Charging for single - use disposable beverage cups: consultation analysis

Executive Summary

A public consultation on Charging for Single-Use Disposable Beverage Cups was open between 22 August and 14 November 2024. The consultation consisted of 16 open and nine closed questions, seeking views from stakeholders, including members of the public, on the proposals from Scottish Ministers to “establish a simple yet robust system, consistent with New Deal for Business principles, which promotes much greater cup reuse while keeping administrative burdens to a minimum.”

There were 1,068 unique respondents to the consultation. A total of 984 responses were submitted by 863 individuals and 121 organisations via Citizen Space. The remaining 84 responses were part of a campaign coordinated by the AVA: The Vending & Automated Retail Association^[1]. This report provides a thematic analysis of responses; full responses, where permission for publication was granted, can be found on the Scottish Government’s consultation website. Public consultations invite everyone to express their views, and those interested in the topic are often more likely to respond. This self-selection means the views of respondents do not necessarily represent the views of the entire population.

Charge level

Respondents were presented with a list of possible minimum prices and asked which they felt would be the most reasonable. The most preferred option (35%) was for no charge for drinks bought in single-use cups. Among the 59% of respondents who selected a specific price, the most selected options were £0.25 (15%) or £0.50 (13%). The option of no charge was favoured by 32% of individuals and 53% of organisations, with the latter driven by opposition among vending retail campaign responses. Beyond vending retailers, preferences varied by organisation type with environmental NGOs preferring a higher minimum price than convenience / hospitality retailers, for example.

The most common theme in comments from those who selected a preferred price per cup was that their selected price was sufficient to encourage behaviour change. There was a clear pattern in responses, with this theme more likely to be mentioned by those favouring a higher price, i.e. a higher charge is more likely to generate behaviour change. The second most prevalent theme among this group was that their chosen price was the ‘right’ level, describing it as fair, reasonable, proportionate and not prohibitive. Many also noted their chosen price was based on their desire to minimise negative impacts on businesses.

Among respondents who indicated that there should be no charge, many felt a charge could have a negative financial impact on individuals, either through a direct charge or through additional costs incurred by businesses that could be passed on to consumers. Many of these respondents noted that increased costs would be a particular challenge to individuals due to the ongoing cost-of-living crisis. The potential negative impact on businesses, especially small businesses, was noted by some respondents, including that an increase in prices could reduce the number of customers and sales, and that additional costs could be incurred by businesses because of introducing the charge.

Several themes not related to a specific charge level were evident in the remaining open comments. Most mentioned was that encouraging reusable cups is not practical for some consumers or for hygiene reasons, followed by calls to consider alternative proposals.

Three quarters (75%) of those answering disagreed with an alternative approach where regulations could require suppliers to charge but leave suppliers to choose the price they charge for a single-use cup, supported by guidance provided by the Scottish Government. A further 13% preferred this approach, and 12% were unsure. The most common reasons for opposing this approach were that a standard minimum price is simpler, clearer and fairer, and potential negative consequences of allowing businesses to choose the price they charge, such as competition between businesses undermining the policy intention.

Scope of the charge

Respondents were asked for their views about exemptions for single-use cups. Among those answering, 52% felt the proposed exemption for single-use cups sold in schools was appropriate, 41% did not and 7% were unsure. While 48% of individuals felt the exemption was appropriate, support was higher among organisations, with 71% in favour. Opinions were also split on the proposed exemption for drinks sold from vending machines. Among those answering, 47% felt this was appropriate, 45% did not, and 8% were unsure. While 43% of individuals were in favour of this exemption, support was higher among organisations, with 67% in favour. For both these proposed exemptions, opinions varied by type of organisation, with all vending retailers and large proportions of public bodies answering in favour and environmental NGOs expressing greater opposition.

When considering the proposed exemption for settings where a reusable cup is not practical^[2], two thirds (66%) of those answering felt this proposal was appropriate, compared to 26% who did not and 7% who were unsure. While two thirds (64%) of individuals were in favour, over three quarters (78%) of organisations felt this exemption is appropriate. There was less variation among organisations regarding this proposed exemption, with two thirds or more of most groups in favour, including 90% of all retailers.

Almost two thirds of respondents commented on exemptions. While the closed question results recorded support for exemptions, among those who left a comment the most prevalent theme was there should be no further exemptions beyond the three listed in the consultation paper. It was suggested that having no further exemptions could help support environmental benefits and promote cultural and behavioural change. Many commented that no exemptions should exist at all, as these could undermine the purpose of the charge, create inconsistencies and confusion among consumers, or disincentivize the use of reusables. Conversely, many others believed there should be no exemptions but did so because they felt there should be no charge at all.

Many also expressed opposition to schools being exempt, most commonly highlighting the need to educate young people to reduce waste and litter and minimise the use of single-use cups. Many also raised the need to exempt health or care settings. Respondents from outside the vending retail sector expressed mixed views on exempting vending machines.

