Market restrictions on single-use plastic items: consultation analysis

6 Environmental, economic and social impacts (Q6)

6.1 As noted in Chapter 1, the main consultation paper was accompanied by five separate impact assessment reports: an environmental impact assessment, a business and regulatory impact assessment, an equalities impact assessment, a 'fairer Scotland duty' impact assessment and an island communities impact assessment. Question 6 in the consultation asked respondents for their views on any additional environmental, economic or social impacts that might to arise from the proposed market restrictions:

Question 6: Taking into account the accompanying Impact Assessments, can you identify any environmental, economic or social impacts we have not identified when developing the proposals contained in this consultation? [Yes / No]

Please give reasons.

6.2 As also noted previously, the environmental report contained five additional questions which respondents could answer on the environmental impact of the proposals. The analysis of these questions has been undertaken separately and the findings will be reflected in the final versions of the relevant impact assessments.

6.3 Table 6.1 shows that, overall, 27% of respondents said they had identified environmental, economic or social impacts in addition to those identified in the impact assessments accompanying the consultation paper. However, organisations were more likely than individuals to identify additional impacts (48% vs 25% respectively).

Table 6.1: Q6 – Can you identify any environmental, economic or social impacts we have not identified in the accompanying impact assessments?

	Yes		No		Total
Respondent type	n	%	n	%	n	%
Environmental charities, third sector and community sector organisations	13	52%	12	48%	25	100%
Packaging manufacturers and other types of manufacturing organisations	10	83%	2	17%	12	100%
Food, drink, tourism and other business organisations	3	38%	5	63%	8	100%
Public sector organisations	1	9%	10	91%	11	100%
Environmental consultancies and resource management organisations	2	40%	3	60%	5	100%
Other organisations	1	50%	1	50%	2	100%
Total organisations	30	48%	33	52%	63	100%
Total individuals	153	25%	467	75%	620	100%
Total (organisations and individuals)	183	27%	500	73%	683	100%

Percentages may not total 100% due to rounding.

6.4 A total of 253 respondents – 52 organisations and 201 individuals – provided comments at Question 6.

6.5 The sections below look in turn at comments on environmental, economic and social impacts. In the main, the comments made were general in nature, and often reflected on the perceived impacts – both positive and negative – related to current or proposed arrangements, without addressing any specific identified gaps in the impact assessments. As far as possible, issues are discussed only once although there was a great deal of overlap and inter-linkages in the points raised by respondents in relation to environmental, economic and social impacts.

6.6 A final section looks at comments from those who did not identify any further impacts.

Environmental impacts

6.7 There were two main themes in the comments focused on environmental impacts. These related to (i) the environmental impact of alternatives to single-use plastics, and (ii) littering. Each of these topics are discussed below.

The environmental impact of alternatives to single-use plastics

6.8 Respondents of all types were concerned about the environmental impact of alternatives to single-use plastics and whether the full life-cycle impact of different materials had been accounted for in the assessments undertaken. However, there were two somewhat different perspectives on this issue, as follows.

6.9 A first group of respondents – mainly environmental charities, third sector and community organisations and individuals – expressed a concern about the proposed market restrictions resulting in a shift away from single-use plastics to single-use items made from other materials which still incurred environmental costs in production, distribution and disposal, and in littering and pollution (the related financial costs in responding to this latter issue were also noted). A potential shift to materials (including mixed materials) which were hard to recycle, and a current lack of infrastructure to deal with wooden or other potentially compostable materials were both noted.

6.10 In terms of the environmental assessment carried out, respondents raised three specific concerns related to (i) the scenario analysis based on single-use plastic and other single-use materials; (ii) the assumption that incineration would be used to deal with waste associated with alternatives to single-use plastics, and the failure to account for the environmental impact of this process, and (iii) the difficulty in 'reconciling' the differing quantitative and qualitative methods used for different elements of the analysis.

6.11 More generally, respondents called for a shift to greater sustainability, with an increased emphasis on multi-use rather than single-use items, which was seen as more in keeping with a 'green' or 'circular' economy. There were other suggestions for a focus on materials for which effective recycling streams were available, or for market restrictions on single-use plastic items to incorporate clear criteria for alternative materials.

6.12 A second group of respondents – mainly those from the packaging and manufacturing sectors and food, drink, tourism and other business sectors as well as some individuals – also highlighted the need to assess the full environmental impact of alternatives to single-use plastics, and the items under consideration for market restrictions. They argued, for example, that non-plastic single-use items used raw materials and resources in their production and were generally heavier and bulkier to transport than their plastic counterparts, that the washing of re-usable items involved an environmental cost, that re-fillable containers were not always re-used often enough to bring any overall environmental benefits, or that substituting 'carton and straw' products with bottles would increase the overall carbon emissions associated with these products. Respondents making these points said that such factors had to be taken into account in any environmental assessment. Additionally, there was a specific concern about perceived inconsistencies in the SEA calculations relating to the carbon impact of single-use cups of different materials.

