The Scottish Government

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3 The Arguments For and Against a Levy

The focus on plastic bags, in particular, is supported by:

• The high volume used.
• The perception that they are generally supplied 'free of charge'.
• The fact that they are a secondary form of packaging.
• The assertion that they add to litter in a highly visible manner.
• Their persistence in the environment.
• The view that they are potentially easy to replace.
• The view that they represent an 'easy target for visible success'.

3.1 The Arguments For a Levy

A bill for levy for certain plastic carrier bags in Scotland has been presented by Mike Pringle MSP [Pringle] following the introduction of the Irish PlasTax as a means of altering behaviour to help protect the environment. A further benefit stressed by Mike Pringle is the reduction of litter while encouraging the reuse of plastic bags. He argues that many plastic bags are not reused but end up in landfill sites or, worse still, as litter on the streets of Scotland.

Proponents of a levy cite the following potential benefits:

• Reduced resource consumption.
• Reduced energy consumption.
• Reduced emissions of greenhouse gases.
• Less litter.
• Increased public awareness of environmental issues in general.
• Strong message to change behaviour.

A Throwaway Society

Mike Pringle asserts that plastic bags contribute significantly to our throwaway culture of waste and argues that their use needs to be curbed, resulting in benefits for both the environment and business. He hopes that, by extension, people would be encouraged to think more about the other products and services they use and become more aware of reuse and recycling issues in general.

The proponents of a levy suggest that plastic carrier bags are only used twice at the most - to take purchases home and then, largely, for rubbish disposal. As such, they argue that plastic carrier bags are a needless waste of resources. This waste includes both the crude oil by-product resource from which the bags are made and the transport resources to deliver them from the manufacturing site ⁹ to the retail outlets where they will ultimately be distributed.

Recycling levels for plastic carrier bags are low in Scotland and supporters of the levy argue that those that are not disposed of responsibly could increase the problems of litter. They often quote the sight and impact of wind-blown bags caught in trees and bushes to illustrate this point.

Litter and Damage to Wildlife

Further problems with littered carrier bags, especially in marine environments, are also cited. The Marine Conservation Society ( MCS) conducts annual surveys every September in the UK to collect and remove litter from beaches. During this work, the MCS catalogues the amounts and types of litter found. The results are given in the MCS's Beachwatch reports [ MCS 2003, MCS 2004, Independent].

In 2003, the survey covered 135 km of UK coastline and, in 2004, this rose to 145 km. Table 3.1 presents the survey data relevant to plastic bags. This category includes supermarket carrier bags as well as other kinds of plastic bags.

Table 3.1 MCS beach litter survey results

The results show a drop of 4% from 2003 to 2004 in the numbers of plastic bags of all kinds collected. However, it is difficult to say whether this figure is statistically significant as it will depend on which beaches were visited.

It is also stated that a range of marine life such as whales, dolphins and turtles are severely injured or killed because they ingest or become entangled in plastic - as many as a million birds and 100,000 marine mammals worldwide every year [Envt Canada, MCS 2005]. One of the reasons given for why marine wildlife consume plastic bags is that they may mistake them for jellyfish, a main source of food for marine mammals. The consequence of this error is that the bags block the throat preventing normal feeding [Envt Canada, MCS 2005]. In 2004, the helpline run by Scottish Society for the Prevention of Cruelty to Animals (Scottish SPCA) received nine calls relating to animals that had become trapped in plastic bags, this is 0.01% of all calls taken. The Scottish SPCA note that the number of calls received will only represent a fraction of the actual number of wild animals who become entangled.

A survey undertaken in the Bay of Biscay during the early 1990s reported that plastic bags of all kinds, including lightweight plastic carrier bags that had been washed out to sea from land-based sources, accounted for 95% of all litter in sub-surface tows [Galgani].

