EU single use plastics directive consultation: impact assessment - environmental report

5. Material Assets

Whilst the SEA legislation does not provide any definition of the term "material assets", the SEPA guidance states that material assets include built assets and natural assets. The scope of "built assets and natural assets" is therefore defined, within this Environmental Report, as encompassing the following:

• Natural assets - raw source of compositional materials of targeted single-use plastic items and any raw materials used to support waste infrastructure;
• Built assets - land take and soil use/loss for new infrastructure;
• Built assets - any new infrastructure required for the adoption of the alternative option.

This section provides the contextual information to inform the assessment (in terms of the review of Plans, Programmes and Strategies (PPS) and the baseline information) as well as an assessment of the effects of the SUP Directive on material assets.

5.1 Relationship with other Plans, Programmes and Strategies and Environmental Objectives

The PPS relevant to the material asset topic area are shown in Figure 5-1 and summarised thereafter.

For the purposes of this SEA, it is assumed that the broad objectives of extant European Union (EU) legislation will be maintained once the UK has withdrawn from the EU and that similar or equivalent environmental protections will remain in place.

The relationship between the identified PPSs and the Restriction of single-use plastic items placed on the Scottish Market are outlined below.

United Nations (2015): Transforming our World - the 2030 Agenda for Sustainable Development sets out 17 global goals agreed by the United Nations. These goals are embedded within the agenda for 15 years and include commitments to protect the planet through sustainable consumption and sustainable management of resources. Placing market restrictions on specific single-use plastic items and oxo-degradable plastics will support Scotland's efforts toward these global goals by seeking to embed sustainability and resource minimisation across all sectors of society and stimulating a departure from single-use plastic items in Scotland. Key sustainable development goals relevant to market restrictions on single-use plastic items include:

• Goal 12: Ensure sustainable consumption and production patterns
• Goal 13. Take urgent action to combat climate change and its impacts
• Goal 14. Conserve and sustainably use the oceans, seas and marine resources for sustainable development.
• Goal 15. Protect, restore and promote sustainable use of terrestrial ecosystems, sustainably manage forests, combat desertification, and halt and reverse land degradation and halt biodiversity loss.

It is predicted that an increase in paper-based products may have implications on the allocation of land use, as greater areas will be required to grow more trees that will be required to meet demand.

European Union (2008): The EU Waste Framework Directive introduced a definition for waste. The Directive introduced key principles to ensure that waste is managed without endangering human, environmental or ecological health. The Directive also introduced the Waste Hierarchy, the "polluter pays principle" and "extended producer responsibility". It included two new recycling and recovery targets to be achieved by 2020:

• 50% for re-use and recycling of household wastes, and
• 70% for re-use, recycling and other recovery of construction and demolition waste

The Directive requires member states to establish national waste prevention programmes accordingly. Restricting specific single-use plastic items in Scotland will proliferate a reduction in plastic waste in line with Directive targets. The Framework Directive necessitates that member states radically enhance waste management and recycling practices. Restrictions on hard-to-recycle single-use plastic items will have the likely effect of increasing recycling efficiency in Scotland, with resultant positive impacts on waste management. Wood-based products have a shorter degradation period than plastic, however an increase in such products will mean a consequent increase in the woodland required to produce them.

European Union (2018): The EU Action Plan for the Circular Economy details an EU Action Plan for the Circular Economy. The Action Plan provides a context for the restriction of single-use plastic products by requiring member states to radically enhance waste management and recycling practices; to design out waste, to design products with longer use phases and which can be recycled (if not repaired/remanufactured) at end of life. The main aims and provisions of the Plan are outlined within Section 4.1 above.

European Union (2019): Directive on the reduction of the impact of certain plastic products on the environment highlights significant negative environmental, health and economic impacts stemming from the continued use of certain plastic products. The aims and provisions of this Directive are outlined in Section 4.1 (above). In the context of Material Assets, the Directive seeks to instil a greater respect for preservation of resources, and in developing a more circular approach to material use, that sees the need for fewer virgin materials through greater resource efficiency.

