Safeguarding Scotland's Resources - A Programme for the Efficient Use of Our Materials: Analysis of Consultation Responses

5. Influencing Behaviours

Background

5.1 The Scottish Government considers that effective and well targeted communication, awareness raising and support will help individuals and businesses make the changes needed to make more efficient use of resources. Ways in which this can be achieved are:

• public campaigns including those targeted at reducing food waste amongst householders
• Eco-Schools movement
• reducing the number of carrier bags used in Scotland
• community action for example through Climate Challenge Fund projects
• effective local waste collection services
• smarter, sustainable procurement for public organisations.

Question M: We are interested in receiving feedback on these proposals, including communications, designed to influence behaviours of individuals and organisations to use material resources more efficiently.

5.2 Forty two respondents (42% of standard responses) addressed this question. Overall there was much support amongst respondents for the proposals. General comments included:

'We support the broad thrust of the Scottish Government's intentions on communications and influencing behaviours. Consumer and business behaviour in both the purchase and consumption of materials/products as well as their sorting, collection and processing for recycling are critical elements to the success of a resource efficient approach that uses materials wisely and maintains their value in the wider economy' (Resource Association).

'We agree that a wide range of measures targeting awareness at different levels are required to improve resource efficiency throughout Scotland, provided that the infrastructure is in place to support increased recycling' (Scottish Council for Development and Industry).

5.3 Others agreed that one key to success is making it easy to reuse materials, for example, through kerbside recycling systems.

Views on public campaigns

5.4 There was much support for public campaigns, largely from local authorities and manufacturers, although it was pointed out that the impact from these may take time to filter through to targets. Five respondents urged that lessons on what has worked previously should inform the planning of future campaigns. For example, COSLA highlighted research commissioned by the Scottish Government Climate Change Behaviours Research Programme to identify the best approaches to encouraging behaviour change. One respondent recommended a social marketing approach:

'Lessons from other fields show that effecting behaviour change requires a wide range of approaches, including awareness raising, education, legislation an continuing support for behaviour change. We would recommend a social marketing approach which encourages consumers by presenting behaviour changes in a fun, easy and popular way, and by emphasising benefits now and costs later' (Consumer Focus Scotland).

5.5 One dominant theme was that an essential factor in successful public campaigns is to ensure consistency in message. It was suggested that this can be achieved by using one body to deliver the message. For example, one respondent commented:

'We believe that there should be one message, delivered by one body - consistently. The public has been told different stories, by different agencies, and so does not have the utmost faith in the recycling message' (Scotpak).

Another view was:

'We believe that a national campaign is important to ensure that the message is consistent across Scotland. However, care must be taken to ensure that the national campaign compliments local systems and services and does not cause confusion......ZWS must act as the co-ordinating body for any national campaigns to ensure that local authorities are fully briefed on the communication plan and can compliment it accordingly at the local level' (Scottish Borders Council).

5.6 Nine respondents explicitly supported a focus on reducing food waste. One manufacturer urged that care should be taken with defining food waste and cognisance should be taken of discussions on this topic at European level through the FoodDrinkEurope initiative. One respondent in particular was eager for householders to understand the impact of food waste:

'In particular we support actions to reduce the scale of household food waste which has a resource and environmental impact many times that of used packaging' (British Glass).

5.7 Six respondents (representing five respondent sectors) documented their support for driving home messages through the Eco-Schools movement. However, it was recognised that some schools still were without adequate recycling facilities (NGO); and momentum could be lost in the transition from primary to secondary school (LA).

5.8 Two local authorities specifically welcomed the notion of a dedicated website to promote the key messages. Another, however, cautioned that such an approach may not impact on the most socially excluded households.

Views on proposals for promoting community action

5.9 Five respondents representing four different respondent sectors expressed broad support for the proposed action. One NGO remarked that they would like to see more learning garnered from local initiatives which could be disseminated wider and scaled up. A local authority suggested that more needs to be done at community level to target hard to reach and high density areas.

Views on waste collection systems

5.10 Six respondents representing four different respondent sectors expressed specific support for the actions proposed regarding waste collection systems. In particular, the production of guidance to local authorities on collection system design was welcomed. Two respondents urged that local authorities and reprocessors respectively be involved in the development of the guidance.

Views on public bodies leading by example

5.11 Five respondents representing three different respondent sectors provided broad support for the proposed action. One waste management company recommended that the Scottish Government develop firm green public procurement standards.

Views on charging for carrier bags

5.12 The Scottish Government proposes to reduce the number of carrier bags used in Scotland by legislating to require retailers to charge for bags with a voluntary agreement that net proceeds will be donated to charitable causes, a proportion of which will be for waste and litter prevention.