Use of net proceeds

The consultation asked respondents what could happen to the revenue raised by the charge. Directing the funds to environmental protection or improvement was preferred by 41% of those answering. Reasons included concerns about the climate crisis, perceptions that insufficient action is being taken to address environmental harm, and the need to prioritise environmental protection. The most common suggestions were to fund anti-littering or waste management services and environmental education or research.

A further 12% preferred the option of proceeds being retained by businesses and encouraged to be donated to good causes. Some respondents felt that this could minimise the administrative or financial burden on businesses and that this model had worked for single-use carrier bags. Among the 12% who felt the proceeds should be collected by local or national government, the most prevalent views were that the funds should be diverted to environmental or waste projects or could be used to support public services.

A further 33%, mostly individuals and vending retail campaign respondents, indicated they would prefer another approach, though many explained in their open comments that there should be no charge and, therefore, no proceeds to distribute. Beyond this, the next most prevalent themes were that the proceeds should not go to the retailer because of concerns it would not be used for good causes, or that the proceeds should go to the third sector.

Recording requirements and enforcement

Among the small number of suppliers of single-use cups who answered, one fifth (21%) agreed with the recording requirements set out in the consultation paper^[3], 9% were neutral, 6% disagreed, and almost two thirds (64%) strongly disagreed. Disagreement was driven by vending retail organisations, all of whom disagreed strongly. Conversely, 86% of public bodies who answered agreed with the reporting requirements.

In open comments, several respondents disagreed with the recording requirement, describing it as an additional administrative burden and overly complicated. A few respondents expressed the view that the administrative burden of recording would affect small businesses the most. However, support for the recording standards was noted by some respondents. A few supported the requirements, describing them as straightforward and clear or noting that the data collected would help monitor the scheme’s success. Some supported deducting reasonable costs associated with administering the charge.

Among all respondents, the proposed enforcement regime was supported by 41% of those who answered, 12% were neutral, 17% disagreed and 29% strongly disagreed. There was higher disagreement among retailers who answered with 69% disagreeing and 12% strongly disagreeing, driven by disagreement expressed by the vending retail campaign response. Strong disagreement was particularly high among convenience / hospitality retail at 43%. The most prevalent theme in open comments was concerns about the resourcing and funding of enforcement activity. Others restated their agreement with the proposed enforcement regime, and some others called for higher or alternative penalties.

Implementation

Suppliers of single-use cups were asked about the challenges of introducing a charge. The most common theme was a concern about the potential impact on trade, such as an increase in cost to customers leading to reduced sales or confrontations with customers when they learn about the charge. Some respondents mentioned the costs of adapting premises or buying equipment to accommodate more dishwashing for reusable cups, the time and training needed to update point-of-sale systems, and reprinting signage and menus. A few were concerned about an administrative burden and reporting requirements.

When asked how much time their businesses would need to prepare to implement the charge, 63% of suppliers of single-use cups who answered indicated it would take their organisation six months or more. A further 19% indicated it would take two to three months, while 15% indicated it would take one month and 3% a couple of weeks. Of those who provided further explanation, the most prevalent themes were that they would need time to establish the necessary systems and procedures and that there would need to be time to communicate the changes with businesses to minimise confusion.

Single-use cup suppliers also suggested how the Scottish Government could help their businesses implement the charge. Some respondents suggested that there needs to be a public information campaign to help consumers understand the charge. Some highlighted the importance of providing suppliers with clear regulations and guidance to simplify the implementation of the new charge, while a few requested grants or financial assistance.

Impact assessments

Fewer respondents left comments about the interim impact assessment questions. Those who responded regarding equalities impacts thought that the impacts would be most significant for disabled people and people with health conditions, as they may struggle to carry and clean reusable cups, and families with children, particularly those families living on low incomes who may not be able to afford reusable alternatives. Some respondents, most of whom were organisations, suggested that the charge could disproportionately impact the poorest people in society. Among the small number who commented on potential impacts on island communities, themes included that island communities should not be treated differently, challenges with waste and recycling facilities on islands and positive environmental impacts for island communities.

When commenting on the interim Strategic Environmental Assessment, there were calls to consider alternative approaches that respondents felt could be more effective than a charge such as improved recycling infrastructure, concerns about the environmental impact of reusable cups. Potential environmental benefits arising from the charge, such as reduced litter, energy consumption and resource use and benefits to wildlife, were noted.

Conclusion

The key message is that while many support the proposals and their potential to encourage behaviour change, many other individuals and organisations either opposed the introduction of a charge or highlighted multiple issues that they felt needed to be considered before progressing the proposals. The responses, therefore, provide valuable and informative evidence for the Scottish Government to draw on when developing the final policy and implementation plan.