Environmental Protection (Single-use Plastic Products) (Scotland) Regulations 2021: business and regulatory impact assessment - final

Footnotes

1. European Union (2019) Directive (EU) 2019/904 of the European Parliament and of the Council of 5 June 2019 on the reduction of the impact of certain plastic products on the environment, Article 3(3).

2. The Scottish Government (2016) Making things last – A circular economy strategy for Scotland.

3. The Scottish Government (2010) Scotland's Zero Waste Plan.

4. The Scottish Government (2013) Safeguarding Scotland's resources - A programme for the efficient use of our materials.

5. The Scottish Government (2020) The Deposit and Return Scheme for Scotland Regulations 2020.

6. The Scottish Government (2018) Expert Panel on Environmental Charging and Other Measures (EPECOM).

7. The Scottish Government (2019) Single-use disposable cups: EPECOM recommendations.

8. The Scottish Government (2020) Ending the throwaway culture: Five principles for tackling single-use items (EPECOM).

9. Marine Conservation Society (2019) Great British Beach Clean 2019.

10. Marine Scotland (2021) Facts and figures about Scotland's sea area (coastline length, sea area in sq kms).

11. Scottish Government (2016) Key Scottish Environment Statistics 2016.

12. Deudero S., Alomar C. (2015) "Mediterranean marine biodiversity under threat: Reviewing influence of marine litter on species" in Marine Pollution Bulletin, Volume 98.

13. Gallo, F et al (2018) "Marine litter plastics and microplastics and their toxic chemicals components: the need for urgent preventive measures", in Environmental Sciences Europe, Volume 30.

14. Resource Futures (2019) "A preliminary assessment of the economic impacts of a potential ban on expanded polystyrene food and beverage containers", p.23.

15. Ibid.

16. The Scottish Government (2021) National Performance Framework.

17. The Scottish Government (2021) National Outcome: We value and enjoy our built environment and protect it and enhance it for future generations.

18. The Scottish Government (2021) National Outcome: We reduce the local and global environmental impact of our consumption and production.

19. The Scottish Government (2020) National Performance Framework - National Indicator Performance.

20. The Scottish Parliament (2019) Climate Change (Emissions Reduction Targets) (Scotland) Act 2019.

21. The Scottish Government (2020) Securing a green recovery on a path to net zero: climate change plan 2018–2032 - update

22. United Nations (2020) UN Sustainable Development Goals.

23. The Scottish Government (2020) Protecting Scotland, Renewing Scotland: The Government's Programme for Scotland 2020-2021.

24. Used for on-the-go food which is ready to eat and does not require further preparation.

25. For simplicity, both EPS and XPS items will be referred to as EPS throughout the rest of this assessment.

26. Scottish Government (2020) Introducing market restrictions on problematic single-use plastic items in Scotland: Partial Business and Regulatory Impact Assessment (BRIA).

27. It is difficult to anticipate and model the impact of restrictions on single-use plastics products on trends in reusables. First, their applications are less directly comparable. For example, food and drink outlets cannot easily switch to giving out reusable straws without systems in place to recover the items and associated consumer behaviour change. Second, like-for-like assessment of price is not straightforward, as it must be based on a 'functional unit', representing one use of the item. This requires reliable data on how many times each item is reused, on average, which is not available.

28. Resource Futures on behalf of Defra (2018a): A preliminary assessment of the economic impacts of a potential ban on plastic cutlery, plastic plates and plastic balloon sticks, A preliminary assessment of the economic, environmental and social impacts of a potential ban on plastic straws, plastic stem cotton buds and plastics drinks stirrers; and Resource Futures on behalf of Defra (2019) A preliminary assessment of the economic impacts of a potential ban on expanded polystyrene food and beverage containers.

29. ibid

30. Resource Futures on behalf of DEFRA (2019) A preliminary assessment of the economic impacts of a potential ban on expanded polystyrene food and beverage containers.

31. These calculated the relevant market shares based on consumption data provided by large companies.

32. Resource Futures on behalf of Defra (2018a): A preliminary assessment of the economic impacts of a potential ban on plastic cutlery, plastic plates and plastic balloon sticks, A preliminary assessment of the economic, environmental and social impacts of a potential ban on plastic straws, plastic stem cotton buds and plastics drinks stirrers; and Resource Futures on behalf of Defra (2019) A preliminary assessment of the economic impacts of a potential ban on expanded polystyrene food and beverage containers.

33. The Scottish Government (2020) Introducing market restrictions on problematic single-use plastic items in Scotland: Strategic Environmental Assessment - environmental report.