Question N: Do you support the proposal of introducing a charge for carrier bags?

5.13 In total, 665 respondents addressed this question (594 of which responded via a campaign). Overall, 94% of all those commenting voiced outright support for the proposal of introducing a carrier bag charge. The seventy one standard responses (72% of all standard responses) addressed this question directly as follows:

	No.	%
Agree with charging	32	45
Partially agree with charging	11	15
Disagree with charging	26	37
Commentary only	2	3

5.14 Local authorities and waste management companies were disproportionately represented amongst those agreeing with the proposal to introduce a charge for carrier bags. All eleven local authorities who provided a view agreed or partially agreed with the charge. Only one of the five waste management companies who responded on this question disagreed with the proposal. Packaging and PR compliance respondents were over-represented amongst those disagreeing with the proposal. All three packaging respondents and four of the five PR compliance respondents disagreed.

5.15 It is difficult to assess the overall body of view from retailers as whilst some indicated clearly whether or not they supported the proposal, others did not provide an overarching view, but instead focused on specific aspects of it, such as the proposed exemptions. Overall, eight of the 14 retailers provided a view on the principle of charging, with five agreeing or partially agreeing and three disagreeing.

5.16 The main focus of the two campaigns (WWF and Marine Conservation Society) was to support charging for carrier bags (see Annex 2 for the text of their respective responses). The WWF campaign referred to introducing a plastic bag charge, whereas the Marine Conservation Society used the term 'single-use carrier bag levy'.

Reasons in favour of charging for carrier bags

5.17 Few reasons were given in support of the proposal. Of those documented, three dominated:

• Charging has worked well previously and elsewhere (11 mentions).
• Whilst playing only one small part in the overall agenda for safeguarding Scotland's resources, charging for carrier bags constitutes a powerful behaviour change message (10 mentions). Comments included:
  'Excellent way to bring the message home to each and every individual' (SGL Carbon Fibers Limited).
• Carrier bags contribute to pollution and litter (6 mentions).

5.18 Other reasons given in support of the proposal were that voluntary efforts are not sufficient to bring about change (2 mentions); and that the scheme will be relatively easy to implement (1 mention).

Qualifying comments

5.19 A few respondents added qualifications to their support of the proposal. It was argued that to be successful, the scheme and the underlying rationale will need to be widely publicised (4 mentions). One respondent (Retail) recommended that common, official messaging and promotional material be provided by the Scottish Government, with a helpline also established. Another respondent commented:

'We would welcome, for example, retailer packs that include detailed guidance, downloadable promotional materials to educate consumers and a communication toolkit' (Local Authority Recycling Advisory Committee).

5.20 Four respondents argued that vigorous enforcement will be required to ensure consistent application of the scheme.

5.21 A recurring concern (11 mentions) was that by placing too much emphasis on charging for carrier bags, other actions which may have more of an impact may be relegated by consumers who feel they have played their part in safeguarding resources. A typical comment was:

'We are not comfortable with measures of this kind being excessively trumpeted as waste prevention and/or resource efficiency measures, as their impact in these areas is marginal and there is a danger that a public perception is created which believes that a major waste problem has been solved - when patently it has not' (Resource Association).

Reasons against charging for carrier bags

5.22 Three arguments against the proposal were presented by five or more respondents:

• The proposal will have little impact on resource efficiency (9 mentions). One comment was:
  'We feel that the Scottish Government has other priorities we would wish to see them act on before tackling Scotland's plastic bag use. This policy has a risk of being a distraction from the real business of reducing waste and improving resource efficiency (Scotch Whisky Association).
• The proposal could inadvertently result in more waste if consumers buy other bags such as bin liners to compensate (8 mentions).
• The proposal is based on the false premise of carrier bags being 'single use' (6 mentions). One individual respondent underlined this point:

'....they are used as bin liners, for emptying vacuum cleaners, picking up local rubbish, carrying wet or muddy sports gear.....or are donated to charity shops for reuse'.