Charting Progress - An Integrated Assessment of the State of UK Seas [Defra 2005] states:

"Marine litter can pose a hazard to beach users and recreational water users. Fish, seals, cetaceans and seabirds can become trapped ( e.g. in sections of discarded fishing nets and plastic or rubber rings). They can also ingest plastic particles and objects, which can be fatal. Marine litter can also degrade the aesthetic quality of the environment, particularly in tourist areas."

Clearly, this is not all due to plastic carrier bags as they make up only a proportion of this litter.

3.2 The Arguments Against a Levy

A number of organisations have lobbied against imposing taxes on plastic bags in many countries. These include the CBC in the UK, the Australian Retailers Association ( ARA) and the Belgian Retail Association ( BRA).

The Benefits of the Plastic Carrier Bag

The advantages highlighted by proponents of plastic carrier bags [ ARA, CBC, EuroCommerce] include:

• Hygiene.
• Convenience.
• Reliability/efficacy/durability (paper bags often rip and are 'double-bagged').
• They can be reused for other purposes in and around the home, e.g.

• Their disposal results in lower greenhouse gas emissions compared with disposal of bioerodable bags of paper, starch or plastic origin.
• There are lower environmental effects compared with paper bags in terms of production and transport as plastic bags use fewer resources, take up less volume and weigh less.

Hygiene is an important issue and, as is the case in Republic of Ireland, bags for wrapping fresh meat, fish, poultry and loose fruit would need to be excluded and remain free of charge because of their hygienic functional role ¹⁰.

Negligible Impacts on the Waste Stream

Plastic films, which include carrier bags and other plastic packaging, make up 4.37% of the household waste stream on average ¹¹ in Scotland [ SEPA]. To put these figures in context, paper and card makes up almost 25% of the household waste stream by weight while putrescibles ( e.g. waste food) nearly 32%. Furthermore, plastic bags alone constitute about 0.3% of the municipal waste stream in the UK [ HM Treasury].

The amount of municipal solid waste (household and commercial waste) collected by local authorities across Scotland for disposal in 2002/03 was 2,589,702 tonnes ¹². Using the UK data, 0.3% of the municipal waste stream by weight equals 7,769 tonnes per year of plastic bags. Any reduction in the amount of plastic bags disposed of would have very little effect on the overall waste disposal figures. Further analysis of the waste issues is provided in sections 4.6 and 5.2.

One of the aims of the EU Landfill Directive is to reduce the amount of biodegradable municipal waste going to landfill. The imposition of a levy that excluded paper bags is expected to increase the number of paper bags used and disposed. Although some would be recycled by consumers ( e.g. through kerbside collections), there would ultimately be more paper bags going to landfill where they would degrade giving off greenhouse gases.

Single Trip or Multi-trip?

The Scottish Waste Awareness Group ( SWAG) survey Public Attitudes to Reduce, Reuse, Recycle in Scotland (2001) stated that:

" The number of people engaging in this range of practices [reuse] was limited, the most commonly practised behaviour was the reuse of materials. This was achieved primarily through the reuse of plastic bags (84% of respondents), although the majority of these were ultimately used as bin liners". [ SWAG]

A Waste Watch study for the UK reported that 54% of people questioned said that they reuse plastic carrier bags, with secondary reuse as bin liners a typical example [Waste Watch]. This study states that:

" Recent research suggests that four out of five people reuse products. Plastic bags and glass jars or bottles are reused by around half the public and plastic containers or bottles by one in five."

Both the SWAG and Waste Watch studies suggest that a proportion of respondents reuse lightweight plastic carrier bags, often as bin liners. If so, the majority of bags would only be reused once. It must also be made clear that, when the SWAG survey states that 84% of respondents reuse bags, this does not mean that 84% of bags are reused. What it means is that 84% of people reuse some of their carrier bags at some point; a similar logic applies to the results of the Waste Watch study.

A more recent study undertaken by the Waste and Resources Action Programme ( WRAP) found that, of the 1,048 people interviewed, 59% said they reuse all their lightweight plastic bags with a further 16% saying they reuse most of them [ WRAP 2005]. The main use by far was as a surrogate bin liner, though other uses were reported such as other shopping, collecting pet mess or carrying other things when going out.

