for the lost revenue related to LDA and it is known that some PCSs allow the LA to keep the net value of the LDA, effectively getting their LDA evidence at zero cost. It is not known what proportion of the WEEE margin goes to LAs, but it is safe to assume that most of it goes to the waste management contractors. Those LAs contacted indicated that as far as they were concerned, there was no additional revenue or cost of WEEE. Waste management contractors This is the sector that appears to be benefitting the most from WEEE revenues. In most cases, local authorities devolve the contractual arrangements for WEEE to the WM company which then contracts with the PCSs. In some cases, the PCSs do manage the collection arrangements, either paying the WM company for haulage and the AATF, the gate fee. But in increasingly, the WM company will agree a price for the evidence with their contracted PCS and manage all the costs and revenues. Discussions with CA site operators indicated that there are now no additional site costs associated with the management of WEEE. Waste management contracts are also still receiving other revenue, in some cases from LAs. As an example, one Local Authority has a contract negotiated with their waste management company in 2007 that includes a handling fee per item of LDA, cooling and Display, ranging between 2.07 - 2.50 and for mixed WEEE, 25-51.65/tonne. The LA receives no value for the WEEE and the annual charge made by the WM company takes no account of this. The WM Company then have a contract with a PCS who pay them an agreed amount per tonne of evidence. PCSs There are three basic types of PCS: Not for profit. These will work on a cost plus basis for their members, but generally have the highest overheads. They also manage most of the non-WM PCS sites. Waste management/larger company owned PCSs who will look to optimise profits either through member fees or through evidence charges where they manage CA sites Others generally PCSs that rely on purchasing evidence from other PCSs. Therefore, the PCSs take up a large proportion of the remaining margin either through high overheads or through additional profit. Calculating the proportion that goes to each is impossible, but it could be estimated using the following assumptions: 70% of DCFs collections and treatment are managed by waste management companies. 30% are run by Compliance PCSs. Net material revenue tends to be retained by whoever runs the sites although some may be shared with Local authorities as part of the overall contract price. An assumption is the WMCs keep 95% whilst LAs get 5%. Where WMCs control collection and disposal, 70% of the evidence value goes to them, 20% is added by the PCSs and 10% is shared by WMCs with AATF operators.

Where PCSs control collection and disposal, it is assumed that they retain 100% of the value of evidence. b. Using the total net revenues from para 7i, it is therefore estimated that the split would be as follows where: LA is local Authorities AATF is treatment facilities CS other is PCSs that do not run collection and treatment CS DCF is PCSs that do run collection and treatment WMC is waste management companies

Fig.9 Estimated of how the net margin has been split between sectors

1.Cost impact based on growth models


a. To consider the potential impact of the various cost scenarios on the amount of WEEE required to meet the likely targets, the tonnage required to meet the targets and the likely costs of collecting and treating that WEEE must be calculated. b. The following has been assumed: That a 65%target on EEE placed on the market is the most likely scenario for the recast. That these percentages will be applied to each category group ie LDA, Cooling, Displays, Mixed and GDL. GDL has been excluded from the totals as the majority of these costs are picked up through the lighting industry levy system. That the level of EEE placed onto the market will stay at 2010 levels. It is recognised that this is unlikely, but it is impossible to speculate on the likely changes. That the % proportion of B2B and B2C will remain at 2010 levels. a. The growth in costs must be considered against two factors: The actual cost of collection The costs charged to producers for collection a. To model the potential growth requirements, the targets have therefore been applied to each category group on a linear basis to 2016. b. However, given that displays are currently declining from figures over 100%, it has been assumed that the percentage rate will continue to fall. c. To simplify the process, 2010 EEE levels have been used as the basis for the targets going though to 2020. The graph below shows the figures for 2008-2010, but there will be a number of factors that will make this difficult to predict. 9

Economic conditions Technology developments Human nature

Fig.10 Reported data for EEE placed onto UK market 2008-2010 a. The calculations have therefore assumed a flat level of EEE supply through to 2020. This might seem unreasonable for displays which are showing a consistent decline. But the percentage collection rate for those has been growing at a rapid rate of 20% per year and the potential decline in supply is therefore offset by assuming a decline in percentage collection rates. Cooling also sits above 50% but it is fair to assume that this should continue to rise and a 65% assumption has been included for 2016. b. Given that the collection targets are likely to be applied to all EEE including nonhousehold, the cost model has used a discounted percentage rate for household WEEE that applies a reduction on the same proportion as currently occurs. Again, this may seem unreasonable as it is possible that the amount of collected B2B that is recorded could rise at a more rapid rate, but this will be difficult to predict. c. The rates of collection target growth on total WEEE are therefore proposed as follows:
LDA Cooling Displays Mixed GDL Total 2010 28.56% 50.15% 100.18% 14.82% 29.33% 2011 34.64% 52.62% 99.32% 23.19% 35.28% 2012 40.71% 55.10% 98.45% 31.55% 41.22% 2013 46.78% 57.57% 97.59% 39.91% 47.17% 2014 52.85% 60.05% 96.73% 48.27% 53.11% 2015 58.93% 62.52% 95.86% 56.64% 59.06% 2016 65% 65% 95% 65% 65% 68%

Fig.11 Straight line growth rates used to calculate costs through to 2016 a.

