Environmental Protection (Single-use Plastic Products) (Scotland) Regulations 2021: islands communities impact assessment - final

Assessment: is the policy likely to have a significantly different impact on island communities?

Waste collections

27. Zero Waste Scotland has undertaken research to understand the difference in weight of alternatives to the single-use plastic items that would be subject to market restrictions (see Table 1 below). The majority of the alternatives highlighted are heavier than the current single-use plastic versions.

28. However, it should be noted that it is estimated that the total amount of single-use plastic waste generated is approximately 1,860 tonnes per year (for the whole of Scotland). This is considered to be insignificant in comparison to the total waste from all sources in 2018, which was over 11 million tonnes.^[6]

29. In addition, it is anticipated that consumer choice will result in a reduction in the prevalence of many of these single-use items over time, regardless of the material used, through switching to reusable options or reduced use of these items^[7][8]. This reduction may be increased if the communications accompanying the introduction of market restrictions highlighted the benefits associated with using less single-use items, regardless of the material.

30. We therefore do not consider that the additional weight of items poses a significant problem for waste treatment and collection in island communities.

31. With regards to the ease of recycling alternatives, previous DEFRA research has indicated that the recycling rates of the single-use plastic items in question are low (between 0 and 10%).^[9][10][11] The recycling rates for common alternative single use items are in the same range, although it should be noted that alternatives to EPS are more commonly recycled, whilst non-plastic single-use cutlery is less commonly recycled.

32. These proposals do not dictate what alternative materials should be used, although it is noted that reusable options are considered to be preferable.^[12] Businesses will therefore be able to choose appropriate alternatives, or in some cases move away from using these items at all. In island areas, items that do not require specialist treatment at the post-use stage may be preferable, as this may reduce local authority costs by enabling treatment or reuse closer to the source of the waste. However, it should be noted that the current single-use plastic items are also often difficult to recycle.

33. We therefore do not consider that this issue is significantly different for island communities.

Marine litter

34. Participants at the workshops and respondents to the consultation noted the prevalence of plastic waste on beaches in island areas at present.

35. It is anticipated that this proposal will have a beneficial effect with regard to marine litter, as cutlery, straws, stirrers, drinks cups and cup lids, balloon sticks and food containers are among the top ten single-use plastic items found on beaches in the EU.^[13] In addition, recent work by Marine Scotland indicated that local litter sources dominate plastic inputs to Scottish coastal areas, so local litter reduction actions can reduce marine plastics.^[14]

36. We therefore consider that this is likely to have a positive impact on island communities. Using communications associated with the introduction of market restrictions to highlight the benefits of moving away from single-use items all together will increase the potential for a beneficial effect.

The use of alternatives on ferries

37. It was noted at the workshops that prior to the Covid-19 pandemic, reusables were already being used on some ferries. It is therefore considered that a switch away from the single-use plastic items under consideration is unlikely to be problematic. It should also be highlighted that for food and beverage containers, only the use of expanded polystyrene would be subject to market restrictions, so ferry companies could use single-use items from an alternative material if necessary.

38. We therefore do not consider that this will have a significant impact on island communities.

Access to alternatives

39. It was noted at the workshops that the Covid-19 pandemic has impacted on hospitality businesses, and businesses may have returned to single-use plastic as a result of perceived hygiene concerns.

40. We do not consider the impact of Covid-19 on businesses to be an island-specific impact, as businesses throughout Scotland have been impacted by the pandemic. However, it will be important to ensure that the island context is taken into account when communication of the changes is undertaken. It was noted during the workshops that this should include local business groups and newspapers for the islands. This will ensure that island businesses are able to plan ahead.

41. With regard to the potential for higher transport costs for heavier alternatives, it is well-documented that island communities face a premium for parcel deliveries.^[15] There does not appear to have been any equivalent research for the delivery costs charged by wholesalers, and there is little publicly-available information about wholesale delivery costs. However, it appears that some wholesalers base the delivery cost on the value, rather than the weight, of the order. This would mean that the delivery cost of the alternative items would not be higher, as costs tend to decrease with the value of the order. Even if companies do base delivery costs on weight, the weight of alternative single-use items remains very small so any increase in cost is likely to be insignificant when considered on a per item basis. We therefore do not consider that this will have a significantly different impact for island communities.

42. This should also be seen in the context of ongoing Scottish Government work to ensure that the parcel delivery market works in the interests of all Scottish consumers and businesses.^[16] In addition, it should be noted that encouraging customer use of reusable alternatives or reduced reliance on single-use items would enable businesses to reduce the impact of any increase in delivery costs.