UK packaging producer responsibility system reform: partial island communities screening assessment

Gathering data, identifying evidence gaps and identifying stakeholders

12. A scoping workshop was held, involving relevant members of Zero Waste Scotland staff, with the aim of identifying ways in which the impact of the policy could differ for island communities. A longlist of potential issues was produced prior to the workshop:

a. Impact on the price of goods

b. Impacts on island producers

c. Reduction in litter impacts

d. Changes to funding for household and household-like packaging waste management

e. Transport issues

13. During the workshop, discussion focussed on the areas where it was felt that there was the most potential for island-specific issues

Areas where issues have not been identified at present:

14. Island-specific issues were not identified in these areas during the workshop:

a. Impact on the price of goods

b. Impacts on island producers

c. Reduction in litter impacts

15. It was considered that any impact on the price of goods was unlikely to be an issue that was significantly different for islands, though we do recognise that the cost of living is generally higher in island communities. ^[7] Any increase in the cost of goods is likely to occur throughout the UK, as a result of producers passing on some of the increase in costs. Similarly, it was thought that any impact on producers would not be unique to island-based producers.

16. It was also determined that though the source of funding for cleansing services (which deal with litter collections and street bin services) will change, this will be the case for all local authorities, and is therefore not expected to have a significantly different impact on island communities. However, it should be noted that island geographies should be taken into consideration when setting standards for efficient and effective cleansing services.

17. A further potential issue was highlighted during the scoping workshop, around the availability of waste to fuel the Shetland energy from waste plant. It was not felt that the policy as proposed would have a substantial impact on the availability of suitable material, and any impact that did occur would be similar for energy from waste facilities elsewhere in the country.

Areas where potential issues have been identified:

18. The following issues were considered to have the potential to have different impacts for island communities:

a. Changes to funding for household and household-like packaging waste management

b. Transport issues

19. Since the workshop, proposals in relation to a take-back scheme for fibre-based cups have been introduced, which may also have impacts for island communities.

20. These issues are explored in more detail below.

Changes to funding for household and household-like packaging waste management:

21. Local authorities are responsible for providing household waste collections and currently pay the net cost of providing this service. This is the cost of providing the service, minus the income received from the sale of materials and any income from charged-for services. Under the revised packaging EPR scheme, producers will be obligated to pay the full net cost of dealing with the packaging that they place on the market, and this will include funding for local authorities to cover an efficient and effective service.

22. Packaging waste generated in commercial premises is collected by a wider range of local authorities and waste management companies and only the recycling collections are intended to fall under full net cost.

23. These proposals mean that producers will be responsible for paying the full net cost of managing their packaging at the post-use stage including collection, sorting and disposal of household packaging waste by local authorities in recycling collections and collection and disposal of packaging in residual services. It should be noted that the funding mechanism will be different for household and household-like municipal waste collections.

24. The funding mechanism for local authorities is likely to be based on efficient and effective service delivery in groups but is expected to factor in geographic, socio-economic and other relevant factors. The payment mechanism will be subject to contractual agreement with a future scheme administrator. The potential for impact on island communities is dependent on whether this mechanism accounts for the unique geography of island communities, and this should be given due consideration by a future scheme administrator.

25. Work undertaken for previous screening assessments under the Islands (Scotland) Act has identified that island authorities face higher costs per capita in collecting, transporting and disposing of waste, as the rural nature of collection routes means they are less efficient. The 8-fold Scottish Government Urban Rural Classification highlights that the majority of the island authorities have high proportions of their populations in very remote small towns and rural areas.^[8]

26. Additional costs are also incurred because waste must often be transported off island, usually by ferry, for processing. SEPA's landfill sector plan identifies the locations of operational landfill sites in Scotland, and clearly shows the limited facilities available on islands.^[9]

27. Kerbside recycling services are not universal in island communities due to the remoteness, which may make it more challenging to achieve high recycling rates in a cost-effective manner. The majority of island authorities have recycling rates that are below the Scottish average, in some cases by a substantial margin.^[10]

28. In addition, islands are the disposal point for the packaging of goods that have been purchased elsewhere, to a greater extent than other parts of Scotland, as a result of high visitor numbers. ^[11]

29. The geographical context will be taken into account when the funding mechanism is designed, to ensure that the higher costs for island authorities are covered by payments from producers. Zero Waste Scotland is currently undertaking research to more accurately understand the costs that local authorities incur in providing household waste collection services to feed into the final UK Impact Assessment, being developed by Defra. This research will be available to allow the scheme administrator to design the funding mechanism appropriately.

30. It is our intention to engage with island authorities and any private providers during the consultation period (anticipated in Spring 2021), once more details on the proposed scheme are in the public domain, to ensure that any additional island-specific challenges posed by running household waste collections are identified, so that these can be highlighted to a future scheme administrator.

31. The findings of this engagement, and the research we are currently conducting around local authority costs, will be fed into the full ICIA screening assessment.

Transport issues:

32. The transport of waste was also identified as a potential issue. The ICIA undertaken for the introduction of a deposit return scheme highlighted that ferry capacity was restricted on a small number of routes.^[12] If service improvements towards a more efficient and effective service, such as more material segregation, resulted from the changes to packaging EPR, this could increase space required on ferry services.

33. Service improvements would be a result of future decisions by local authorities and will not be directly mandated by this policy. It is therefore not anticipated that this policy will directly exacerbate the transport issues faced by island communities. Local authorities and other waste providers would need to ensure that consideration is given to transport issues if they choose to propose service changes.

34. However, one of the aims of the proposal is to reduce unnecessary packaging, which should reduce pressure on ferry services from the transport of waste.

35. In addition, the majority of the island authorities have signed up to the household recycling charter, which sets out an ambition for signatories to improve services. It is therefore possible that authorities would seek to improve services independent of any impacts from packaging EPR.

36. However, a future scheme administrator should be mindful of transport capacity, to ensure that there are not unintended consequences for island authorities.

Take-back of disposable fibre-based cups:

37. The preferred option within the UK-wide consultation contains a proposal for a take-back scheme in relation to fibre-based cups.

38. Following further analysis work, small and micro businesses may be temporarily or permanently exempted from this requirement. At present, a two-year exemption for small businesses is the favoured option, allowing time for the development of collection and reprocessing infrastructure. Funding for the introduction of this requirement may be available for small businesses, but it is not currently anticipated that the ongoing costs of running a take-back scheme would be covered. It is therefore likely that businesses selling filled cups (e.g. cafes) would need to pay for the costs of collection and disposal of fibre-based cups.

39. In an island context, we recognise that recycling of cups may not be possible locally, so businesses may face higher costs in arranging for fibre-based cups that have been collected under a take-back scheme to be transported for recycling.

40. This may increase costs for businesses on islands, and could be problematic for small businesses that only operate in island locations and are unable to benefit from economies of scale.

41. We will seek to engage with island authorities and any private waste service providers during the consultation to better understand this issue.