1.Cost assumptions
a. Costs have been calculated on the basis of current cost plus the predicted cost of achieving the necessary growth to achieve the targets. 10

b. For LDA, it is assumed that sufficient is being collected and that there is no additional cost related to growth as this will come from either protocols of improved enforcement. The graph in para 9c shows the potential for profiteering from evidence values applied across the full tonnages required to meet the targets. c. For Displays, it is assumed that there should be no additional cost as the level of display collection currently exceeds the 2020 targets. Indeed, it is expected that cost should reduce due to the declining weight of collected displays. d. For Cooling, there should also be no additional cost to achieve the target as the hazardous nature of this category should mean that all available items are collected anyway. e. It is only for Mixed that there is likely to be the additional costs associated with meeting the targets. f. Research has been conducted within the Local Authority sector to estimate the costs of extending recycling collections to include small WEEE. g. The universal response has been that for LAs, WEEE is simply not an issue and certainly not a priority collection stream. Their view is that any expansion of WEEE collections would be funded by Compliance PCSs through their refuse collection contractor. h. Likewise with CA site operations, there are no perceived incremental costs for Local Authorities for WEEE separation and management on site. There are, however, historical commercial relationships between LAs and their CA site management contractors that are reflected in current revenue flows although it is not possible to estimate the scale of these. i. These are highly significant as anecdotally, they suggest that in most cases, the operator retains the revenue as part of their overall commercial position with the LA. j. The general view is that effectively, LDA evidence will therefore always be at best, Free of Charge to PCSs where they secure their evidence through waste management companies. k. A recent small WEEE collection trial in Lincolnshire demonstrated that volumes from that type of process are likely to be low and unlikely to lead to significant growth.

1.Predicted growth costs


a. To predict growth costs, the model has considered two scenarios the charge for evidence and actual costs. b. It is assumed that the targets will be applied to the total amount of EEE placed on the market without differentiating between B2B and B2C. It is therefore assumed that the evidence cost will be applied to the total collected tonnage although a cost line has been shown where B2B would be assumed to be zero cost and evidence would only be charged on B2C. c. The costs are based on a split of 10% reuse and 90% recycling through to 2016. It is recognised that this is an unlikely scenario as the inclusion of B2B will see a far higher reuse element, especially for IT equipment. d. It must also be recognised that it has been assumed that the target system will start in 2011 which clearly it is not. As it is unknown when the Government would impose incremental targets under the recast requirements, this is just used to build estimated costs for 2016. e. The graph below is modelled as follows: Total charge assumes that the cost of evidence remains constant and is applied to all of the tonnage (including B2B) against the growth model needed to meet 65% by 2020. 11

Total cost a. assumes that the current net costs for each type of WEEE are applied to the total tonnage at the assumed growth rates. This reduces due to the sharp growth required for LDA. Total cost b. assumes that incremental mixed WEEE growth will only be achieved through high cost extraction and therefore adds 100/tonne to the cost of collecting Mixed WEEE over and above 2010 levels. High assumes that all evidence will be charged at the current extreme trading levels. Extreme assumes that all evidence will be charged at 2007 extreme trading levels. Costs per tonne are assumed as follows:
Evidence charge to producers Low High Extreme 15 20 20 140 180 190 230 200 340 120 170 220 Net WEEE cost a. b. -120 -120 70 70 78 78 34 150

LDA Cooling Displays Mixed

Fig.13 Costs used for Fig 14 predictive graph

Fig.14 Predictions of potential costs increases versus WEEE costs/values d. This shows the extreme positions that may emerge for 2016 if there is a shortfall. It must also be recognised that if a similar target system is adopted to the packaging PRN system, then a surplus caused, for instance, by the capture of hidden recycling could lead to a dramatic fall in evidence prices rather than an escalation. e. There is also the issue of displays. Under the current PRN system, a 65% target for displays would see the value of display evidence probably match the actual cost of collection and recycling as there is already a large surplus. The fact that displays (and the same will apply to cooling equipment) have to be collected because of their hazardous nature means that this will always be the case. Nevertheless, the model assumes that the charge made for evidence will be at a level created by the current market type rather than by a PRN market type. f. With regards to the EU position, a calculation has been made using the same % growth and cost assumptions as for the UK model. This has been extrapolated from the 2012 figure given in the Commission Impact Assessment of 12m tonnes 12

in 2012 and assessing the tonnage that would be required by 2016 to meet the targets, but as in the UKs case, that certainly for displays, the amount being collected would be well above the target. g. The validity of these figures is extremely questionable as it does not take account of the current positions of other Member States. But it demonstrates a potential comparison between the actual costs of collection and the charges to producers should a current UK type regime be allowed to spread.