UK Government (1990): The Environmental Protection Act seeks to improve resource use and environmental performance through the control of waste collections and management across the UK. The Act designates the regime for licensing of waste operations and provides the first definition of "controlled wastes" (known as Hazardous Wastes in Scotland). The Act introduced the Duty of Care for producers, carriers, importers and exporters, and also introduced criminal offences regarding litter in a bid to reduce littering across the UK. The Act requires the UK to tightly control the movement and handling of wastes.

The Scottish Government (2020): The Scottish Government Programme for Government (2020-21) outlines the Government's commitment to tackle climate change and to prepare Scotland for the new, low carbon world. The main objectives of the Programme are outlined in Section 4.1 (above). The programme seeks to increase recycling rates and stimulate greater resource efficiency and respect for material assets by developing a route map to reduce waste and meet 2025 recycling targets as well as boosting the circularity of the Scottish economy.

Scottish Government (2014): A Marine Litter Strategy for Scotland identified five proposed strategic directions to reach a zero waste Scotland, supported by responsible behaviours. The strategy seeks to address litter within the marine environment between 2013 and 2020. The objectives of the strategy are to enhance current legislation to promote effective clean-up of contaminated areas whilst supporting local and national stakeholders to understand and support litter-free urban areas. The strategy complements the introduction of market restrictions on single-use plastic items as a preventative measure which will help realise the vision of a "clean, healthy, safe, productive and biologically diverse marine and coastal environment that meets the long term needs of people and nature".^[54]

Scottish Government (2014): Toward a Litter free Scotland - The National Litter Strategy (2014) sets clear actions which have an impact upon material assets when seeking to improve the environment through targeted approaches to litter and fly-tipping. The strategy seeks to educate the public to adopt alternative behaviours to waste management through access to improved recycling opportunities, improved product design, awareness campaigns and targeted exploration to tackle litter on beaches. The strategy also proposes exploring enforcement opportunities and identifying pilot solutions to litter. Placing restrictions on specific single-use plastic items will support delivery of these actions and ambitions by limiting the impacts of disposable items and promoting the development of sustainable alternatives.

Scottish Government (2016) Making Things Last - A Circular Economy Strategy is Scotland's first circular economy strategy. The strategy endeavours to set out early priorities to embed the circular economy across key Scottish sectors including manufacturing. It seeks to embed circular economy principles into the manufacturing process, to design materials for reuse, recycling and recovery, whilst embedding a mindset across the public that materials are finite and that current consumptions patterns and reliance on 'single-use' are unsustainable. The Strategy repeats the targets to recycle 70% of all waste and to send no more than 5% of all waste to landfill by 2025. It also reiterates the need to promote a shift away from the prevailing take-make-dispose consumption pattern.

Scottish Government (2013): Safeguarding Scotland's Resources set out the ambition to minimise the resources needed to sustain the market demand for products in Scotland. The document sets out a range of measures to promote efficient use of materials and to reduce waste. A total of 13 actions are proposed to develop baseline evidence for circular economy opportunities, to influence behaviours, enhance the design of products and packaging, and to support businesses to prevent, manage and benchmark wastes.

Scottish Government (2013): Scotland's Zero Waste Plan set out the Scottish Government's spearhead strategy to make the most of resources and to reduce, reuse and recycle more materials in Scotland. Measures to achieve the vision include using separate collections of specific waste types, increasing reuse and recycling opportunities and introducing new recycling targets of 70% of all waste recycled by 2025 and a maximum of 5% of all waste to landfill by 2025. The Zero Waste Plan is the flagship policy for Scotland's waste ambitions. The market restriction of single-use plastics will have the likely impact of stimulating greater recycling and reuse as well as stimulating a significant reduction in plastic waste levels in Scotland.

Scottish Enterprise (2016): A Manufacturing Future for Scotland details a series of interventions to be adopted which will help nurture further growth across the manufacturing sector. The strategy seeks to support companies to reap the benefits of the circular economy through the opportunities linked to product design, manufacturing processes and supply chains. The strategy seeks to eradicate waste through innovation in product design and remanufacturing. The market restriction of single-use plastics can support the strategy by incentivising manufacturers to design products consistent with the vision of a more sustainable, resource-efficient Scotland.