34. Cole, G; Worth, C; Powell, K; Reeve, S; Stevenson, S; Morgan, N; Walker, H (2019) Preliminary research to assess the impacts of a ban or restrictions in sale in Wales of items in the EU's Single Use Plastics Directive. Cardiff: Welsh Government, GSR report number 32/2020.

35. HM Treasury (2020): The Green Book, Central Government Guidance on Appraisal and Evaluation - Social time preference rate (STPR), p.45-46.

36. Zero Waste Scotland (2011-2021) Carbon Metric Publications.

37. Department for Business, Energy & Industrial Strategy (2020) Green Book supplementary guidance: valuation of energy use and greenhouse gas emissions for appraisal.

38. European Commission (2021) EU Emissions Trading System (EU ETS).

39. Resource Futures on behalf of Defra (2018a): A preliminary assessment of the economic impacts of a potential ban on plastic cutlery, plastic plates and plastic balloon sticks, A preliminary assessment of the economic, environmental and social impacts of a potential ban on plastic straws, plastic stem cotton buds and plastics drinks stirrers; and Resource Futures on behalf of Defra (2019) A preliminary assessment of the economic impacts of a potential ban on expanded polystyrene food and beverage containers.

40. WRAP (2019) Gate fees 2018/19 report Comparing the costs of alternative waste treatment options

41. letsrecycle.com compiles prices per tonne for different materials on an ex works (EXW) basis (EXW is a shipping arrangement in which a seller makes a product available at a specific location, but the buyer has to pay the transport costs.) Paper prices were downloaded from: https://www.letsrecycle.com/prices/

42. Resource Futures on behalf of Defra (2019) A preliminary assessment of the economic impacts of a potential ban on expanded polystyrene food and beverage containers.

43. Zero Waste Scotland (2013) Scotland's Litter Problem: Quantifying the scale and cost of litter and fly tipping.

44. Zero Waste Scotland (2013) Scotland's Litter Problem: Quantifying the scale and cost of litter and fly tipping.

45. Resource Futures on behalf of Defra (2019) A preliminary assessment of the economic impacts of a potential ban on expanded polystyrene food and beverage containers.

46. Nelms et al. (2017) Marine anthropogenic litter on British beaches: A 10-year nationwide assessment using citizen science data.

47. European Commission (2018) Impact Assessment, Reducing Marine Litter: action on single-use plastics and fishing gear.

48. Audit Scotland (2000) Benchmarking refuse collection, A review of councils' refuse collection services and information provided by Zero Waste Scotland.

49. Scottish Government (2005) Based on the approach in Proposed plastic bag levy - extended impact assessment final report.

50. Resource Futures on behalf of Defra (2019) A preliminary assessment of the economic impacts of a potential ban on expanded polystyrene food and beverage containers. Available at: http://sciencesearch.defra.gov.uk/Default.aspx?Menu=Menu&Module=More&Location=None&Completed=220&ProjectID=20292

51. Zero Waste Scotland (2021): "Pricing impacts of single-use plastic bans: Assessing the impact of market-restrictive bans for single-use plastic products on product pricing". Not published.

52. ISWA (2017). Prevent marine plastic litter – now!

53. OSPAR survey on most commonly found identifiable microplastic items in beach litter in the UK.

54. Beaumont, N. et al. (2019) Global ecological, social and economic impacts of marine plastic. Marine Pollution Bulletin. Vol. 142, pp. 189-195; and Hodal, K (4 Apr 2019) Marine plastic pollution costs the world up to $2.5tn a year, researchers find. The Guardian.

55. Competition and Markets Authority (2015) Competition impact assessment: guidelines for policymakers.

56. Scottish Government (2020) Businesses in Scotland: 2020.

57. Law, P. (2017) Scotland's plastics industry: Crucial to the overall sector, Interplas Insights.

58. British Plastics Foundation (2021) Members Directory 2020-21.

59. British Plastics Foundation (n.d.) About the British Plastic Industry. The two polymer manufacturers are Ineos Olefins & Polymers (Grangemouth; polymers include Polyethylene High Density/Linear Low Density [HD / LLDPE swing], Polypropylene) and PET Processors (UK) LLC (Dumfries; polymers include Polyethylene Terephthalate [PET]).

60. Resource Futures on behalf of Defra (2018a): A preliminary assessment of the economic impacts of a potential ban on plastic cutlery, plastic plates and plastic balloon sticks, A preliminary assessment of the economic, environmental and social impacts of a potential ban on plastic straws, plastic stem cotton buds and plastics drinks stirrers, and Resource Futures on behalf of Defra (2019) A preliminary assessment of the economic impacts of a potential ban on expanded polystyrene food and beverage containers.

