Single-use disposable cups: EPECOM recommendations

Recommendations

Ambition

The Panel agrees that the following ambition should be at the core of the Scotland’s action on single-use disposable beverage cups:

Scotland has a sustainable model of consumption by 2025 which includes the majority of beverages being sold in reusable cups.

Recognising the complexity and on the go nature of drinks consumption, the Panel emphasises that there is no single solution to reduce the prevalence of single-use disposable beverage cups. Instead, a portfolio of measures and interventions is required, and the Panel has developed a suite of measures that would, if implemented, make significant impact on the use of single-use disposable beverage cups.

The recommendations relate to 5 key themes:

The Expert Panel had an initial remit referring to ‘coffee cups’ as a priority item relating to tackling Scotland’s throwaway culture. As such the range of recommendations refer to typical takeaway hot beverage cups found in retail outlets. Where any recommendation could be expanded to cover other types of disposable cups, it is highlighted in the body of the text. 

Recommendations on the single-use disposable beverage cups. 

The Panel has used the model set out in the Waste Hierarchy^[5], when developing their recommendations. The Hierarchy, as set out below, sets out to categorise the best courses of action to reduce waste creation, from prevention being the best option through reuse; recycle; recover other value and disposal.

Culture of Sustainability

The evidence considered by the Panel indicates that significant changes in social norms, consumer behaviour and business practices are required by retailers and customers in order to realise a widespread shift from single-use disposable beverage cups to reusable cups. This will require a major change in existing on the go service models and the way consumers behave and make choices. 

Specifically the Panel has noted evidence that: 

• Around 200 million single-use disposable beverage cups are consumed each year in Scotland and, without intervention, this is projected to increase to 310 million by 2025^[6].
• The growing dependence on single-use packaging associated with our on the go and throwaway culture has increased the volume of waste generated. Single-use disposable beverage cups generate circa 4,000 tonnes of waste in Scotland each year; and single-use disposable beverage cups production and waste generates ~5,900 tonnes of CO2e/year in Scotland. Around 40,000 single-use disposable beverage cup are littered in Scotland annually. 

Interaction with stakeholders indicated that there is significant enthusiasm particularly among young people for government interventions to support and drive forward sustainable behaviour on the part of consumers, producers and businesses. The young people who attended the stakeholder group were especially keen to see Scotland become a world leader in developing a sustainable approach. 

On the specific measures proposed, social marketing measures were considered to be a key supporting action that, although they may not be transformative on their own, would be critical in communicating and normalising the desired behaviour changes from any measures taken, in particular price-based interventions.

Consistent messaging and labelling were seen as an important step, with particular gaps being identified around communicating a cascade of desired behaviour. 

Recommendation

Concerted action is needed at national and local level to promote sustainable production and consumption and tackle Scotland’s throwaway culture, to prevent single-use disposable beverage cup consumption and to help make reusable options more accessible and acceptable as the default mode of consumption. 

Promoting cultural and behavioural change is critical and will underpin the success of the other measures the Panel is recommending. The Panel considers that a range of social marketing measures are required to raise awareness of the need for change and to support and enable individual and organisational change. The Panel is keen to emphasise that social marketing is a key supportive measure, and the interventions set out in this Report will only be effective if aligned with effective communication. 

The Panel is clear that moving towards a culture of sustainability is essential and that social marketing and a clear direction of travel are needed to support this. 

Designing and delivering social marketing measures will be needed to ‘shift the paradigm’ so that unsustainable consumption becomes socially unacceptable and ensure sustainable consumption becomes the new social norm, and to raise awareness of the environmental impact of single-use disposable beverage cups.

The Panel recommends the following measures:

1. Using Scotland-wide social marketing measures to promote sustainable consumption and help make unsustainable consumption socially unacceptable. 

Outstanding issues for Scottish Ministers to consider 

A more detailed understanding of barriers and drivers to changing consumer behaviour on single-use disposable beverage cups is required to inform future social marketing strategies. In particular the drivers and 

symbolic motivations fuelling on the go consumption would need to be better understood in order to deliver targeted behaviour change.

Prevention

Evidence considered by the Panel highlighted that moving away from a dependence on single-use disposable beverage cups is a vital component in reducing throwaway culture and promoting sustainable consumption. The independent literature review demonstrated the effectiveness of charging separately for a cup as an intervention that can act as a ‘habit disruptor’ to reset consumer behaviour.