Scottish Government (2014): The Scottish National Planning Framework and Scottish Planning Policy are two documents which promote waste as a resource. The framework and the planning policy recognise the need to appreciate the value of waste, and the role it plays in a more circular economy. Of particular note, the Scottish Planning Policy (para 175) recognises that "waste is a resource and an opportunity, rather than a burden. Scotland has a Zero Waste Policy, which means wasting as little as possible and recognising that every item and material we use, either natural or manufactured, is a resource which has value for our economy.' Materials with a high intrinsic value and which may be reused; such as renewable sustainable bio-based, or re-usable products that may replace single-use plastic products; would stimulate even greater resource efficiency within Scotland.

Scottish Government (2011): The first land use strategy for Scotland, Getting the best from our land - A land use strategy for Scotland (2011)) had the objectives of: land-based businesses working with nature; responsible stewardship of Scotland's natural resources; and urban and rural communities better connected to the land. The vision, objectives and principles of the strategy were retained and built upon by the second land use strategy (published 2016) which covers the period 2016 - 2021. The Strategy promotes the need to utilise resources sustainably and aligns clearly with the objectives underpinning the market restriction on single-use plastics with regard to preservation of material assets.

Scottish Government (2018): Climate Change Plan - The Third Report on Proposals and Policies 2018-2032 provides a progress update on the Governments Climate Change Plan. the main provisions of the plan are outlined in Section 4.1 (above). Restrictions on single-use plastic products within the Scottish market will promote less linear consumption models, stimulating the expansion of more circular practices, products and procedures in-line with the Plan. It will also improve recyclate quality through reduced contamination in other secondary streams.

5.2 Baseline Characteristics

This section of the Environmental Report identifies and characterises current environmental baseline conditions for material assets and evaluates how these baseline conditions are likely to change due to the introduction or proposed market restrictions on single-use plastic items in scope.

As detailed in the section introduction, the scope of "built assets and natural assets" is defined within this Environmental Report, as:

• Natural assets - collected waste materials and waste stream;
• Natural assets - raw source of compositional materials of alternative non-plastic single-use items and any raw materials used to support waste infrastructure;
• Built assets - land take and soil use/loss for new infrastructure;
• Built assets - any new infrastructure required for managing waste generated by alternative options.

5.2.1 Current Resource Use, Waste Management and Disposal of Materials Relevant to the SUP Directive

Our analysis estimates that the total number of single-use plastic items targeted by the Directive is around 777 million items with a total weight of approximately 2,100 tonnes.

Figure 5‑2 shows a breakdown of single-use plastic waste generated by item.

5.2.2 Current Infrastructure Associated with Waste Management

The majority of single-use plastic items are not recyclable and hence are either landfilled or incinerated. The total amount of single-use plastic waste generated is approximately 2,850 tonnes which is considered an insignificant proportion when compared to other waste streams and does not have a significant impact on the available capacity in existing infrastructure.

5.2.3 Predicted Future Trends in Relation to Scottish Government Waste Targets

The amount of single-use plastic waste is not deemed to have significant impacts on Scottish Government Waste Targets. Due to the heavier nature of alternative products, and assuming 100% replacement, the proposed market restrictions could result in more waste (approximately 1,440 tonnes, +70%) being generated, which would have a minor impact on Scotland's waste reduction target (See Table 5‑1).

5.2.4 Likely Evolution of the Baseline without the SUP Directive

Without the proposed market restriction of single-use plastic items, it is expected that the prevalence of such products may still contract, although to a far smaller degree than if restrictions were implemented. This is due to many commercial entities opting to move away from single-use plastics generally, both to enhance their green credentials and for the protection of the environment. Such moves are taking place on an ad hoc, individual basis and so the effect of such measures would be far less reaching than a statutory restriction. Without a blanket restriction, the current volume of plastic waste in Scotland would be likely to continue, along with attendant emissions surplus and litter levels This in turn would have significant detrimental effects on the Scottish landscape, the Scottish environment, resource efficiency and the territorial and outsourced emissions produced.