Litter Culprits?

A Local Environmental Audit and Management System ( LEAMS) report by Keep Scotland Beautiful ( KSB) states that the main items of litter in Scotland are:

• Cigarette litter (cigarette ends, matches, matchboxes, cigarette packaging) found at 70% of sites inspected.
• Confectionary litter (sweet wrappers, chewing gum wrappers and crisp packets) found at 50% of the sites inspected.
• Drinks-related litter (cans, bottles, cups, straws and lids) found at 34% of sites.
• Fast food packaging litter (fish & chip wrappers, polystyrene cartons, burger wrappers, plastic cutlery) found at 10% of sites.

Even though those plastic carrier bags that are littered are visible and persistent in the environment, the report did not mention them specifically [ KSB].

Windblown plastic litter in the environment is often from other plastic sources such as the agricultural wrappings for hay bales, etc. [ CBC]. WRAP has commented that a reduction in plastic bags used would not result in a noticeable improvement in the overall litter situation [ WRAP 2004a].

These results have been echoed elsewhere in the UK by ENCAMS¹³. Its surveys have also shown that the main littering problems in England are from smoking products, food and drinks containers (plastic and glass) and dog mess, with the most prominent commercial litter coming from elastic bands dropped by postmen [ ENCAMS].

A further recent survey conducted in England, commissioned by the Industry Council for Packaging and the Environment ( INCPEN) and carried out by ENCAMS collected 37 carrier bags out of a total of 58,041 items, which equates to 0.064% of all items of litter found [ INCPEN- ENCAMS]. The chief culprits were confirmed as chewing gum and cigarette ends. The data show that lightweight plastic carrier bags are not major contributors to reported land litter in Scotland.

A Finite Resource

Plastic bags are made from a by-product of crude oil refining. Supporters of plastic bags would argue that they maximise the benefits from a finite resource, rather than flaring off the excess gases (including ethene) produced by the crude oil cracking process.

Behavioural Change?

Countries that have not introduced a levy have argued that it is people's littering behaviour which needs to be changed and that this will not necessarily come about from the imposition of a levy [ ARA]. The Belgian Retail Association agrees; it believes that the main problem and cause of litter is not in the plastic bag per se, but the public's behaviour in simply discarding it rather than disposing of it properly. Education and awareness raising are seen as the key to the litter problem rather than levying the use of lightweight plastic carrier bags [EuroCommerce].

Job Losses

Those against the levy argue that it will lead to job losses in an industry that has successfully developed and optimised its product to provide an efficient and effective means of transporting goods from place of purchase to the home. This topic is discussed in more detail in Section 5.2.

3.3 The Voluntary Approach

The introduction of a levy at a UK level was reviewed and rejected in 2003. The Department for Environment, Food and Rural Affairs (Defra) has stated that "…we have no current plans for a plastic bag tax, but the Government keeps all taxation under review" [Defra 2003, Hansard 2004]. Various voluntary mechanisms are currently being investigated.

WRAP is working with the British Retail Consortium ( BRC) on a 'reusable bags' project. The aim of this project is to achieve a united approach across retailers through the creation of a retail partnership. This will provide a high level exposure of 'reusable bags' to the consumer at most retail outlets. It is hoped that the 'reusable bags' concept can be presented more effectively to consumers, actively encouraging behavioural change in a self-sustaining way that will avoid the introduction of a levy. Actions under consideration include:

• In-store awareness promotions.
• High visibility of store 'reusable bags'.
• Loyalty points for carrier bag reuse.
• Staff training in carrier bag advice.
• Checkouts without lightweight carrier bags.
• A pilot project in Edinburgh and Bristol in Autumn 2005.

