Packaging - extended producer responsibility: equality impact assessment

Stage 2: Data and evidence gathering, involvement and consultation

This section includes the results of the evidence-gathering (including the framing exercise), including qualitative and quantitative data and the source of that information, whether national statistics, surveys or consultations with relevant equality groups.

Age

Recycling behaviours & perception of climate change

In surveys of household attitudes and behaviours associated with recycling and waste, older people are more likely to be highly motivated to recycle. 68% of people aged 65+ describe themselves as "wanting to be a really good recycler", compared to 56% aged 35-64, and 51% aged 18-34. Differences in recycling behaviours and perceptions towards climate change, suggests a requirement for targeted communications for different age groups.^[36]

Young people are more likely to be very concerned about climate change, with 26% of young adults (aged 16-24) viewing climate change as an immediate and urgent problem, whereas only 76% of those aged 75+ view it as urgent. However, this age group showed the greatest increase from 69% in 2020 to 76% in 2021.^[37]

Younger people also claim to be more informed about climate change: almost 70% or 18-24 stated they knew a lot about climate change compared to just 53% of those over 65. The source of information for these age groups differs significantly with social media accounting for 66% of 18-24 year-olds, but just 23% of 65+. Older age groups receive the majority of this information from TV (64%).^[38]

Data gaps identified and action taken

Should be considered as part of the service design at local authority level.

Inclusive communications

If communications are only available via digital means, older adults may not be aware of changes to services to the same extent as younger groups.

Older people are less likely to be internet users: 76% of adults 60+ use the internet compared to 99% of 16-24. This is a significant increase for 60+ from previous years (29% in 2007). Of disabled adults aged 60+, 66% reported using the internet, compared with 81% of non-disabled adults aged 60+. ^[39]

Therefore, there may be a requirement for suitable forms of non-digital communication for older people.

Conversely young people are highly likely to use the internet and may therefore benefit from digital communications.

The Scottish Government will continue to work with the other administrations to ensure inclusive communication methods and channels are considered through policy implementation.

Poverty

In 2020-23, 39% of people in households with household heads aged 16-24 were in relative poverty after housing costs. Those aged 55-64 were the next most likely to be in poverty. The age groups in between all had similar poverty rates between 17% and 21%.^[40]

Data gaps identified and action taken

See discussion in the Fairer Scotland Duty Assessment.

Disposable Income

Average equivalised household disposable income, across the UK, by age group of the chief economic supporter (CES) for 2021/22 was lowest in the 16-24 age group (£27,596 per year). Disposable income for other age groups ranging from £31,085 (65+) to £40,926 (25-34). This shows that the youngest and oldest are most likely to have the least disposable income. ^[41]

Any potential cost pass through associated with the reform could therefore impact on young adults more than other age groups.

Disability

Inclusive labelling format and communications

Labelling and communications associated with packaging EPR should be accessible to visually impaired people and persons with learning disabilities.

In Scotland 27% of the population have a long-term physical or mental health condition (1.5 million people). This is above the UK average (24%).^[42]

Neurodivergent individuals and individuals with learning disabilities who require communication support often encounter extensive exclusion and disadvantages. Employing inclusive communication is crucial as it acknowledges that diverse individuals use various methods to comprehend and express themselves. The use of inclusive communication is imperative to enable individuals to be aware of and assert their rights, live autonomously, and actively engage in all aspects of life. ^[43]

People with limiting conditions are also less likely to use the internet. In Scotland, 14% of adults aged 34-59 years who have some form of limiting long-term physical or mental health condition, do not use the internet. This increases to 34% for those over 60. This is a significantly higher share than for those who do not have a disability for both adults (2%) and over 60s (19%). This suggests a requirement for suitable forms of non-digital communication.^[44]

Data gaps identified and action taken

Should be considered as part of the service design at local authority level.

Labelling requirements on packaging will be picture-based and easily recognisable. The Scottish Government will continue to work with the other administrations to ensure inclusive communication methods and channels are considered through policy implementation.

Poverty

Scottish national statistics show that 24% of households where a household member is disabled are more likely to be in relative poverty compared to 18% of households where no one is disabled.^[45]

On average, households with at least one disabled adult or child need an additional £975 a month to have the same standard of living as households where this is not the case. The average extra costs rise to £1,248 per month where there are two disabled adults in the household and at least two children. On average, the extra costs required to enjoy the same standard of living as a non-disabled person equates to 63% of a disabled person's income after housing costs.^[46]

Data gaps identified and action taken

See discussion in the Fairer Scotland Duty Assessment.