61. Scottish Government (2020) Introducing market restrictions on problematic single-use plastic items in Scotland: Strategic Environmental Assessment (SEA).

62. Resource Futures on behalf of Defra (2018a): A preliminary assessment of the economic impacts of a potential ban on plastic cutlery, plastic plates and plastic balloon sticks, A preliminary assessment of the economic, environmental and social impacts of a potential ban on plastic straws, plastic stem cotton buds and plastics drinks stirrers, and Resource Futures on behalf of Defra (2019) A preliminary assessment of the economic impacts of a potential ban on expanded polystyrene food and beverage containers.

63. Resource Futures on behalf of Defra (2018a): A preliminary assessment of the economic impacts of a potential ban on plastic cutlery, plastic plates and plastic balloon sticks, A preliminary assessment of the economic, environmental and social impacts of a potential ban on plastic straws, plastic stem cotton buds and plastics drinks stirrers; and Resource Futures on behalf of Defra (2019) A preliminary assessment of the economic impacts of a potential ban on expanded polystyrene food and beverage containers.

64. Resource Futures on behalf of Defra (2019) A preliminary assessment of the economic impacts of a potential ban on expanded polystyrene food and beverage containers.

65. The BPF Expanded Polystyrene Group (n.d.) Find a supplier. Producers identified are: Engineered Foam Products (Livingston), Moulded Foams (Cumbernauld, Stornoway, Peterhead), Sundolitt (Corpach, Montrose, Stirling), Thulecraft (Lerwick). Email correspondence with the firms confirmed that Sundolitt does not produce any of the items in scope (the others were contacted but did not respond to our request).

66. Sundollit. 19/04/2021

67. ONS (2009) UK Standard Industrial Classification of Economic Activities 2007 (SIC 2007), Main volume.

68. SPICe (Scottish Parliament Information Centre) Spotlight (2019) Fast food booming – a cause for concern?

69. Scottish Government (2020) Businesses in Scotland: 2020.

70. SPICe (Scottish Parliament Information Centre) Spotlight (2019) Fast food booming – a cause for concern?

71. British Takeaway Campaign (2019) Cooking up growth, Serving up talent.

72. Based on sector turnover data from Scottish Government (2020) Businesses in Scotland: 2020; and unit price data from Welsh Government (2020) Preliminary research to assess the impacts of a ban or restrictions in sale in Wales of items in the EU's Single Use Plastics Directive.

73. Resource Futures on behalf of Defra (2018a): A preliminary assessment of the economic impacts of a potential ban on plastic cutlery, plastic plates and plastic balloon sticks, A preliminary assessment of the economic, environmental and social impacts of a potential ban on plastic straws, plastic stem cotton buds and plastics drinks stirrers; and Resource Futures on behalf of Defra (2019) A preliminary assessment of the economic impacts of a potential ban on expanded polystyrene food and beverage containers.

74. Resource Futures on behalf of Defra (2019) A preliminary assessment of the economic impacts of a potential ban on expanded polystyrene food and beverage containers.

75. Resource Futures on behalf of Defra (2019) A preliminary assessment of the economic impacts of a potential ban on expanded polystyrene food and beverage containers. The £30m figure is based on the sum of the capital costs for the two EPS product categories (47.7 + 68.1 = 115.8) distributed evenly between the four known EPS manufacturing facilities in the UK: £28.95m.

76. Scottish Government (2020) Scottish Annual Business Statistics 2018.

77. Manufacture of paper and wood products except furniture in England and Scotland (2018) of £6,317m and £959m, respectively, over manufacturing workforce jobs (Dec 2019) of 2.25m and 183,000, respectively. ONS (2019) Regional GVA (balanced) by industry: all NUTS level regions; and ONS (2020) JOBS05: Workforce jobs by region and industry.

78. Welsh Government (2020) Preliminary research to assess the impacts of a ban or restrictions in sale in Wales of items in the EU's Single Use Plastics Directive.

79. Zero Waste Scotland (2021): "Pricing impacts of single-use plastic bans: Assessing the impact of market-restrictive bans for single-use plastic products on product pricing". Not published.

80. Same methodology applied as Resource Futures research for Welsh Government. Obtained by taking an average of prices found from different wholesaler websites, primarily: Catering24; Cater4you; Nisbets.