In addition, BRC and the Scottish Retail Consortium ( SRC) have formed a working group to look at the possibility of developing a voluntary code of conduct. They will be working with members and other key stakeholders including the CBC. The CBC has submitted a draft Voluntary Code on Best Environmental Practice for the Provision, Use and Disposal of Plastic Retail Carrier Bags for consideration by the working group. While the draft code is not yet available, the CBC note that the draft proposal outlines plans for:

• Encouraging industry and retailers to work together to find ways of further reducing energy, material and environmental impacts in the production, transportation and storage of plastic carrier bags.
• Active support and participation in waste reduction and reuse initiatives.
• Development of new schemes to promote recycling.
• A commitment for separate film collection for degradable bags.
• Development of a customer information campaign.
• An independently audited scheme to monitor, measure and report success.

The CBC strongly supports a voluntary approach for Scotland and the UK as a whole. It suggests that reusable bags should be offered, but that free, disposable lightweight plastic carrier bags should also be available so that consumers can make their own choice.

The imposition of a levy in Australia was considered and then postponed for two years (until the end of 2004) to see if the voluntary take-up of reusable bags and increased rates of recycling could reduce the number of lightweight plastic carrier bags by a target of 50%. A report from the Australian consultants Nolan- ITU published in March 2005 states that bag usage fell by 20.4% between 2002 and 2004 through the voluntary code of conduct agreed by retailers [Nolan- ITU].

This reduction is broken down into supermarkets reducing usage by 25% and non-supermarket retailers reducing usage by 10-15%. This result shows that a voluntary scheme can have a significant effect, given the support and time to get its message across. The Australian Government is determined to continue this trend to the extent of reducing use to 50% by the end of 2005 and ultimately phasing out plastic bag use completely by 2008 [Aus Govt].

3.4 Other Alternatives to a Levy for Reducing the Impacts of Plastic Bags

Degradable bags have been suggested as a possible solution. The issues surrounding their disposal, recycling and littering implications are discussed in Section 2.1.

Other ways of reducing usage include promoting the reuse of lightweight plastic bags, the purchase of thicker 'bags for life' or rigid boxes as well as recycling plastic bags (either within shops or by local authorities). These alternatives are all fully feasible and in operation, but have only had a small uptake so far.

Recycling is one option for polyethene plastics as a way of reducing their environmental burdens. This would be achieved through replacing raw materials (virgin polymer) with recycled polymer (see Dixons case study below), as well as reducing the (albeit very small) load on landfill at their end-of-life. Recycling of all plastic films - not just carrier bags - currently stands at 300,000 tonnes per year in the UK [ CBC].

Dixons plc, in association with Nelson Packaging introduced the UK's first fully recycled carrier bag in 2003 [Dixons]. Rather than being sent to landfill, waste plastic collected from commercial back-of-store and post-consumer in-store sources in the UK is used to make bags for Dixons. An independent LCA of these bags has been undertaken by Nottingham University. This estimates that every tonne of recycled bags produced saves around 1.8 tonnes of oil compared with a tonne of bags made from virgin material [Nottingham]. Dixons argues that using recycled material to produce plastic carrier bags not only reduces the environmental burden directly (through the use of less crude oil by-products and less waste being discarded), but it also educates the consumer to some extent.

Some retailers have adopted voluntary charging. Lidl currently charges 5p per bag in its UK stores. B&Q has piloted a scheme in its shops in Scotland at the same level, while IKEA charges 5p per lightweight plastic carrier bag at its Edinburgh store with good success (see Appendix 2 for more details). There is a similar story in Australia where European companies based there such as Aldi and IKEA already charge for their bags [ RMIT], although this is a voluntary approach rather than mandatory. Consequently, some shoppers are already aware of, and accustomed to, the idea of paying for carrier bags for their goods.

Where incineration is the main disposal method in preference to landfilling, carrier bags offer high calorific values equal to or greater than that of oil. Hence, energy can be recovered from the bags and put back into the national electricity grid. This would reduce the need for conventional fossil fuels for power - again albeit by a small degree. However, there are currently only two energy-from-waste incinerators in Scotland [ SEPA].

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