Fig.15 Potential costs for 2016 based on expected EU WEEE arisings

1. Summary
a. It is clear that the current market has settled into a broadly status quo position that suits the majority of PCSs, DCF operators and Local Authorities. b. There appears to be little motivation within that market to reduce prices to producers who generally, have very little understanding of market conditions and no visibility on market prices, either for commodity values or the costs for creating evidence. c. This is leading to producers paying an increasingly disproportionate level of margin into the system with little sign of any change under the current Regulatory requirement where all collected B2C WEEE must be paid for by producers. The current gap between cost of collection and recycling vs charge to producers has been indicated to be in the region of >50m. d. Whilst this position allows some high prices to be charged, the current margins would seem to be limiting the tendency to move to the level of ransom charges seen in 2007/8. Moves by the Environment Agency to control non-contracted trading are also making this more difficult. However, marginal trading activity suggests that given the right conditions, the position would quickly be exploited again in a similar way to 2007/8. e. A change in the targets could well lead to a return to full exploitation but it must also be recognised that this could go both ways. Packaging Regulations experience has demonstrated that in a supply/demand market based on targets, charges for evidence bear no relation to costs and quickly establish their positions on the basis of market flexibility. In a shortfall situation, it is therefore likely that evidence charges would move much higher than current extreme pricing. But equally, in a surplus as already exists with displays prices can quickly fall to levels that then become counter-productive and stifle existing activity unless the material has an intrinsic value in its own right. 13

14

Appendix 1
2007 2007 Average Average gate collection fee/value costs Large Household Appliances Sm Household Appliances all IT and Telcom s Equipm m ent Consum Equipm er ent Lighting Equipm ent Electrical and Electronic Tools Toys Leisure and Sports Medical Devices Monitoring and Control Autom atic Dispensers Display Equipm ent Cooling Appliances Gas Discharge Lam ps Total -110 -15 -15 -15 -15 -15 -15 -15 -15 -15 120 0 40 70 70 70 70 70 70 70 70 70 40 80 2007 Average costs 0 55 55 55 55 55 55 55 55 55 160 80 2,000 217 119-160 225 140 2,300 340 220 2,300 153-183 152 95 111-216 150 150 120 150 190 190 190 180 2007 Average m arket Evidence charges 5 115 93-147 73-140 2007 Average m arket cost 2007 extrem e used for trading calculation charges 5 120 125 120 20 190 190 190 Cost @ 2007 WEEE Total cost at extrem e Predicted 2016 tonnage av. Mkt prices Costs @ extrem tonnage @ 65% 2016 costs @ 2016 costs @ 2016 costs @ e collected prices m arket applied to prices applied to (other than extrem e average average 2011 collected Av. total cost price total 10% displays) prices prices costs 60,395 6,514 6,393 6,304 17 3,455 174 2 166 0 44,049 58,263 307 186,037 0 358,251 351,598 346,715 913 190,021 9,589 97 9,123 0 7,047,842 4,661,010 613,676 301,974 781,639 799,086 756,470 0 518,240 26,152 211 24,881 0 1,207,894 1,237,595 1,214,611 1,197,744 0 656,437 33,126 334 29,858 0 422,763 905,387 920,535 876,232 0 583,869 29,449 233 27,852 0 11,408,672 9,438,532 776,070 25,389,593 321,882 97,061 133,851 48,487 33,442 51,852 40,389 7,596 14,769 5,231 123,301 133,108 9,413 981,459 6,437,636 1,609,409 -43,454,041 -1,067,670 -1,472,358 -533,354 -367,866 -570,369 -444,280 -83,559 -162,462 -57,541 7,644,662 8,652,026 14,120,168 -17,796,645 18,441,567 11,647,305 25,431,646 16,731,346 9,212,473 0 9,851,836 7,673,935 1,443,293 2,658,468 0 5,818,404 0 7,777,765 6,058,370 911,554 2,215,390 0

9,911,028 14,976,664 8,156,768 12,817,779 705,727 705,727

41,922,340 27,742,725 29,283,781 18,635,133 21,650,925 21,650,925 174,007,899 120,798,326

13,588,836 21,982,177 34,077,770

15

Appendix 2 Proposed B2C targets that would be necessary to achieve the proposed recast targets with B2B collections at current rate
B2C %targets LDA Cooling Displays Mixed Total B2C tonnages LDA Cooling Displays Mixed Total 2011 34% 44% 97% 23% 15% 2011 169,622 89,306 126,029 150,129 535,086 2012 40% 46% 96% 31% 18% 2012 199,361 93,507 124,933 204,273 622,075 2013 46% 48% 95% 39% 20% 2013 229,101 97,709 123,837 258,417 709,064 2014 52% 50% 95% 47% 23% 2014 258,841 101,910 122,742 312,561 796,053 2015 58% 52% 94% 55% 25% 2015 288,580 106,111 121,646 366,704 883,042 2016 64% 54% 93% 63% 28% 2016 318,320 110,313 120,550 420,848 970,031

16

You might also like