Wet wipes containing plastic - proposed ban: strategic environmental assessment

Non-Technical Summary

Introduction

Marine litter poses a number of problems across the economy, environment, and society. These detrimental effects include damage to marine wildlife, as well as wider ecosystem deterioration, public health issues, impacts on aesthetics, and a wider range of economic impacts across industries reliant on our coastal and marine environment.

Marine litter threatens the realisation of a shared vision for ‘clean, healthy, safe, productive, and biologically diverse marine and coastal environments, managed to meet the long term needs of nature and people’. It is essential that Scotland’s marine and coastal resource is protected from the damage caused by marine litter, including sewage-related debris such as wet wipes containing plastic.

The Scottish Government has national and international commitments to protect the marine environment, and to take necessary measures to protect and conserve it. These include the reduction of sources of marine litter.

Taking these commitments into account, the Scottish Government is consulting on a proposal to ban the manufacturing, supply and sale of wet wipes containing plastic. The consultation, which will seek views on this proposal, is being undertaken with the purpose of bringing about environmental and ecosystem benefits through the reduction of the presence of plastic litter.

What is a Strategic Environmental Assessment?

This Environmental Report summarises the findings from the Strategic Environmental Assessment (SEA) of the proposal to ban the manufacturing, supply and sale of wet wipes containing plastic. An SEA of the proposals is required by the Environmental Assessment (Scotland) Act 2005 (‘the 2005 Act’).

An SEA identifies the likely significant environmental impacts of plans and policies, and proposed reasonable alternatives to them. An SEA also identifies mitigation measures that are required to avoid or minimise any significant adverse effects and highlights opportunities for enhancements of beneficial effects. Taking place at an early stage in the plan or policy preparation process, it ensures that decision-making is informed by relevant environmental information. An SEA provides opportunities for the public to consider this information and use it to inform their views on the draft plan or policy.

A screening and scoping exercise on the proposed ban on the manufacturing, supply and sale of wet wipes containing plastic was undertaken by the Marine Directorate, in accordance with the requirements of the 2005 Act. In response to the screening, the Scottish Consultation Authorities^[1] confirmed the need for an SEA due to the likelihood for significant environmental effects to occur. They also provided comment on the proposed scope and methodology of the assessment. Their views are taken into account in this Environmental Report, as per the requirements of the 2005 Act.

What are the proposals?

Through the refreshed Marine Litter Strategy for Scotland the Scottish Government has committed to reducing the most problematic sources of marine litter, with the intention to benefit the marine environment.

Wet wipes containing plastic do not fully disintegrate in water or in the sewerage system if they are flushed down the toilet. If these wipes arrive in the marine environment they are a persistent and problematic source of marine litter.

Our long-held policy position in Scotland has been that appropriate and suitable alternatives exist to wet wipes containing plastic, and these are available on the market in Scotland and the UK, and that businesses and consumers should be encouraged to switch to, respectively, manufacturing and buying these alternatives. The Scottish Government has supported multiple behaviour change campaigns to discourage incorrect disposal of these plastic products, but these have seen limited success.

Taking into consideration the pressures created by marine litter on the environment and wildlife, the Scottish Government is therefore consulting on the proposed ban on the manufacture, supply and sale of wet wipes containing plastic. The proposed ban is based on evidence that wet wipes contribute to marine litter and sewer blockages, and the majority of wet wipes sold contain plastic. The proposal covers wet wipes intended for domestic use, with exemptions for those used in medical care or industrial / commercial settings.

How was the Strategic Environmental Assessment undertaken?

The SEA provides a high-level and qualitative assessment of the potential environmental effects that are likely to result from the proposed ban on the manufacture, supply and sale of wet wipes containing plastic.

The assessment identifies the effects of the proposed ban on the SEA topics that are scoped into the assessment, specifically: biodiversity, flora and fauna; water quality, resources, and ecological status; and material assets. The assessment also considers the effects of the proposed ban on a series of key statements or SEA objectives. These SEA objectives reflect the scope of the assessment as well as the environmental protection objectives from relevant legislation. The assessment also considers the interaction of this proposal with relevant existing plans and strategies.