81. SPICe (Scottish Parliament Information Centre) Spotlight (2019) Fast food booming – a cause for concern?

82. Scotland's Census (2021) Housing.

83. We note that there will be a programme of public engagement alongside the policy, which will mitigate this impact. Furthermore, the lead-in period allowing time for firms to adjust will give an opportunity for smaller firms to discover changes to the rules that they might otherwise have been unaware of.

84. See, for example, Bernard et al. (2019) The origins of firm heterogeneity: A production network approach, NBER working paper No. 25441.

85. Resource Futures on behalf of Defra (2018a): A preliminary assessment of the economic impacts of a potential ban on plastic cutlery, plastic plates and plastic balloon sticks, A preliminary assessment of the economic, environmental and social impacts of a potential ban on plastic straws, plastic stem cotton buds and plastics drinks stirrers; and Resource Futures on behalf of Defra (2019) A Preliminary Assessment of the Economic Impacts of a Potential Ban on Expanded Polystyrene Food and Beverage Containers.

86. Resource Futures on behalf of Defra (2019) A preliminary assessment of the economic impacts of a potential ban on expanded polystyrene food and beverage containers.

87. Welsh Government (2020) Preliminary research to assess the impacts of a ban or restrictions in sale in Wales of items in the EU's Single Use Plastics Directive.

88. Suntory Beverage and Food GB&I, owner of Ribena, began trialling paper straws on its cartons in retailers in the UK in September 2020. Tetra Pak began consumer trials of its paper straws in 2019. Sources: Suntory (2020) The final straw: Ribena becomes first major UK juice drinks brand to trial paper straws on cartons; and Tetra Pak (2019) ​​​​​​​​​​​​​​​​​​​​Tetra Pak becomes first carton packaging company to launch paper straws in Europe.

89. Tiffin, R. et al (2012) for Defra. Estimating Food and Drink Elasticities.

90. British Takeaway Campaign (2019) Cooking up growth, Serving up talent.

91. Zero Waste Scotland (2021): "Pricing impacts of single-use plastic bans: Assessing the impact of market-restrictive bans for single-use plastic products on product pricing". Not published.

92. Scottish Government (2018) Business and Regulatory Impact Assessments (BRIA) toolkit.

93. Zero Waste Scotland (2020) Majority of Scots concerned over single-use items and packaging. Available at: https://www.zerowastescotland.org.uk/press-release/majority-scots-concerned-over-single-use-items-and-packaging

94. European Union (2019) Directive (EU) 2019/904 of the European Parliament and of the Council of 5 June 2019 on the reduction of the impact of certain plastic products on the environment, Article 3(3).

95. The Scottish Government (2020) Introducing Market Restrictions on Problematic Single-Use Plastic Items in Scotland: Strategic Environmental Assessment - Environmental Report.

96. Resource Futures on behalf of Defra (2018a): A preliminary assessment of the economic impacts of a potential ban on plastic cutlery, plastic plates and plastic balloon sticks, A preliminary assessment of the economic, environmental and social impacts of a potential ban on plastic straws, plastic stem cotton buds and plastics drinks stirrers; and Resource Futures on behalf of Defra (2019) A Preliminary Assessment of the Economic Impacts of a Potential Ban on Expanded Polystyrene Food and Beverage Containers.

97. Resource Futures on behalf of Defra (2019) A preliminary assessment of the economic impacts of a potential ban on expanded polystyrene food and beverage containers.

98. Welsh Government (2020) Preliminary research to assess the impacts of a ban or restrictions in sale in Wales of items in the EU's Single Use Plastics Directive.

99. Suntory Beverage and Food GB&I, owner of Ribena, began trialling paper straws on its cartons in retailers in the UK in September 2020. Tetra Pak began consumer trials of its paper straws in 2019. Sources: Suntory (2020) The final straw: Ribena becomes first major UK juice drinks brand to trial paper straws on cartons; and Tetra Pak (2019)Tetra Pak becomes first carton packaging company to launch paper straws in Europe.

100. Welsh Government (2020) Preliminary research to assess the impacts of a ban or restrictions in sale in Wales of items in the EU's Single Use Plastics Directive. Available at: https://gov.wales/sites/default/files/statistics-and-research/2020-05/impacts-of-a-ban-or-restrictions-in-sale-of-items-in-the-eus-single-use-plastics-directive.pdf

101. Pricing impacts of single-use plastics bans. Eunomia. January 2021. Unpublished

102. Pricing impacts of single-use plastics bans. Eunomia. January 2021. Unpublished.

103. See discussion on page 24. Tiffin, R. et al on behalf of Defra (2012) Estimating food and drink elasticities. Available at: https://www.gov.uk/government/publications/food-and-drink-elasticities