The academic literature review commissioned on behalf of the Panel and carried out by the University of Cardiff^[7] highlighted evidence suggesting that:

• Charges are more effective than discounts in reducing the use of single-use disposable beverage cups.
• Clear messaging and social marketing tools can help boost the effect of a charge. 
• A minimum charge of £0.20 would be needed to change behaviour of 49% of the population.
• Charges are unlikely to substantially affect hot drink sales where they can be implemented in a cost-neutral way^[8]. 
• While charging is considered effective, the use of single-use disposable beverage cups is more resistant to behaviour change interventions than, for example, single-use carrier bags.

The stakeholder engagement events highlighted divergence on the impact and acceptability of charges. Feedback from industry and retailers suggested a preference for focusing on recycling rather than prevention measures, such as charges. 

In addition, concerns raised by business representatives stressed the need for a level playing field to address any competitive disadvantage that might arise from, for instance, exemptions from any mandatory charges or voluntary charging for single-use disposable beverage cups. This could be addressed by putting the requirement to charge for a single-use disposable beverage cup on a national and mandatory footing. 

Among non-governmental organisations (NGOs) and youth groups there was strong support for a charge, with young people calling for an accelerated timescale (within the calendar year) for the introduction of a charge, accompanied by a widespread awareness and social media campaign. There was concern among young people that any form of charging for single-use disposable beverage cups would be used by retailers to mask a price increase, which would have to be addressed through clear communication in the lead up to any future introduction of a charge. 

The Panel considered the opportunity presented to set a target to focus on a reduction in the consumption of single-use disposable beverage cups and reflected on the current move across a range of countries to deliver a reduction in the use of single-use items and that there was scope to recommend a target that reflects the Panel’s ambition. The Panel is aware that other countries are proposing the introduction of a charge for disposable cups or measures that would reduce the consumption of single-use disposable beverage cups and would want to see any action in Scotland demonstrate a strong and determined approach that suits the Scottish content to develop a Scottish target that would, at least, match the ambitions being made elsewhere. 

As part of their role, the Panel has considered the proposal to ban sales of expanded polystyrene/PVC beverage cups by 2021 which is in line with EU Single-use Plastic Directive ambitions. The Panel agreed that the ban would not be controversial as it would have a limited effect on overall reduction in single-use disposable beverage cups but would remove them from the waste stream.

Recommendation

Environmental charges, notably price based interventions, have been shown to be effective at reducing consumption and should be considered in tandem with other preventative measures. The Panel believes that a charge is more effective at reducing consumption and increasing reusable cup use than a disposable cup discount.

The Panel considers that there is strong evidence that a separate charge for single-use disposable beverage cups should be put in place in Scotland. 

Furthermore, the Panel notes that separate minimum, mandatory pricing for cup and drink should be introduced at a national level to effectively change behaviour, ensure consistent messages to the consumer, and create a level playing field for retail and businesses. 

The Panel considers that retailers should move to introduce voluntary separate pricing as soon as possible and in advance of any regulatory action by government. 

In addition, to help communicate aspirations and drive positive change, the Panel considers that Scotland should set ambitious targets for the coming years in relation to the consumption reduction of single-use disposable beverage cups.

The Panel supports the commitment within the EU Single-use Plastic Directive to ban expanded polystyrene/PVC beverage cups by 2021.

The Panel recommends the following measures:

2. The introduction of a national, mandatory requirement to sell beverages and disposable cups separately, including an initial minimum price of between 20-25p^[9] per cup^[10]. 

3. Retailers and businesses should, in anticipation of future regulation, be supported and encouraged to put in place voluntary separate pricing (of beverage and cup) to promote behaviour change.

4. The Scottish Government should consider introducing an ambitious national consumption reduction ambition or target for single-use disposable beverage cups. 

5. Banning sale of non-recyclable expanded polystyrene/PVC beverage cups, in line with EU Single-use Plastics Directive by 2021.

Outstanding issues for Scottish Ministers to consider

The Panel recognises that further analysis and consultation will be required on these measures, notably to develop a mandatory minimum price cup charge that is separate from the price of the beverage. Consideration would need to be given to the impacts on business, in particular SMEs, alongside exploring whether the proposed charge should be implemented in a cost-neutral manner; equalities impact of any charge on single-use disposable beverage cups also need further careful consideration. However, the Panel is keen that the needs of business and consumer groups are weighed against the current climate emergency. It is recognised that there is a need to take radical and immediate action to minimise the effects of climate change. 

Further engagement with stakeholders would be needed to determine the optimal timing of any charge, especially with regards to how a charge would fit in with other changes in the landscape, particularly Extended Producer Responsibility (EPR) and Deposit Return Scheme (DRS). Any future implementation of a charge would benefit from an independent cost-benefit analysis of its economic and environmental impacts, including a Life Cycle Analysis (LCA). The Panel considers that this further analysis and consultation can best be done by the Scottish Government. The Panel notes that formal consultation by Scottish Government on any future proposals, business and equality impact assessments would also be conducted.