5.3 Consideration of Reasonable Alternatives

5.3.1 Methodology

Changes in the amount of waste generated due to the adoption of non-plastic alternatives are estimated using market research data and average weight assumptions discussed in Section 4.3.1.

5.3.2 Results

The assessment considers the anticipated changes to the material demand for producing single-use plastic items and waste generated (Table 5‑1).

Single-use plastic items are lightweight and hence the total amount of virgin materials is deemed to be insignificant when compared to other waste streams (i.e., 2850 tonnes). However, their negative environmental impacts on marine and wildlife are significant due to leakages and litter, hence the proposed market restrictions.

Table 5‑1 Total amount of waste generated by SUP items and alternative options.

Measure No	Single-use plastic item in scope	Waste generated (tonnes)		Difference (tonnes)	Change (%)
		Single-use plastics	Alternative option
1	Cutlery	720	830	110	15%
2	Plates	500	950	450	90%
3	Beverage Stirrer	10	20	10	100%
4	Straws	170	320	150	88%
5	Balloon sticks	10	20	10	100%
6	Food containers made of expanded polystyrene	330	660	330	100%
7	Cups and beverage containers made of expanded polystyrene	120	500	380	317%
8	Oxo-biodegradable HDPE	230	230	-	0%
Total		2,090	3,530	1,440	69%

Built assets include waste infrastructure which facilitates the collection, reprocessing and/or disposal of the materials as a waste. The scope includes the land used and loss of habitats therein.

The key to each assessment score is shown below:

Score Key:

++ : Significant positive effect
+ : Minor positive effect
0 : No overall effect
- : Minor negative effect
-- : Significant negative effect
? : Score uncertain

NB: where more than one symbol is presented in a box it indicates that the SEA has found more than one score for the category. Where the scores are both positive and negative, the boxes are deliberately not coloured (i.e. 'no overall effect'). Where a box is coloured but also contains a "?" this indicates uncertainty over whether the effect could be a minor or significant effect although a professional judgement is expressed in the colour used. A conclusion of uncertainty arises where there is insufficient evidence for expert judgement to conclude an effect.

Measure No 1

Material/item to be restricted: Plastic cutlery

The alternative option: Wooden cutlery

Notes:

SEA criteria: Will it contribute towards achieving Scotland's waste targets?

Score: Minor positive effect / Score uncertain

Commentary: The weight of wooden cutlery is expected to be 15% higher than the plastic option (110 tonnes/year). Nevertheless, there is a possibility to collect wooden cutlery for composting which would consequently contribute to Scotland recycling targets. This is subject to the availability of infrastructure to collect and manage waste, and changes in people's attitudes to put single-use wooden items in the right bin.

No additional built infrastructure is required to manage waste generated by the non-plastic single-use alternative.

SEA criteria: Will it increase the economic value and utility of affected materials?

Score: No overall effect

Commentary: We do not expect this measure to increase the economic value and utility of affected materials.

SEA criteria: Will it reduce 'leakage' of material to landfill or energy recovery or as litter?

Score: Minor positive effect / Score uncertain

Commentary: Yes, wooden cutlery is compostable and can contribute to Scotland's recycling targets, subject to the availability of infrastructure to collect and manage this waste stream.

Measure No 2

Material/item to be restricted: Plastic plates

The alternative option: Wax-coated paper plates

Notes:

SEA criteria: Will it contribute towards achieving Scotland's waste targets?

Score: Minor positive effect / Score uncertain

Commentary: The weight of wax-coated paper plates is expected to be 90% higher than the plastic option (450 tonnes/year) which will increase the amount of waste generated. However, there is a possibility to collect wax-coated paper plates for composting which would consequently contribute to Scotland recycling targets. This is subject to the availability of infrastructure to collect and manage waste, and changes in people's attitudes to put wax-coated paper plates in the right bin.

