Single-Use Disposable Beverage Cups Charge Strategic Environmental Assessment: Environmental Report

3. Approach to the assessment

3.1 Scope of the assessment

This assessment considers the estimated impacts of the proposed charge on single-use disposable beverage cups across Scotland, focusing on the 10-year period from implementation in 2025 to the year 2035.

The proposed charge applies to all single-use disposable beverage cups, for both hot and cold drinks.

Table 2 sets out the environmental topics scoped into this assessment, as proposed in the scoping report. ‘Cultural heritage and the historic environment’ and ‘Air’ have been scoped out of this assessment since no significant direct impacts are anticipated in either of these areas. Feedback from the consultation on the scoping report indicated that all statutory consultees were satisfied with the environmental topics proposed. Following feedback from NatureScot on the scoping report, some of the objectives have been amended to include environmental enhancement and maximisation of opportunities for benefit as well as environmental protection and avoidance of negative impacts.

3.2 Environmental objectives

The anticipated impacts of the proposed charge have been assessed against each of the following environmental objectives, as set out in the scoping report (and amended following advice from consultees).

Climatic factors

• Reduce greenhouse gas (GHG) emissions resulting from the production and disposal of single-use disposable beverage cups.

Biodiversity

• Maximise opportunities to improve the quality of natural habitats by avoiding pollution and habitat loss associated with the production and disposal of single-use disposable beverage cups in terrestrial, coastal, and marine ecosystems; and
• Avoid adverse impacts to habitats and species resulting from littered single-use disposable beverage cups.

Human health

• Avoid adverse impacts to human health resulting from exposure to food contact materials.

Soil

• Enhance soil quality in Scotland by reducing soil pollution (e.g. microplastics) from littered single-use disposable beverage cups.

Water

• Promote sustainable use of water resources in the production and maintenance of different types of beverage cups; and
• Enhance water quality in Scotland by reducing pollution from littered single-use disposable beverage cups in bodies of water.

Material assets

• Reduce consumption of virgin materials used to produce single-use disposable beverage cups;
• Maximise potential to embed a circular economy in Scotland by encouraging consumers to opt for reusable alternatives to single-use disposable beverage cups; and
• Reduce loss of materials to landfill, energy recovery, or litter in the form of waste single-use disposable beverage cups.

Landscape and visual impacts

• Enhance the appearance of outdoor spaces in Scotland by reducing the volume of littered single-use disposable beverage cups in the environment and the associated negative visual impacts.

3.3 Consideration of reasonable alternatives

The Environmental Assessment (Scotland) Act 2005 requires that reasonable alternatives be assessed. This assessment will consider the environmental impacts of the proposed charge against the reasonable alternative of not implementing the charge, i.e., ‘do nothing’, or continue with ‘business as usual’. As the commitment to introduce a charge has been made by the Scottish Government, and it is not a requirement of existing legislation, it is considered reasonable to assume that if this charge were not implemented, no equivalent measure would be introduced as an alternative.

Under a ‘do nothing’ or ‘business-as-usual scenario’, it is anticipated that some voluntary arrangements would be put in place. For example, single-use disposable beverage cup recycling schemes, discounts for bringing your own reusable cup, or single-use disposable beverage cup charges could be arranged by businesses voluntarily. Indeed, some retailers have such schemes already in place.

However, these would not be on a national scale and without a mandatory minimum charge, if the charge for single-use disposable beverage cups is set too low, the impacts are expected to be minimal. For example, EPECOM research suggests that a 5 pence charge on single-use disposable beverage cups does not change consumer behaviour^[15]. Mandatory takeback schemes may be introduced as part of the reforms to pEPR, though it is not anticipated that this would impact consumption of single-use disposable beverage cups, only the recycling of them.

Feedback on the scoping report indicated that statutory consultees were satisfied with the proposed reasonable alternative.

3.4 Environmental principles

The assessment in this SEA has followed the guiding principles in Section 13(1) of the Continuity Act. These principles are:

• The principle that protecting the environment should be integrated into the making of policies;
• The precautionary principle as it relates to the environment;
• The principle that preventative action should be taken to avert environmental damage;
• The principle that environmental damage should as a priority be rectified at source; and
• The principle that the polluter should pay.

The assessment objectives encompass the principles that environmental damage should be prevented or reduced by the policy in question. The assessment highlights any outcomes of the proposed policy that may be expected to cause environmental damage.

The introduction of a charge on single-use disposable beverage cups is guided by many of these principles. The charge is being implemented with the aim of protecting the environment from the negative impacts of single-use material consumption and waste. The charge is guided by principles of taking preventative action to avert environmental damage and the rectification of impacts at source; seeking to address the environmental impacts of single-use items by reducing their consumption in the first instance.

3.5 Assessment methodology

This SEA has been undertaken on a topic-by-topic basis, assessing the anticipated impact of the proposed charge against each of the agreed environmental topic objectives presented in section 3.2. The assessment has been guided by the environmental principles set out in section 3.4.

Step 1: Review of relevant literature

Existing life cycle assessments, studies, and academic literature have formed the basis of the initial research stage of this assessment.

A number of key variables and uncertainties were identified as unknowns in this topic area. These are set out in section 5.1, and any assumptions made stated throughout the assessment.

Estimates formed as part of a report^[16] commissioned by Zero Waste Scotland on the consumption of single-use disposable beverage cups in Scotland were used to ascertain the expected changes in volumes of cups placed on the market in response to a charge under three different scenarios.

Conclusions from other literature sources were combined with these estimates to present three possible scenarios (low, medium, and high impact) for the quantifiable environmental effects of the proposed charge.

Step 2: Supplementary data

It was proposed in the scoping report that any additional data that could not be obtained from the literature review would be sought using a life cycle inventory database, with processes modelled in life cycle assessment (LCA) software.

Throughout the course of the experiment, this step was not deemed necessary. Wherever results from LCA studies needed to be amended to better reflect the situation in Scotland, existing results (such as those taken from the Scottish Waste Environmental Footprint Tool) were used to supplement the data instead of using LCA databases and software to build up results from scratch.

Step 3: Relating back to environmental objectives

Following the literature review and subsequent calculations, the estimated changes in consumption, behaviours, and corresponding environmental impacts were related back to the environmental objective set out in section 3.2.

Step 4: Consideration of cumulative effects

Interactions between identified impacts under the different environmental topics were considered qualitatively to identify any conflicting or enabling outcomes.