6.13 Some respondents argued that oxo-biodegradeable or plant-based items were less environmentally damaging and should be exempt from the proposed market restrictions. It was argued (by a respondent from the 'other' organisational category) that the impact assessment had not taken account of the potential increase in food waste going to landfill if compostable catering items and food remains could no longer be disposed of together.

Positive environmental impacts

6.14 In a few cases individuals, in particular, noted positive impacts that they thought would accrue from the proposed changes in terms of benefits to the natural environment and wildlife, and improved wellbeing of communities. Respondents in this group argued that long-term environmental gain should be valued over short-term economic gain, and stressed the importance of protecting the environment for the future.

Littering

6.15 One environmental issue discussed by a wide range of respondents was that of littering (including marine littering). Littering was noted as a significant issue, in urban and rural as well as coastal areas, which had negative impacts on the quality of outdoor spaces, wildlife and biodiversity and the tourism industry. There was a view that the positive effects of reduced littering, and the cost savings to the economy as a whole related to cleaning up rivers and oceans needed to be accounted for.

6.16 However, respondents often also said that getting rid of single-use plastic would not in itself resolve the current issue of litter, particularly if single-use plastic items were simply replaced with single-use items made of other materials. It was, though, occasionally argued that biodegradable products and materials such as wood and paper would offer some benefit in this respect in that they broke down in the environment more quickly than plastics.

6.17 Respondents said that specific action was required to address littering and poor waste disposal practices and bring about widespread behaviour change among the public, with suggestions including awareness raising and education campaigns, aimed at the general public and children, increased provision of bins and on-the-go recycling facilities, greater enforcement activity in terms of patrols, fines, etc.

6.18 Some also said that the current proposals for market restrictions would also not address the issue of marine pollution related to fishing equipment.

6.19 Respondents sometimes noted items other than single-use plastics that contributed to littering and had a negative impact on the environment. A specific issue raised by some packaging and manufacturing organisations was that of chewing gum. This was seen as a major contributor to littering, with respondents arguing that an EPR-type scheme might provide a mechanism for tackling this issue. Other issues mentioned included fly-tipping and dog fouling.

Economic impacts

6.20 Respondents discussed a range of economy and business-related issues in their comments at Question 7. These largely related to the business opportunities presented by the proposals and a broader shift toward a 'greener' economy; the challenges for businesses and small businesses in particular; the need for support for businesses in implementing the proposed changes; the role and influence of 'big business' in achieving change; and the global economy. Each of these are discussed briefly below.

Business opportunities presented by the proposals

6.21 Individuals and environmental charities, third sector and community organisations highlighted the economic and business opportunities presented by the proposed market restrictions and a more general transition to a green economy. Respondents said, for example, that:

• There were marketing opportunities for small businesses that embraced the proposed changes.
• Research and development and manufacturing related to alternative materials to replace single-use plastics, and the development of return and reuse systems, would create jobs and bring benefits to the economy. There was a specific call for the BRIA to give full consideration to re-usable as well as alternative single-use options.
• Any initial increase in costs would be reduced over time.

6.22 More generally, it was common for respondents in this group to say that a move to a more circular economy, and an improved recycling / re-use infrastructure would provide a range of opportunities for businesses in Scotland.

Business challenges presented by the proposed changes

6.23 In contrast to the points noted above, respondents (mainly food, drink, tourism and other business organisations; packaging manufacturers and other manufacturing organisations; and some individuals) expressed concerns about the anticipated costs for businesses, and small businesses in particular, in adapting to the proposed changes. It was argued that businesses involved in the plastics supply chain would face significant losses, or challenges in adjusting their businesses, and this, in turn, would impact on those employed in these sectors. It was also said that business users of single-use plastic items would face higher costs because the alternatives would be more expensive, or that new systems would incur additional costs; that there would be additional bureaucracy and complexity related to recycling requirements; and that there may also be a loss of revenue related to the sale of bio-waste if compostable materials were covered by the restrictions. Some also expressed concerns about the impact on business diversity if restrictions on catering items made some businesses and premises non-viable.

6.24 There was some specific concern expressed about the restrictions extending to compostable items, the impact that this would have on manufacturers in this field, and calls for clarity on this for businesses that had opted to use such items for environmental reasons.

6.25 Respondents also said that this was a difficult time for many businesses – particularly those in the hospitality and catering sectors – because of the impacts related to Covid and the uncertainties relating to Brexit, and that further changes at this time would add to the challenges currently faced.