No additional built infrastructure is required to manage waste generated by the non-plastic single-use alternative.

SEA criteria: Will it increase the economic value and utility of affected materials?

Score: No overall effect

Commentary: We do not expect this measure to increase the economic value and utility of affected materials.

SEA criteria: Will it reduce 'leakage' of material to landfill or energy recovery or as litter?

Score: Minor positive effect / Score uncertain

Commentary: Yes, paper plates are compostable and can contribute to Scotland's recycling targets, subject to the availability of infrastructure to collect and manage this waste stream.

Measure No 3

Material/item in scope: Plastic beverage stirrer

The alternative option: Wooden stirrer

Notes:

SEA criteria: Will it contribute towards achieving Scotland's waste targets?

Score: Minor positive effect / Score uncertain

Commentary: The weight of a wooden stirrer is expected to be 100% higher than the plastic option (10 tonnes/year) which will increase the amount of waste generated. However, there is a possibility to collect wooden stirrers for composting which would consequently contribute to Scotland recycling targets. This is subject to the availability of infrastructure to collect and manage waste, and changes in people's attitudes to put single-use wooden items in the right bin.

No additional built infrastructure is required to manage waste generated by the non-plastic single-use alternative.

SEA criteria: Will it increase the economic value and utility of affected materials?

Score: No overall effect

Commentary: We do not expect this measure to increase the economic value and utility of affected materials.

SEA criteria: Will it reduce 'leakage' of material to landfill or energy recovery or as litter?

Score: Minor positive effect / Score uncertain

Commentary: Yes, wooden stirrers are compostable and can contribute to Scotland's recycling targets, subject to the availability of infrastructure to collect and manage this waste stream.

Measure No 4

Material/item in scope: Plastic straws

The alternative option: Wax-coated paper straws

Notes:

SEA criteria: Will it contribute towards achieving Scotland's waste targets?

Score: Minor positive effect / Score uncertain

Commentary: The weight of wax-coated paper straws is expected to be 88% higher than the plastic option (150 tonnes/year) which will increase the amount of waste generated. However, there is a possibility to collect wax-coated paper straws to be composted with food waste which would consequently contribute to Scotland recycling targets. This is subject to the availability of infrastructure to collect and manage waste, and changes in people's attitudes to put single-use paper straws in the right bin.

No additional built infrastructure is required to manage waste generated by the non-plastic single-use alternative.

SEA criteria: Will it increase the economic value and utility of affected materials?

Score: No overall effect

Commentary: We do not expect this measure to increase the economic value and utility of affected materials.

SEA criteria: Will it reduce 'leakage' of material to landfill or energy recovery or as litter?

Score: Minor positive effect / Score uncertain

Commentary: Yes, wax-coated paper straws are compostable and can contribute to Scotland's recycling targets, subject to the availability of infrastructure to collect and manage this waste stream.

Measure No 5

Material/item in scope: Plastic balloon sticks

The alternative option: Cardboard balloon sticks

Notes:

SEA criteria: Will it contribute towards achieving Scotland's waste targets?

Score: Minor positive effect / Score uncertain

Commentary: The weight of cardboard balloon sticks is expected to be 100% higher than the plastic option (10 tonnes/year) which will increase the amount of waste generated. However, there is a possibility to collect cardboard balloon sticks to be composted with food waste which would consequently contribute to Scotland recycling targets. This is subject to the availability of infrastructure to collect and manage waste, and changes in people's attitudes to put cardboard balloon sticks in the right bin.

No additional built infrastructure is required to manage waste generated by the non-plastic single-use alternative.

SEA criteria: Will it increase the economic value and utility of affected materials?

Score: No overall effect

Commentary: We do not expect this measure to increase the economic value and utility of affected materials.

SEA criteria: Will it reduce 'leakage' of material to landfill or energy recovery or as litter?

Score: Minor positive effect / Score uncertain

Commentary: Yes, cardboard balloon sticks are compostable and can contribute to Scotland's recycling targets, subject to the availability of infrastructure to collect and manage this waste stream.