Economic impacts are assessed in a Business and Regulatory Impact Assessment (BRIA).

Which reasonable alternatives have been assessed?

Reasonable alternatives, including business and public behaviour change measures have not solved the current issue. Wet wipes containing plastics are still manufactured, they are still purchased, and they are still disposed of down toilets and are littered. Alternative measures to reduce this form of pollution have made no impact. On this basis, we do not consider that there are any reasonable alternatives to the proposed ban on the manufacture, supply and sale of wet wipes containing plastic.

What is the current impact of wet wipes on the marine environment?

Scotland’s marine environment supports a diverse array of habitats, which in turn support a wide range of marine plants and animals. The presence of marine litter, especially plastic litter, exerts a negative pressure on all components of the marine environment. Scottish Government analysis investigated the average numbers of wet wipes found each year per 100m of beach surveyed in Scotland. This analysis shows that the trend in annual average wet wipe numbers over the period 2005 to 2022 is increasing by approximately 50 wet wipes every 10 years. Progress towards Good Environmental Status (GES) for elements including marine litter is monitored and measured under commitments in the UK Marine Strategy^[2].

What are the likely significant environmental effects of the proposed ban on the manufacture, supply and sale of wet wipes containing plastic?

The proposed ban on the manufacture, supply and sale of wet wipes containing plastic is expected to provide a likely reduction in the risk of harm posed to species, habitats, and the marine environment as a whole. Marine litter is one of many stressors that have impacts on the marine environment. The proposed ban will not eliminate all marine litter, but it will reduce the pressure of plastic litter on ecosystems, as well as on the species and habitats within them.

What are the cumulative effects of the proposed ban on the manufacture, supply and sale of wet wipes containing plastic?

As the proposal is for a single measure, there is no scope for cumulative effects of this proposal. The reduction in the presence of wet wipes containing plastic in the marine environment may contribute toward achieving GES. Wet wipes containing plastic are only one type of marine litter, and as such a ban on these alone would not achieve GES. In the long term, as part of a suite of current and possible future measures banning a variety of single-use plastic items, this proposal may result in positive impacts to Scotland’s marine environmental.

Conclusion

Overall, this assessment considers that the reduced risk of harm that would result from a ban on the manufacture, supply and sale of wet wipes containing plastic will potentially provide environmental benefits for the topics of biodiversity, flora and fauna, water quality, resources and ecological status, and material assets, and could help contribute to the achievement of the SEA objectives. This is because the proposed ban has the potential to result in reduced risk of harm to a range of marine species and habitats, as well as to the built sewer infrastructure.

Reasonable alternatives have previously been tried and have not made a discernible impact, therefore the proposed ban is the only route that has the potential to lead to significant beneficial environmental effects being realised.

How do I respond to the consultation?

The consultation on the proposed ban on the manufacture, supply and sale of wet wipes containing plastic can be read https://consult.defra.gov.uk/wet-wipes-1/wet-wipes-containing-plastic. Responses to the consultation on the proposed ban should be submitted via the online form https://consult.defra.gov.uk/wet-wipes-1/wet-wipes-containing-plastic or in writing to Consultation Coordinator, Defra, 2nd Floor, Foss House, Kings Pool, 1-2 Peasholme Green, York, YO1 7PX, by 25 November 2023.

The consultation on this SEA Environmental Report is now open, along with the accompanying partial Business and Regulatory Impact Assessment. Views and opinions on this are now invited and should be provided by 25 November 2023.

Please send comments on the SEA and BRIA via: WWSEAandBRIA@gov.scot

Or send by post to:

Wet Wipe SEA and BRIA

Scottish Government

Area 1B North

Victoria Quay

Edinburgh

EH6 6QQ

Following the consultation period, the responses received will be analysed, and a Post-Adoption Statement and a Final BRIA will be prepared. These documents will explain how issues raised in the SEA and partial BRIA, and associated views in response to the consultation, have been addressed.