In considering an appropriate target for Scotland in terms of a reduction of the number of single-use disposable beverage cups used in Scotland, research would be needed to develop a baseline for the target and to ensure there that the target was ambitious and SMART (Specific, Measureable, Achievable, Realistic and Time-bound) and would have maximum impact. Further assessments and engagement would need to be undertaken to ensure that all equality issues were fully considered.

Promoting Reuse

Evidence considered by the Panel has highlighted that in order to deliver a significant reduction in the prevalence of single-use disposable beverage cups, a significant increase in the acceptability and adoption of reusable cups is needed. The Panel recognises that this is not straightforward so recommend a number of trials or pilots to develop experience and enhance the knowledge base of how this could work in practice. In a closed setting, such as a workplace, there is a strong case to ban using single-use disposable beverage cups as a means of driving this change. 

The Panel has noted the leadership already shown by some public and private sector organisations to date on single-use disposable beverage cups, for example certain retailers, Scottish Government and NHS Scotland, and considers there is a clear case for scaling up approaches that have been shown to be effective in suitable settings and sharing learning. the Panel has asked for a case study of the Scottish Government’s ban on single-use hot drinks cups to be published to provide a starting point for any organisations seeking to replicate it.

The Panel’s review of available evidence has also highlighted:

• Despite voluntary measures by retailers to promote reuse, reuse rates among major retailers are consistently around just 1-2% of sales^[11], suggesting significant scope to increase reusable cup use rates at point of sale.
• Initial evidence regarding Scottish Government’s decision in summer 2018 to remove all single-use disposable beverage cup from its estates and a trial by NHS Scotland which promoted reuse alongside implementation of a cost-neutral single-use disposable cup charge, both proved highly effective in reducing consumption of single-use disposable beverage cups.
• There are already examples of large scale reusable cup schemes, including deposit based schemes such as RECUP scheme in Germany.

Feedback from the Youth and Equalities sessions suggested support for all types of interventions (charging, bans and cup rental schemes), while recognising that not all settings are suitable to all interventions. Cup rental schemes were seen as an exciting way to potentially address some of the difficulties associated with the on the go nature and convenience of single-use disposable beverage cup consumption. It was recognised that this would probably be easier to implement on a localised scale, for example in cities, during events and festivals, or even on trains. 

Withdrawal of single-use disposable beverage cups were considered to be more effective in office settings than for on the go consumption. Feedback from the Industry and NGO events was that ‘closed loop settings’ was too vague and while there was interest in the opportunities that adopting this approach could bring there would need to be further exploration to establish which areas or types of locations would be suitable for this approach.

Recommendation

As well as making single-use disposable beverage cups less desirable, the accessibility and convenience of reusable cups must also be improved as part of the paradigm shift towards a culture of sustainability. Uptake of reusable cups should be encouraged by promoting reuse at point of sale in commercial outlets, banning single-use disposable beverage cups in settings where this is feasible, and taking steps to increase availability of reusable cups. 

The Panel recommends the following measures

6. Demonstrate the viability of reusable cup rental schemes for a range of hot or cold drink types at a local or national level by establishing ambitious replicable trials in significant parts of Scotland as soon as possible, potentially by the end of 2019, with a view to these being quickly assessed and rolled out to other areas. These should draw on learning from other countries.

7. Issuing best practice guidance to support better promotion of available reuse options by retailers at point of sale, including a duty to provide, facilitate and accept reuse options alongside separate charging and communicating assurances that ‘Bring you own’ (BYO) reusable cups will be accepted at point of sale. 

8. Developing reuse options which eliminate a range of single-use cups types for both hot and cold drinks across a wide range of ‘closed loop’ settings^[12], for example: offices, events, festival venues etc. Changes to legislation should be introduced to ensure this is delivered and it should be supported by:

• Sharing best practice guidance to demonstrate viability of the approach and encourage more trials. 
• Using public sector leadership to encourage adoption of reuse in closed loop settings more widely.

Outstanding issues for Scottish Ministers to consider

More work would be needed to identify the range of appropriate settings suitable for organisational bans on single-use disposable beverage cups and to more actively promote or require reuse measures. In particular, what constitutes a ‘closed loop setting’ would need to be better articulated. 

Consideration would also need to be given to the appropriate scale for rolling out cup rental schemes. No national scheme exists to date, but there would be significant value in conducting urgent trials on a localised scale.