Measure No 6

Material/item in scope: Food containers made of expanded polystyrene

The alternative option: Wax-coated cardboard boxes

Notes:

SEA criteria: Will it contribute towards achieving Scotland's waste targets?

Score: Minor positive effect / Score uncertain

Commentary: The weight of wax-coated cardboard boxes is expected to be 100% higher than the plastic option (330 tonnes/year) which will increase the amount of waste generated. However, there is a possibility to collect cardboard balloon sticks to be composted with food waste which would consequently contribute to Scotland recycling targets. This is subject to the availability of infrastructure to collect and manage waste, and changes in people's attitudes to put wax-coated cardboard boxes in the right bin.

No additional built infrastructure is required to manage waste generated by the non-plastic single-use alternative.

SEA criteria: Will it increase the economic value and utility of affected materials?

Score: No overall effect

Commentary: We do not expect this measure to increase the economic value and utility of affected materials.

SEA criteria: Will it reduce 'leakage' of material to landfill or energy recovery or as litter?

Score: Minor positive effect / Score uncertain

Commentary: Yes, wax-coated cardboard boxes are compostable and can contribute to Scotland's recycling targets, subject to the availability of infrastructure to collect and manage this waste stream.

Measure No 7

Material/item in scope: Cups and beverage containers made of expanded polystyrene^[55]

The alternative option: Plastic-coated paper cups

Notes:

SEA criteria: Will it contribute towards achieving Scotland's waste targets?

Score: Minor negative effect

Commentary: The weight of plastic-coated paper cups is expected to be 317% higher than the plastic option (380 tonnes /year) which will increase the amount of waste generated. What's more, a recent report by Scotland's Expert Panel on Charges and Other Measures^[56] states that only 2% of single-use paper cups are recycled in Scotland, with the majority either landfilled or incinerated.

If EPECOM's recommendation to put in place a charge on single-use cups is taken forward, this could significantly reduce consumption and so the overall environmental impacts of this product category.

SEA criteria: Will it increase the economic value and utility of affected materials?

Score: No overall effect

Commentary: We do not expect this measure to increase the economic value and utility of affected materials.

SEA criteria: Will it reduce 'leakage' of material to landfill or energy recovery or as litter?

Score: No overall effect

Commentary: No, switching from EPS cups to paper cups without the availability of recycling infrastructure and behaviour change will not reduce the amount of single-use cups landfilled or incinerated.

Measure No 8

Material/item in scope: Oxo-degradable HDPE

The alternative option: Conventional HDPE

Notes:

SEA criteria: Will it contribute towards achieving Scotland's waste targets?

Score: No overall effect

Commentary: Switching form oxo-degradable to conventional plastic is not expected to have any impact on the amount of waste generated nor recycled as both types of plastic are not widely recycled in Scotland.

No additional built infrastructure is required to manage waste generated by the non-plastic single-use alternative.

SEA criteria: Will it increase the economic value and utility of affected materials?

Score: No overall effect

Commentary: We do not expect this measure to increase the economic value and utility of affected materials.

SEA criteria: Will it reduce 'leakage' of material to landfill or energy recovery or as litter?

Score: No overall effect

Commentary: No, switching from Oxo-degradable HDPE to Conventional HDPE without the availability of recycling infrastructure will not reduce the amount of HDPE plastics landfilled or incinerated.

5.4 Mitigation and Enhancement

Single-use plastic items targeted by market restrictions are expected to be replaced by heavier single-use items made of paper or wood. This will lead to a shift in materials used from fossil-based materials to wood or paper which will require additional land and water resources. There are some non-plastic alternatives which are not recyclable and hence will end up landfilled or incinerated. This can be best addressed through greater application of multi-use items and particularly for frequently used items such as plates and cups. Other recyclable alternatives, primarily made of wood or fibre, can be composted and so it would be imperative to increase access to and use of appropriate recycling infrastructure to ensure the capture of these materials for recycling.

More importantly, additional measures should be considered in order to reduce the generation of non-plastic single-use items and incentivise behavioural change towards the adoption of multi-use alternatives.