Sex

Poverty

In 2020-23, analysis of poverty rates in Scotland showed 19% of women and 20% of men were in relative poverty after housing costs. Poverty is typically measured at the household level so families/couples are typically assessed together. For lone-person or single-parent families this can be further analysed.

Historically, poverty rates were highest for single mothers, but this has gradually declined to be comparable with other single household types. In 2020-2023, poverty rates were highest among single, childless men (33%). The poverty rate for single, childless women and single mothers was the same at (29%). Estimates for single fathers were not available.^[47]

Research into poverty in Scotland in 2023 showed that just over 10% of workers in Scotland are locked in persistent low pay (below the real living wage), with 72% of those people being women. ^[48]

Data gaps identified and action taken

See discussion in the Fairer Scotland Duty Assessment. The "Poverty and income inequality in Scotland: 2020-2023" research has identified gaps in the data regarding poverty rates in these groups.

Pregnancy and Maternity

We are not aware of any relevant existing evidence at this time on pregnancy and maternity in relation to the policy.

Data gaps identified and action taken

No impacts identified.

Gender Reassignment

We are not aware of any relevant existing evidence at this time on pregnancy and maternity in relation to the policy. No impacts identified.

Data gaps identified and action taken

No impacts identified.

Sexual Orientation

Poverty

The poverty rate has been consistently higher for LGB+ adults compared to straight / heterosexual adults since this category was first assessed in 2011-14.

In 2020-23, 25% of LGB+ adults were in poverty, compared to 19% of straight adults and 21% of adults whose sexual orientation was not known. ^[49]

Data gaps identified and action taken

See discussion in the Fairer Scotland Duty Assessment.

Race

Inclusive communications

More than 170 languages other than English are spoken in homes across Scotland. In the 2011 Census, 93.8% of people in Scotland aged 3+ stated they could speak, read and write English compared to 75.2% of people born in EU accession countries and 88.8% of people born in the Middle East and Asia. ^[50]

Polish was the most commonly spoken language in Scotland after English, Scots and Gaelic.

The most commonly spoken languages at home other than English and Scots were:

• Polish (54,186 people)
• Urdu (23,394 people)
• Punjabi languages (23,150 people)
• Chinese languages (16,830 people)
• French (14,623 people)

This suggests any changes to services and communications associated with reforms should be made accessible in multiple languages.

Data gaps identified and action taken

Should be considered as part of the service design at local authority level.

Labelling requirements on packaging will be picture-based and easily recognisable.

Poverty

In 2010-23, people from minority ethnic (non-white) groups were more likely to be in relative poverty after housing costs compared to those from the 'White - British' and 'White - Other' groups.

The poverty rate was 50% for the 'Asian or Asian British' ethnic groups and 51% for 'Mixed, Black or Black British and Other' ethnic groups. The poverty rate amongst the 'White - Other' group was 22% and that of the 'White - British' group was 18%.^[51]

Data gaps identified and action taken

See discussion in the Fairer Scotland Duty Assessment.

Disposable Income

The mean equivalised household disposable income, across the UK, by ethnicity for 2019/21 was lowest in the Black African, Black Caribbean and Black Other ethnic group categories (£31,633 per year). Mixed (£33,886 per year) and Other (£35,916 per year) ethnic groups were the next lowest, with Asian (£36,454 per year) and White (£36,660 per year) having the highest disposable income. ^[52]

Any potential cost pass-through associated with packaging EPR could therefore impact on Black ethnic minority groups more than other groups.

Data gaps identified and action taken

See discussion in the Fairer Scotland Duty Assessment.

Religion or Belief

Poverty

In 2017-22, Muslim adults were more likely to be in relative poverty (63%, 40,000 each year) than adults overall (19%), after housing costs were taken into account. For adults belonging to the Church of Scotland, 16% were in relative poverty after housing costs (170,000 adults each year), compared to 19% of Roman Catholic adults (110,000 adults) and adults of other Christian denominations (19%; 60,000 adults). ^[53]

Though this appears to infer a relationship between religion and socio-economic disadvantage, this may be further related to race rather than religion, as detailed above.

Data gaps identified and action taken

See discussion in the Fairer Scotland Duty Assessment.

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.