Finally, the business and equalities impacts of any requirements would need to be considered, in particular how the needs of people with disabilities can be met in reusable coffee cup design and provision. 

Recycling 

Evidence considered by the Panel confirms that, consistent with waste hierarchy principles, reducing the dependence on single-use items and switching to reusable cups would have the most significant impact in tackling Scotland’s waste and becoming a more sustainable society; but that improved recycling of single-use disposable beverage cups is needed to manage this waste stream in the short-term. 

During its considerations, the Panel has:

• Welcomed concerted efforts across the UK to increase capture and recycling rates, including the recently launched Glasgow Cup Movement which offers the potential to test out a system and city-wide approach to collecting and recycling single-use disposable beverage cups. 
• Noted actions by some coffee retailers to expand in-store recycling infrastructure in tandem with a voluntary producer responsibility scheme to support sustainable collection arrangements.
• Concluded that this will have limited impact given the proportion of beverages sold on an on the go basis which will require off-site disposal.
• Noted estimates produced by the paper cup industry of the proportion of cups collected and recycled across the UK and future projections of recycling trends; and highlighted the need for robust Scotland-specific data. 
• Concluded that pursuing recycling as the main or only focus of improving sustainability will provide limited impact.

The stakeholder engagement sessions reaffirmed the considerable efforts underway in this area by business leaders, highlighting that there are some powerful success stories here and a platform to drive further development. 

At the events it was also reinforced by both NGOs and young people that while recycling efforts are important, they are not the key to solving the problem of single-use disposable beverage cups, and that the emphasis of efforts and resources should go to measures delivering prevention and promoting reuse. 

It was noted by all stakeholders that careful consideration would need to be given to the timeline of implementing any measures and how EPR reform sits with the work of the Panel. 

Recommendation

Whilst the Panel considers that prevention is paramount, it accepts that it will take time to shift the on the go convenience culture and establish reuse as the social norm. Therefore, while preventive measures are key, it is important in the short term to increase accessibility and uptake of recycling options, where prevention or reuse is not yet possible. To effectively capture cups for recycling, consumers must have reasonable access to, and be inclined to use, suitable recycling facilities at the point their cup is ready for disposal. This is both an infrastructural and behavioural challenge. 

The Panel welcomes the proposed reform of extended producer responsibility arrangements across the UK and considers that this presents a critical opportunity to drive positive change in relation to disposable beverage cups by incentivising design/materials that are easier to recycle and ensuring full costs of recycling and recovering waste from single-use disposable beverage cups are met by producers, with the opportunity to deliver improved collection arrangements. 

The Panel recommends the following measures

9. Promoting the uptake of recycling where reuse is not yet possible by:

• Innovation in disposable cup design to move to a position where they are more readily and widely recyclable and can be recycled through existing collection infrastructure. 
• Ensuring clearer consumer messaging and labelling, to avoid confusion about recyclability of cups, especially those made of biodegradable or compostable materials, and signal desired behaviour.
• Building on future implementation of changes to packaging producer responsibility schemes to support further improvements in recyclability of cups and collection arrangements, including on the go recycling infrastructure. 

Evidence and Analysis

The Panel agrees that the work they have undertaken on single-use disposable beverage cups has allowed them to access as much evidence as there is currently available to make their recommendations, and will publish the commissioned research alongside a knowledge account collated for the Panel with this Report. However, there is a strong case to build on this evidence base as work is undertaken to implement these recommendations and this will be essential in demonstrating how interventions can be made effectively and inspire others to make changes to be a more sustainable society. 

Evidence-based policy is the cornerstone of responsible policy making. The Panel has noted that there is a limited suite of evidence setting out clear findings on the full range of interventions to prevent consumption and promote reuse and recycling of single-use disposable beverage cups within a Scottish context.

Recommendation

The evidence base on measures to prevent and address the impact of single-use disposable beverage cup consumption within a Scottish context should be strengthened and expanded. 

It is imperative to strengthen and expand available evidence to inform policy development and implementation of measures, and to enable shared learning, while noting that undertaking analytical exercises should not delay the vital decisive action that needs to be taken on this issue.

The Panel recommends the following measures

10. Developing, synthesising, and learning from evidence from Scotland and more widely by Scottish Government, Zero Waste Scotland and academic institutes to inform policy development and promote behaviour change, especially on expanding the drivers of responsible consumption.

11. Embedding robust analysis and evaluation of tests of change within a Scottish context. 

• Publish/share the lessons learned and encouraging sharing knowledge from the private sector to enable and support change.