EU single use plastics directive consultation: fairer Scotland duty scoping assessment

Fairer Scotland Duty - Scoping Assessment

Title of Policy, Strategy, Programme etc

The introduction of market restrictions on certain single-use plastic items in line with Article 5 of the EU Directive (EU) 2019/904 on the reduction of the impact of certain plastic products on the environment.

Summary of aims and expected outcomes of strategy, proposal, programme or policy

The proposal is for a market restriction on single-use plastic (SUP) products in line with Article 5 of the EU Directive (EU) 2019/904 on the reduction of the impact of certain plastic products on the environment (hereafter referred to as the "SUP Directive").

The following items are included:

1. Single-use plastic cutlery (forks, knives, spoons, chopsticks);

2. Single-use plastic plates (plates, trays/platters, bowls);

3. Single-use plastic straws;

4. Single-use plastic beverage stirrers;

5. Single-use plastic balloon sticks;

6. Single-use food containers made of expanded polystyrene;

7. Single-use cups and other beverage containers made of expanded polystyrene, including their covers and lids;

8. All oxo-degradable products.

The following definitions, taken from the SUP Directive are applied to this assessment;

• 'plastic' means a material consisting of a polymer as defined in point 5 of Article 3 of Regulation (EC) No. 1907/2006, to which additives or other substances may have been added, and which can function as a main structural component of final products, with the exception of natural polymers that have not been chemically modified;
• 'single-use plastic product' means a product that is made wholly or partly from plastic and that is not conceived, designed or placed on the market to accomplish, within its life span, multiple trips or rotations by being returned to a producer for refill or re-used for the same purpose for which it was conceived;
• 'oxo-degradable plastic' means plastic materials that include additives which, through oxidation, lead to the fragmentation of the plastic material into micro-fragments or to chemical decomposition

The proposed introduction of market restrictions is part of a package of measures being taken forward by Scottish Ministers to address marine litter and support a shift away from our throwaway culture.

Summary of evidence

The proposed introduction of market restrictions is intended to apply consistently across Scotland and does not specifically target particular groups or sections of society. It is, however, important to ensure that the impact on those who experience socio-economic disadvantage is understood, whether this is through low income, low wealth, material deprivation, area deprivation or socio-economic background. For the years 2016-2019, it was estimated that 19% of Scotland's population were living in relative poverty after housing costs^[1].

The Impact Assessment published alongside the SUP Directive^[2] highlighted that the items that would be restricted by this policy have alternatives available.

Cutlery, straws and stirrers are noted to have clear alternatives available, while food containers and cups have some alternatives available. As such, this policy would not prevent similar items being available, but instead is likely to result in a shift in the materials used, or an increase in the use of reusable containers.

There is, however, the potential for differential impacts associated with the proposed introduction of market restrictions if issues arise with regard to the cost of the alternative items or reuse models. Those on low incomes have previously been identified as being more likely to pay more for essential goods and services, including food, than the rest of the population^[3]. This inherently represents a higher proportion of the income of low-income households^[4]. Feedback to DEFRA's consultation on single use plastic^[5] indicated that paper straws could be more expensive than plastic ones, and the Welsh Government's consultation^[6] has highlighted that hospitality businesses may face increased costs, which may pass to their customers.

That said, research undertaken on behalf of the Welsh Government has indicated that the potential price differences are generally small, with the exception of balloon sticks where an increase of 11p per unit was cited^[7].

In addition, research undertaken on behalf of the EU^[8] has indicated price differences between -0.007 euros and +0.146 euros. This research was conducted in 2018, and used data sources from across the EU, including some from the UK.

Table 1: Unit cost of single-use plastic items and single-use non plastic items

	Unit cost (average) in €
	Single-use plastic items	Single-use non-plastic items
Cutlery	0.053	0.098
Straws	0.012	0.092
Stirrers	0.014	0.007
Drinks cups	0.1	N/A
Drink cup lids	0.029	N/A
Food containers	0.118	0.264

We will seek views from representative groups during the consultation as to whether the proposed introduction of market restrictions has a particular impact on those experiencing socio-economic disadvantage, both with regard to the potential for additional costs, and also to understand whether those experiencing socio-economic disadvantage use more or less of the single-use plastic items being targeted.

The proposed market restrictions also extend to products made from oxo-degradable plastics. We have not identified any likely significant impacts as a result of the banning of this material. However, we welcome views on this matter.

Summary of assessment findings

This partial assessment has not identified any definitive impacts on those who experience socio-economic disadvantage. However, to ensure that any issues are identified, we will be seeking views from representative groups during the consultation.

Sign off

Name: Don McGillivray

Job title: Deputy Director, Environmental Quality and Circular Economy