6.26 Occasionally, respondents said that there had been insufficient consideration of the impact on businesses. There were also specific calls for (i) impact assessments to take account of the reduction in food waste and corresponding increase in landfill waste if compostable items were no longer allowed in the catering sector (suggested by an 'other' organisation), and (ii) a comprehensive BRIA for small businesses (suggested by a respondent in the food drink and tourism and other business grouping).

The need for support for businesses in implementing change

6.27 There was a range of calls for (i) appropriate information and support (including financial) to be made available to businesses, and (ii) appropriate timescales and transition arrangements for the implementation of any market restrictions. This was needed to assist businesses in the plastics sector in making necessary changes, and to allow businesses in other sectors to use up existing stock, source alternative products and make the necessary changes to their operating systems. This was an issue for public sector organisations as well as commercial businesses. A 6-month transition period was suggested by respondents in the manufacturing sector, whereas one food, drink, tourism and other business organisation respondent called for a 2-year lead to assist with product development.

The role of 'big business'

6.28 Environmental charities, third sector organisations and community groups and some individuals highlighted the role of 'big business' (including oil companies, manufacturers and supermarkets) in setting market trends and influencing consumer behaviour and the need to tackle any 'vested interests' that might be opposed to the proposed changes. Respondents noted that legislation would force all businesses to adhere to the same standards. This would create a 'level playing field', making sure that smaller environmentally conscious businesses were not at a disadvantage, and removing the onus from consumers to make good choices.

The global economy

6.29 Respondents made a number of points regarding the implications of the proposals in the context of a modern global economy. In particular, packaging manufacturers and other manufacturing organisations noted the advantages of harmonisation with the rest of the UK and / or other European countries with regard to the approach taken to restricting single-use plastics, and the disadvantages for businesses should Scotland choose to deviate from practices elsewhere. One particular issue raised was the potential for lost export opportunities if the manufacture of oxo-biodegradeable products were banned in Scotland but not banned elsewhere.

6.30 Other points made by individuals included, for example:

• The potential for people to avoid any restrictions by buying items overseas
• The need to ensure that Scotland does not export oil to other countries to feed the plastics industry.

6.31 The point was also made that single-use plastic is a global issue and any action taken by Scotland could not, on its own, address the problem.

Social impacts

6.32 There were three main themes in the comments relating to social impacts: (i) the impact on health and wellbeing, (ii) the financial impact on individuals, and (iii) the impact on equality groups. Each of these are discussed below.

Health and wellbeing

6.33 Environmental charities, third sector and community sector organisations and some individuals said that the proposals would lead to reduced littering and pollution, enhanced outdoor spaces and positive behaviour change, and that this, in turn, would offer benefits in terms of mental and physical wellbeing and quality of life. It was also argued (by environmental charities, third sector and community sector organisation respondents) that the negative impact on health linked to micro-plastics entering the food chain, and the health benefits of reducing single-use plastics needed to be properly valued and accounted for in the various impact assessments, although the challenges in doing so were acknowledged.

6.34 Less often, packaging manufacturers and other types of manufacturing organisations and some individuals said that the health and hygiene benefits of single-use items (in commercial and healthcare settings) should be considered.

Financial impact on individuals

6.35 Individuals and some organisations (including packaging manufacturers and other types of manufacturing organisations) were concerned that the proposals would reduce choice and increase costs for consumers, and that this would have the greatest impact on the poorest and most vulnerable in society. (Financial pressures created by Covid were also noted in this context.) Although some said a shift to reusable products would bring long-term savings, others urged that steps should be taken to ensure that individuals were not financially disadvantaged,

The impact on equality groups

6.36 Some respondents – including both individual and organisations – stressed the need to take account of the differential impact of the proposals on different groups, and to engage fully with relevant groups (women, disabled people, those who are socially disadvantaged) in any further policy development work.

No additional impacts identified

6.37 Around a fifth of those who commented ticked 'no' at the closed question indicating that they did not identify any additional environmental, economic or social impacts not already covered. These respondents offered three main types of comments with regard to the impact assessments:

• Some endorsed or expressed agreement with the impact assessments carried out, describing them as thorough, comprehensive, and covering all necessary impacts.
• Some noted concerns about the assessments which were similar to those raised by other respondents, related to, for example:
  • The impact on particular groups such as low-income families, people who were socially disadvantaged, disabled people, and women – there was a specific call for equality impact assessments and appropriate consultation to be carried out for each item considered for market restrictions
  • The impact on businesses (and smaller businesses in particular), and the challenges related to additional costs incurred as a result of the proposed market restrictions.
• Some did not make any substantive comment, simply saying they did not know of, or had not identified, any additional impacts, or that they did not feel qualified to comment in detail. Additionally, some respondents said they did not have access to the impact assessments referred to in the question.

6.38 Finally, some respondents used their comments to reiterate their support for the policy proposals, the general 'direction of travel' of policy in this area, and the anticipated positive impacts. In some cases, respondents also called for further or more immediate action to be taken.