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Consultation Paper on Producer Responsibility for Non-Packaging Waste Agricultural Plastics
SCOTLAND ONLY OR GREAT BRITAIN?
44. The primary aim of this consultation exercise is to seek views on whether voluntary or statutory producer responsibility would be the more effective means of managing non-packaging plastics waste. However, we also wish to canvass opinion on whether there ought to be, or needs to be, a Scotland-only scheme or whether we should join with England and Wales to introduce a single scheme across Great Britain.
45. The benefits of a Scotland-only scheme are that, irrespective of whether it is voluntary or statutory, Scottish Ministers will be able to strike the best balance of cost and benefit to fit the nature and scale of agricultural practice in Scotland. That means not having to compromise our own needs and preferences to fit in with a wider whole, nor skewing a scheme which may be optimised for the large-scale agricultural operations found in England.
46. On the other hand, Scotland's different agricultural structure may count against a Scotland-only scheme. That is likely to be particularly so in agreeing a voluntary scheme since the probable lower uplift volumes per holding, greater distances between holdings and the greater average distances from the holding to the reprocessor will mean potentially significant higher unit costs for operating the scheme. On that basis a Scotland-only scheme will probably require to be a statutory one, both to remove the temptation for participants to withdraw and to ensure that producers become involved in the first place.
47. A second reason for forming a Great Britain scheme could be that any material difference in targets or treatment requirements between the different jurisdictions could lead to abuse as operators in the more stringent jurisdiction attempt to reduce their compliance costs by taking advantage of the less onerous requirements (whether real or perceived) of the other. In other words, there could be under-reporting of waste arisings on the more stringent side of the border and over-reporting on the cheaper. Although this would be contrary to the Code of Practice of a voluntary scheme and would be made illegal under a statutory scheme there is an obvious case for not allowing it to happen in the first place. Even if abuse did not take place there would need to be a means of distinguishing imports of waste into Scotland from wastes arising within Scotland to prevent recycling/recovery figures being distorted. This entails a data reporting burden which would not be required under a single scheme.
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