5.23 A range of other reasons against charging for carrier bags was identified by four or fewer respondents:

• This imposes an additional tax on an item already taxed under the Producer Responsibility (Packaging Waste) Regulations.
• Will affect the poor and elderly disproportionately.
• We should wait for the longer term impact of the Welsh initiative to be clear before going down this route.
• Amounts to Government interference with business commercial interests. One respondent commented:
  'While some businesses agreed with the proposal...many expressed exasperation at being asked to effectively administer a Government scheme to influence the public's behaviour' (Federation of Small Business).
• Could damage the retail sector in town centres as it will put people off impulse buying.
• Administrative burden, particularly for small firms.
• Too difficult to enforce.
• Voluntary measures are sufficient.
• Retailers will pass on overheads of the scheme onto their customers.
• Presents a health hazard with multi-use carrier bags harbouring food bugs such as E-Coli and salmonella.
• Customers using their own bags attract the attention of store detectives.
• Cannot use self check-out with own bags.
• Carrier bags make up a very small proportion of street litter.
• This constitutes an indirect attack on plastics as single use carrier bags are predominantly made from plastics.
• This presents packaging in a negative light, when in fact it has benefits of protecting valuable food and other products.
• Not likely to change behaviour in isolation, but must be part of a wider safeguarding resources agenda.

Views were invited on key aspects of the proposals: including all retailers; including all single use/disposable carrier bags regardless of material; setting the minimum charge at 5p; the proposed exemptions; making the scheme cost neutral for retailers; directing net revenues to good causes; design of the reporting system.

Views on including all retailers

5.24 In total, 125 respondents addressed this question (104 of which resulted from the Marine Conservation Society campaign). Overall, 97% of all those commenting voiced support for the proposal to include all retailers. The 21 standard responses (21% of all standard responses) addressed this topic as follows:

	No.	%
Agree	17	81
Disagree	2	10
Commentary only	2	10

NB Percentages may not add to 100% exactly due to rounding

5.25 A recurring comment (8 mentions) was that including all retailers was fair and contributed to a level playing field. For example:

'Consumers may be put off going to a certain shop if they have to pay for carrier bags when they can go to a competitor down the road and get bags for free' (Inverclyde Council).

5.26 Other supporting comments were:

• The inclusion of all retailers sends out a consistent message that is easy for consumers to understand (2 mentions).
• Easier to implement and enforce if all retailers are included (1 mention).
• This is how it has been introduced elsewhere (1 mention).

5.27 One respondent (Business) argued that the proposal to include all retailers does not present a level playing field as compliance will cost micro-businesses proportionately more than large businesses. Another (Retail) considered that consumers should not be encouraged to take their own bags for use in the takeaway sector due to the possibility of bacteria impacting on health.

5.28 One respondent sought further clarification on the definition of 'retailers' (Business). Two others recommended that impact assessments are undertaken prior to any firm decisions being made.

Views on including all single use/disposable carrier bags, regardless of material

5.29 In total, 123 respondents addressed this question (104 of which resulted from the Marine Conservation Society campaign). Overall, 96% of all those commenting voiced support for the proposal to include all single use/disposable carrier bags, regardless of material. The 19 standard responses (19% of all standard responses) addressed this topic as follows:

	No.	%
Agree	14	74
Partially agree	1	5
Disagree	3	16
Commentary only	1	5

5.30 Two substantive reasons were provided in favour of the inclusion of all single use bags regardless of material:

• Paper bags and plastic bags alike are damaging to the environment (5 mentions). One respondent commented:
  'There is nothing to be gained from replacing one type of free bag with another made from a different material' (Marine Conservation Society).
• Including all bags regardless of material is in keeping with the other proposals and presents a consistent front (2 mentions).

5.31 Those opposing the proposal emphasised their view that this inclusive approach had previously caused confusion in Wales (2 mentions); and that paper bags create fewer litter problems than plastic bags, so perhaps should be handled differently (e.g. charged but at a lower rate) (LA). Two respondents argued that it is inappropriate to place a levy on paper bags made from 100% recycled material. One remarked:

'....the single culprit for 100% of the issues highlighted is the Supermarket Plastic Checkout Vest Carrier Bag' (Smith Anderson Group Limited).

Views on setting the minimum charge at 5p

5.32 Twenty eight respondents (28% of standard responses) addressed this topic as follows:

	No.	%
Agree	17	61
Disagree	9	32
Commentary only	2	7

NB Percentages may not add to 100% exactly due to rounding

5.33 Those supporting setting the minimum charge at 5p included five retailers. The most common reason given in support was that 5p matches the charge in Wales which was sufficient to change behaviour and will provide a consistent approach thereby helping to keep administration costs down. One respondent (Business) argued that the charge should be no more than 5p as a higher cost would most likely be negatively received by customers. One retailer urged that the cost be equal to or lower than the current cheapest Bag for Life (currently thought to be 6p).

5.34 Those opposing the 5p charge were generally in favour of this being set at a higher level, with 5p considered too low to change attitudes. Recommended costs ranged from 8p - 20p.

5.35 Four respondents urged that provision is made for reviewing and potentially increasing any charge set.

Views on the exemptions proposed in Annex 2

5.36 Twenty eight respondents (28% of standard responses) addressed this topic. The majority agreed with the proposed exemptions, suggested additional exemptions or provided other relevant commentary. Only three respondents clearly stated their opposition to the proposals.

