Charging for single - use disposable beverage cups: consultation analysis

1. Introduction

Background

Implementing a minimum charge on single-use disposable beverage cups is a long-standing Scottish Government commitment. The 2019 report of the independent Expert Panel on Environmental Charging and Other Measures (EPECOM) set out a clear case for encouraging behaviour change through price-based interventions. The Panel recommended a mandatory minimum charge of between 20-25p on all single-use disposable beverage cups to reduce consumption of single-use cups and encourage consumers to use reusable alternatives instead.

The Scottish Government issued a formal response, agreeing with the Panel’s recommendations, and in 2019 committed to legislate for a charge to be applied on single-use beverage cups. The Circular Economy (Scotland) Act includes provisions that give Scottish Ministers powers to require suppliers to levy a minimum charge on single-use items. The Scottish Government has set out its intention to use these powers to implement a charge on single-use beverage cups. It has been developing policy proposals for the planned cups charge, drawing on advice from a Single-use Cups Charge Advisory Group which includes a wide range of stakeholder representatives, including from business, retail, equalities groups and local authorities.

A public consultation on the policy proposals was open between 22 August and 14 November 2024. The consultation paper outlined Scottish Ministers’ ambition 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”. The proposals in the consultation were:

• A charge of at least 25p should apply to all single-use beverage cups when an individual buys a drink of any kind, including through a loyalty scheme, to maximise coverage and ensure the charge is easily understood.
• The charge will apply regardless of cup material and, therefore, would include cups made of biodegradable material or bio-based plastics.
• Where a drink is provided for free, for example as part of care provision in settings such as hospitals and care homes, the charge will not apply.
• There will be limited exemptions based on purpose or setting, for instance, in schools and when a drink is bought from some vending machines.
• Retailers should be able to retain reasonable implementation costs from the charge, in line with the approach taken for the single-use carrier bags charge.
• To the extent it is legally deliverable within the competence of the Scottish Parliament, the net proceeds of the charge should be used for environmental or similar purposes.

Across 16 open and nine closed questions, the consultation sought views from stakeholders, including members of the public, on the proposals. The analysis of responses provided in this report will be used to help develop the final policy and implementation plan.

Respondent profile

Standard responses: 984 consultation responses were submitted via Citizen Space, an online consultation platform. Individuals provided 863 responses, with the remaining 121 responses from organisations^[4].

Campaign responses: A further 88 responses were received by email as part of a campaign coordinated by AVA: The Vending & Automated Retail Association. Of these:

• 11 were from individuals and were included in the analysis as individuals.
• 77 were from vending organisations.
  • Most organisations emailed one response, but representatives from 17 organisations submitted multiple emails e.g. one organisation submitted 35 emails^[5]. In line with the approach used to analyse standard consultation responses, where all organisations have an equal weighting (see below), each organisation has been counted as one response in the analysis and tables in this report, even if that organisation submitted multiple emails.
  • Four of the 77 campaign responses were sent by organisations that had also submitted a standard Citizen Space response, i.e. they are included in the 984 above. Again, each was counted as one organisation in the analysis, leaving 73 retail vending organisations, as cited in the data tables.

Based on the above, there were 1,068 unique responses to the consultation, i.e., 984 standard responses, plus 88 campaign responses from unique respondents, minus four campaign responses from organisations that also submitted a Citizen Space response.

Respondents were categorised as individuals or organisations based on the information provided in their Respondent Information Form (RIF). Organisations were also grouped by the nature of their work. Table 1 overleaf shows the number of each type of respondent. It should be noted that the views of organisations are often heavily influenced by the retail vending sector, which makes up almost two fifths of organisation responses.

Ten of the 1,068 respondents (eight manufacturer / packaging organisations, one retail trade association and one individual) submitted responses where similarly worded statements were used in answers to various questions. This is often the case where a respondent shares or endorses the same views as an organisation which has made its response public before the consultation closes, or where a representative association has provided a suggested response to its members. Each of these respondents has been counted as a separate response in the analysis, and relevant points raised in these responses have been noted in the report.

Those responding via Citizen Space on behalf of an organisation were asked if their organisation is involved in the supply of single-use disposable beverage cups at any stage, including when selling a drink to a consumer. A total of 56 organisations stated they were, as did eight individuals who also answered the question. Most (29) of these organisations were in the retail sector, 10 from the public sector, and 7 from manufacturing/packaging. Campaign respondents did not provide this information, but it is assumed that many would also be suppliers.

