Ban on the supply and sale of wet wipes containing plastic: Strategic Environmental Assessment Post-Adoption Statement

5. How the opinions expressed on the Environmental Report were taken into account

The Environmental Report was published for consultation alongside the partial Business and Regulatory Impact Assessment, and the UK-wide consultation paper. Views were invited on:

• The level of support for the proposed ban.
• The scope of the ban and whether it would include supply and sale of wet wipes containing plastic, or manufacturing in addition.
• The proposed exemptions for medical and industrial uses.
• The proposed length of transition period, to allow manufacturers and retailers sufficient time to adjust their businesses.
• The definitions within the ban for wet wipes and plastic.

1,561 responses to the consultation were received through the survey hosted on Citizen Space and via email. A joint UK-wide government response to the consultation was published on 22 April 2024 and contained a summary of the consultation responses^[11]. Overall, over 93% of respondents either agreed or strongly agreed in support of a ban on the supply and sale of wet wipes containing plastic.

Stakeholder engagement has highlighted that the market is moving towards reducing the manufacture, supply and sale of wet wipes containing plastic. Several manufacturers and retailers have already made voluntary commitments to stop producing or selling wet wipes that contain plastic, showing that it is possible and commercially viable. As a result, there are suitable non-plastic wet wipe substitutes currently available, including moist toilet tissue and baby wipes.

Whilst the market is partially addressing the problem and businesses have innovated to develop plastic-free wet wipes, evidence suggests that the pace of transition across the industry as a whole will remain slow in the absence of government intervention. Additionally, there is no guarantee that this current level of voluntary action will be sustained or increased in the future. Responses to the consultation indicate that 38% of wet wipes sold contain plastic and suggest that only half (53%) of manufacturers have plans to cease manufacturing wet wipes containing plastic within the next five years. The urgency to reduce consumption of unnecessary single-use plastic items means Scottish Government needs to take action to achieve this goal.

Some stakeholders highlighted concerns via the consultation that suitable alternatives did not exist in some circumstances, such as in medical settings and certain industries, for example where the strength provided by plastic is a necessary feature and is not currently available through other materials. Scottish Government therefore intends to exempt from the ban business-to-business sales, including use in medical settings. Stakeholders have informed us these wipes make up around 20% of those sold in the UK. However, in the case of wet wipes on sale to the general public, as plastic-free alternatives are already widely available for many products, a ban is still considered the preferred route.

We acknowledge that some consumers may have a genuine need for wet wipes containing plastic for medical care purposes, therefore we intend to include an exemption which will allow for such wet wipes to be sold in pharmacies. Wet wipes containing plastic will not be permitted for sale on the shelves, and members of the public who require these products for medical purposes will need to specifically request these from a pharmacist.

We are aware of the economic impacts that the ban could have. We are therefore allowing an 18-month transition period in order to reduce manufacturer and retailer transition costs, as well as to allow sufficient time to sell remaining stock of wet wipes containing plastic and to transition to producing plastic-free wet wipes.

65% of respondents agreed with the proposed definition of a wet wipe: “A wet wipe is a piece of pre-moistened or pre-wetted non-woven material which is conceived, designed and placed on the market for single-use (disposable) and intended for personal care e.g., personal hygiene or domestic use e.g., household cleaning purposes. Prewetted wipes typically contain an impregnation liquid which has been added to the wipe before it is placed on the market.” Limits on dimensions or shape have not been included, which means that any and all of these items available for domestic use would be captured by this definition.

65% of respondents agreed with the proposal to use the UK REACH (UK Registration, Evaluation, Authorisation and Restriction of Chemicals) definition of plastic: "a material consisting of polymer to which additives or other substances may have been added, and which can function as a main structural component of final products, with the exception of natural polymers that have not been chemically modified”. The UK REACH definition is internationally recognised and is consistent with the definition used in The Environmental Protection (Single-use Plastic Products) (Scotland) Regulations 2021. Under the ban, the alternative products on the market would be made from cotton, paper, or other non-plastic substrates. It is expected that these would not pose the same risk of harm to the marine environment, nor would they add to the burden of marine plastic litter that currently exists.