5.37 Where respondents recommended additional candidates for exemption these included:

• On-line deliveries, the packaging of which the customer has no control over (4 mentions).
• Bags used to transport take-away food (on the grounds of potential health risks of using the customer's own bag) (3 mentions).
• Compostable bags (2 mentions).
• Bags provided to prevent leakage (e.g. for flowers) (1 mention).
• In the case of clothes and accessories as retailers may not be willing to give full refunds on goods transported in customers' own bags (1 mention).
• Where a bag is clearly designed for significant reuse (1 mention).

5.38 A recurring comment amongst retailers was to welcome the proposed exemption in airports for purchases made after passing through security. This was viewed as particularly important for reasons of security, tax and to allow for impulse buying.

5.39 Whatever exemptions are put in place, it was argued that these will need to be widely publicised with definitions such as 'small bags' made explicit (4 mentions).

5.40 The three reasons given in opposition to the proposals were:

• Too generous and will open up the possibility of cost avoidance (Ind).
• Too much scope for confusion (Retail).
• There should be only one reason for exemptions - on grounds of risk to health (PR-C).

Views on making the scheme cost neutral for retailers

5.41 Nineteen respondents (19% of standard responses) addressed this topic. Sixteen of these agreed with the proposal and three disagreed.

5.42 Those in favour of the proposal considered that it constituted a pragmatic approach, which will facilitate acceptance of the scheme by retailers, and prevent retailers passing on additional costs to customers. One respondent (Business) commented that it would be helpful if other associated costs such as additional staff training and information campaigns could also be recovered by retailers.

5.43 The three reasons given in opposition to the proposal were:

• All of the charge should go to good causes as retailers are currently giving bags away free (Ind).
• If retailers are not permitted to recover their administrative costs this will provide an incentive to run the scheme efficiently (PR-C).
• Does not resonate with the trade. This is part of retailers' social responsibility agenda and if the proposal is introduced it will present an unlevel playing field with some retailers recovering their costs and others choosing not to do so (Retail).

Views on directing net revenue to good causes

5.44 In total, 138 respondents addressed this topic (104 of which were Marine Conservation Society campaign responses). Amongst the 34 standard respondents addressing the topic (34% of standard responses) all but one provided supportive commentary and suggestions. The remaining respondent (Business) argued that unless legislation is put in place to require retailers to direct net revenue to good causes, not all will do this.

5.45 Seven of the standard responses put forward a view that there should be transparency in how much revenue is going to good causes and which causes have been the recipients. It was agreed that this could be done by using posters (Ind) or by displaying a charity certificate (Ind). Six respondents requested clarity, perhaps in guidance, on which causes might be considered 'good' and what percentage of net revenue should be directed to them.

5.46 Several respondents argued that retailers should be given leeway to decide for themselves which causes to support and that the causes permitted should be wider than environmental and resource efficiency organisations.

5.47 The Marine Conservation Society campaign responses argued that proceeds should of a levy should go to charities and NGOs working on: litter and waste prevention and reduction; litter collection and surveying; recycling; and environmental protection and improvement. Some of the standard responses also highlighted the type of good cause which they perceived to be suitable candidates to receive such revenue. These were:

• environmental projects (6 mentions)
• recycling/reuse and resource efficiency projects (6 mentions)
• litter campaigns/collections (3 mentions)
• social enterprises involved in sustainable resource management (2 mentions)
• community gardens (1 mention)
• local projects nominated by local people (1 mention)
• health and welfare (1 mention).

Views on the design of the reporting system

5.48 Sixteen respondents (16% of standard responses) addressed this topic. Many simply welcomed the proposal to keep reporting as simple and minimal as possible. One typical comment was:

'....every effort should be made to minimise the administrative impact on businesses resulting from these proposals. Any eventual reporting requirements must be simple and easy to implement' (CBI Scotland).

5.49 Some respondents emphasised their view that reporting should be transparent and open to scrutiny (4 mentions). Two respondents urged that reporting is tied in with the annual financial reporting cycle, with one (PR-C) suggesting that the revenue go through the company tax reporting system with audit picking up anything untoward.

5.50 There were mixed views on the proposal for 'light touch' enforcement. Whilst one respondent (Retail) explicitly welcomed this approach, others (4 respondents) felt that enforcement needs to be more prominent. One remarked:

'While a 'light touch' voluntary approach may be preferred due to the lower cost involved, it could provide an opportunity for unscrupulous retailers to keep the money raised' (Consumer Focus Scotland).