Waste electrical and electronic equipment reform consultation: equalities impact assessment

Key Findings

Age

Older individuals may be disproportionately affected by any changes to service design or introductions of new services by local authorities, retailers, online sellers, producers and manufacturers^[7]. It is possible older persons may be more likely to find changes and/or new services difficult, particularly in relation to new digital technology^[8]; they are also more likely to have a limiting condition such as visual or hearing impairments^[9]. Therefore, inclusive communication methods and styles would need to be factored into all communications to ensure that relevant support is provided by whoever is providing the service/information^[10].

The Scottish Household Survey (2021)^[11] found that older people are slightly less likely to be regular internet users, with 71% of adults 75+, and 91% of adults aged 60-74 regularly using the internet. This compares with 100% of 16-24 year olds. It will thus be important for inclusive communications to go beyond digital means. This should be taken into consideration for the ability of various age groups to access digital information, online shopping, and internet seller take-back schemes, as well as any proposal to make mandatory labelling to provide information on the sustainability of electronics available via QR codes. It will also be important to consider that older people may be slightly less likely to benefit from online sellers offering free take-back services.

Any improvements to communications to ensure individuals of all ages understand opportunities for the recycling or reuse of WEEE will have a positive impact. There will also be a need to ensure that container type, collection frequency and any amendments to assisted lift^[12] provision are taken into consideration. This will be particularly relevant for older and less physically able householders who may for example, struggle to lift kerbside boxes or bags.

The introduction of kerbside collections for WEEE and online take-back services should have a positive impact on particularly younger and elderly age groups (particularly single pensioner households). These age groups^[13] have been shown as less likely to have direct access to a private vehicle, and therefore lack the convenience car owners would have in terms of transporting items to their local household recycling centre or directly to a retailer. Household recycling centres are generally located outside of city centres, and the transport of items of WEEE could be difficult using public transport. For large items of WEEE, transporting by private transport is the only alternative for the householder to paying for the local authority to collect. Similarly, householders purchasing new large electrical items will have the option to pay the retailers to remove the old appliance on delivery of the new item.

Consideration should be given to how any increases in costs attributed to WEEE EPR is passed through^[14] to the consumer, with younger people more likely to be in relative poverty and/or have a lower disposable income. At this time, direct attribution costs have not been finalised. However, cost modelling work undertaken by Defra suggests an estimated net cost increase across all households of £0.95/year should all proposals in the consultation be taken forwards.

Recently, increasing attention has been given to vapes (e-cigarettes), and specifically the uptake in disposable vape use by young people^[15],[16]. In spring 2023 The Scottish Government commissioned research to better understand the environmental impacts of single-use vapes. The research, published in June 2023^[17], informed the four nations consultation on tackling smoking and youth vaping which ran from Oct-Dec 2023^[18]. This consultation also proposes creating a new EEE category for vapes, to ensure that vapes producers are paying the full cost of separate collection and recycling of waste vapes, and remove the risk of other existing Category 7 producers subsidising the cost of collection and treatment of vapes.

Disability

24% of adults in Scotland have a long-term physical or mental health condition, as per the Scottish Household Survey (2019)^[19]. A physical or mental disability may affect an individual’s capacity to manage or adapt to any changes associated with reform of the system. For example the introduction of services such as kerbside collection services, online take-back and accessing take-back points.

To help support people with limiting conditions adapt to any future changes in managing their WEEE, inclusive communication methods and styles, including non-digital means, would need to be applied and adequate support provided by local authorities, retailers, online sellers, and producers/manufacturers. Any communications would need to be inclusive for a variety of conditions, including but not limited to, visual and hearing impairments, dyslexia, and other learning difficulties, etc. as well as communications tailored to young and adult carers.

Similar to older people, people with limiting conditions^[20] are less likely to use the internet. 29% of adults who have some form of limiting long-term physical or mental health condition or illness do not use the internet, a significantly higher share than for those who have some form of non-limiting condition or illness (10%) and those who have none (6%). As noted above, inclusive communications beyond digital means will thus be required.

Any improvements to communications to ensure individuals with limiting conditions can manage and adapt to opportunities for the recycling or reuse of WEEE, will have a positive effect.

The introduction of kerbside collections of WEEE and online take-back services should positively affect people with limiting conditions by providing a more accessible service. Just under half^[21] (46%) of people with a long-term health problem or disability which limits their day-to-day activities, reside in households with no cars or vans. This compared to only 19% of people with no limiting long-term health problem.

As above, consideration will need to be given as household collections of WEEE are designed and implemented in terms of container type, collection frequency and any amendments to assisted lift provision. This will be particularly relevant for less physically able householders who may for example, struggle to lift kerbside boxes or bags.

Again, consideration would need to be given to how any increases in cost of electrical items is passed through to the consumer, with 23% of people with disabilities in relative poverty compared to 17% of people who are not disabled^[22].

Sex

No evidence was identified which would indicate a likely differential impact based on sex resulting from changes to the WEEE EPR system.

Pregnancy & Maternity

No evidence was identified which would indicate a likely differential impact on pregnant or new mothers resulting from changes to the WEEE EPR system.

Gender Reassignment

No evidence was identified which would indicate a likely differential impact on an individual who has undergone gender reassignment or changed their gender identity resulting from changes to the WEEE EPR system. Sexual Orientation No evidence was identified which would indicate a likely differential impact on sexual orientation resulting from changes to the WEEE EPR system.

Race

The issues outlined above regarding inclusive communications also apply to minority ethnic citizens. In instances where English is not spoken as the first language, consumers should be able to readily access required information. As such, it will be important for local authorities, retailers, online sellers, and producers/manufacturers to ensure their communications are accessible in multiple languages.

Some minority ethnic people are less likely to have access to a vehicle^[23]. Car ownership statistics from the Transport Scotland Scottish Household Survey^[24] shows that the proportion of households with no car or van available was highest for ‘African’ (60%) or ‘Caribbean or Black’ (49%) ethnic groups. These groups therefore may benefit from the introduction of kerbside collections of WEEE and online take-back services.

Minority ethnic groups are more likely to be in relative poverty and/or have a lower disposable income^[25] and may potentially be disproportionally impacted if any increases in cost of electrical items is passed through to the consumer.

Religion or Belief No evidence was identified which would indicate a likely differential impact on for based on religion or belief resulting from changes to the WEEE EPR system. Marriage and Civil Partnership

The Scottish Government does not require assessment against this protected characteristic unless the policy or practice relates to work, for example HR, policies and practices. This policy does not relate to work therefore we have not considered it for this EQIA.