Analysis approach

The Lines Between was commissioned to provide a robust, independent analysis of the responses to the public consultation. The main purpose of consultation analysis is to understand the full range of views expressed and, where possible, using closed questions, to quantify how many respondents hold particular views. This report provides a thematic analysis of responses based on the analysis approach outlined below.

Reflecting the number and knowledge of respondents, it is impossible to detail every response in this report; some, especially organisations, shared lengthy submissions reflecting their specific subject matter expertise. These responses are referenced where possible. Full responses to the consultation, where permission for publication was granted, can be found on the Scottish Government’s consultation website.

Similarly, the technical nature of some of the proposals outlined in the consultation means it is impractical to fully repeat or explain these within this report. Further information on the proposals can be found in the consultation paper.

Quantitative analysis

The consultation included nine closed questions. Not all respondents answered every question. To compare across sub-groups, this report presents the results of the closed questions based on those who answered each question.

To allow comparisons across sub-groups, the tables in this report and Appendix A present the results of the closed questions based on those who answered each question. For clarity, each table shows:

• The percentage of respondents from the total sample of 1068 respondents who selected each response (grey row).
• The percentage of respondents among those who answered each question, broken down by individual and organisation responses and by type of organisation (rows including and under “All answering”).
• The sample size column notes how many respondents within each audience answered each question.

Please note that the row percentages may not add to 100% due to rounding.

Qualitative analysis

Qualitative analysis identifies the key themes across responses to each question. The research team developed a draft coding framework based on a review of the consultation questions and a sample of responses. During the coding process, new codes were created if additional themes emerged.

When reviewing the qualitative analysis in this report, we would ask the reader to consider:

• Public consultations invite everyone to express their views; individuals and organisations interested in the topic are more likely to respond than those without a direct or known interest. This self-selection means the views of respondents do not necessarily represent the views of the entire population.
• Qualitative questions were included in the consultation to allow respondents to elaborate on the views they recorded at the closed questions. However, not all respondents chose to comment, with those who commented providing varying levels of detail. The qualitative analysis is, therefore, based on the information provided by those who commented. In a few instances highlighted in the report, this has led to the prevalent themes in qualitative comments not aligning with the overall results of closed questions.
• Where differences between the views of individuals and organisations, or by type of organisation were evident in qualitative responses, these have been noted. If no specific differences are highlighted then a mix of respondents raised a theme, though the composition of the sample means the vast majority were typically individuals.
• Some respondents have possibly not fully read or engaged with the consultation paper, leading to answers which do not directly address the questions, or comments which suggest respondents have misinterpreted the question or misunderstood the nature of the proposed changes. While all comments have been included in the analysis and all themes presented in this report, we focus on those directly answering each question.
• Similarly, many respondents repeatedly raised the same issues or suggestions at multiple questions, regardless of the specific focus of the question. These views are all included in this report, but analysts exercised judgment about the most relevant place to include each theme to avoid repetition.
• In a small number of instances where a response received via email or in a PDF document contained information that did not align with specific questions, analysts exercised judgment about the most relevant place to include this material for analysis purposes.
• Quotes are included to illustrate key points and provide useful examples, insights and contextual information.

Weight of opinion

This report presents the themes identified in responses from most to least commonly mentioned at each question. All themes, including views shared by small numbers of respondents, are covered; a view expressed by a very small number of participants is not given less weight than more general comments shared by a majority.

Similarly, all responses have an equal weighting. We recognise this means a response from an individual has the same weight as the response from an organisation which may represent many members, but this approach ensures all views are presented.

Qualitative analysis of open-ended questions does not permit the quantification of results. However, to assist the reader in interpreting the findings, a framework is used to convey the most to least commonly identified themes in responses to each question:

• Many respondents, 50 or more respondents, a prevalent theme.
• Several respondents, between 30 and 49 respondents, a recurring theme.
• Some respondents, between 10 and 29 respondents, another theme.
• A few / a small number, fewer than 10 respondents, a less commonly mentioned theme.
• Two/one respondent; a singular comment or a view identified in only one or two responses.

This framework is used solely to present the prevalence of themes within consultation responses. Given the subjective nature of attributing importance and the self-selection of consultation respondents, this does not necessarily represent the importance of a theme.