Charging for single - use disposable beverage cups: consultation analysis

2. Charge level

This chapter presents the analysis of responses to Q1 to Q4, which sought views on the most appropriate minimum price for a single-use disposable cup, and on an alternative approach where Scottish Ministers could require suppliers to charge in regulations but leave it up to suppliers to choose the price they charge for a single-use cup.

Views on a minimum charging level

Q1: What would you consider a reasonable minimum price for a single-use disposable beverage cup, which is visible and separate to the price of the drink, to meet the aims of the scheme: to reduce the use of these items towards reusable alternatives?

In Q1, respondents were presented with a list of possible minimum prices and asked which they thought would be the most reasonable charge. As shown in Table 2, 47% of respondents selected one of the potential prices, while 43% selected ‘other amount’, 3% were unsure, and 8% did not answer. A follow-on question Q1A allowed respondents to elaborate on their ‘other amount’ answer; a small number who were unsure or did not answer also commented. Analysts further categorised each respondent according to their open comments at Q1A^[6]. Table 2 overleaf shows the distribution of preferred minimum prices before and after coding.

Table 2: Preferences for a minimum price for a single-use disposable beverage cup

Possible Minimum Price	Before Coding N=	%	After Coding N=	%
Zero / no charge / do not support	-	-	377	35%
Less than £0.10 but more than 0	-	-	48	4%
£0.10	-	-	52	5%
£0.20	92	9%	95	9%
£0.25	154	14%	157	15%
£0.30	92	9%	92	9%
£0.40	20	2%	20	2%
£0.50	141	13%	141	13%
More than £0.50	-	-	27	3%
Other amount (please specify)	457	43%	-	-
Other amount/suggestion/comment	-	-	18	2%
Don’t know	28	3%	25	2%
Not answered	84	8%	16	1%
Total	1068	100%	1068	100%

After coding, the most selected answer in Q1 was that the minimum price should be zero or that there should be no charge; 35% of respondents left comments to this effect.

Among the 59% of respondents who selected a specific price, the most selected options were £0.25 (15%) or £0.50 (13%). Among those who commented that the price should be less than £0.10, almost all suggested 5p, and a very small number suggested 1p or 2p. Of those suggesting a price greater than £0.50, over half suggested £1, with the remainder suggesting a range of other prices.

Table 3: Preferences for a reasonable minimum price for a single-use disposable beverage cup, after coding, by type of respondent

Audience	(n=)	% Zero / no charge	% £0.10 or less	% £0.20	% £0.25	% £0.30	% £0.40	% £0.50	% More than £0.50	% other amount / other comment / DK
All respondents	1068	35	9	9	15	9	2	13	3	6[7]
All answering	1052	36	10	9	15	9	2	13	3	4
Individuals	872	32	10	10	15	10	2	16	3	3
Organisations:	180	53	6	7	16	5	2	2	2	8
All retail	113	73	7	4	6	0	2	1	1	6
- Retail - Vending	73	100	0	0	0	0	0	0	0	0
- Retail - Convenience / Hospitality	33	27	24	12	15	0	6	3	3	9
- Retail - Trade Association	4	0	0	0	25	0	0	0	0	75
- Retail – Events / Festivals	3	0	0	33	33	0	0	0	0	33
Manufacturer / packaging	13	62	8	8	23	0	0	0	0	0
Environmental NGO	15	0	0	0	27	27	0	20	13	13
Public sector inc. local authority	15	0	0	27	53	13	0	0	7	0
Quality / consumer protection	4	50	0	0	0	0	0	0	0	50
Wholesaler	4	50	25	0	0	0	0	0	0	25
Waste management	2	0	0	50	50	0	0	0	0	0
Other	14	7	0	7	43	21	7	0	0	14

As 82% of consultation respondents were individuals, the preferred minimum price among individuals was very similar to the total sample, with 32% favouring no charge and the next most preferred being £0.50 (16%) and £0.25 (15%).

Among organisations, however, just over half (53%) preferred no charge and 16% £0.25, followed by 7% favouring £0.20. However, the preference for no charge among organisations was clearly driven by the vending retail sector, all of whom indicated there should be no charge. Beyond this, preferences varied by type of organisation, from 33% of environmental NGOs preferring a minimum price of at least £0.50, compared to 62% of manufacturer / packaging organisations and 27% of convenience / hospitality retailing preferring a charge of £0.20 or less, with 40% of the latter group preferring a charge of £0.20 or less.

Q2: Please provide reasons for your answer to question 1. We would be interested in knowing your views on what price per cup would encourage behaviour change.

Over nine in ten respondents commented in Q2. Because the comments provided followed on from respondents’ answers in Q1, for ease of reading, the analysis below is presented in three sections:

• Part 1 presents the themes evident among those who selected a specific price.
• Part 2 presents the themes raised by those who preferred no charge.
• Part 3 outlines several other themes which respondents took the opportunity to raise at Q2.

Part 1: Reasons for selecting specific prices

Three fifths of respondents selected a specific price per cup at Q1. The most common themes raised by these respondents were that their selected price is:

• Sufficient to encourage behaviour change.
• A fair and reasonable price that would not be prohibitive to consumers.
• Most likely to minimise impacts to businesses.

Other reasons were given for selecting each potential price, which are presented below in order of prevalence at Q1.

Will be effective in generating behaviour change

Many respondents felt the price they selected was the most likely to encourage behaviour change; this was the most prevalent theme among individuals and organisations who selected a price per cup and was also more likely to be mentioned by environmental NGOs and public bodies than other types of organisations. Most comments did not go into detail, simply stating that any charge needs to be high enough to be noticeable to consumers and make them think twice about their behaviour. Some respondents, particularly organisations, cited the research referenced in the consultation paper, which suggested that a charge of 20-25p would be sufficient to change the behaviour of 49% of the population.

There was a clear pattern in responses whereby this theme was more likely to be mentioned by those favouring a higher price, i.e. the higher the charge, the more likely it is to generate behaviour change. While one in ten of those who selected £0.20 at Q1 raised this theme, the likelihood of changing behaviour was mentioned by four in ten of those selecting £0.25, five in ten of those preferring £0.30, six in ten of the small number who favoured £0.40 and three quarters of the many respondents who selected a price of £0.50.

“If the objective of a charge on single-use cups is to encourage behaviour change, we believe that a charge needs to appear significant enough to make consumers think about the additional cost they are paying for a single-use cup in addition to their drink, and what they could save by choosing to bring their own reusable cup or borrowing a cup where schemes are operational.” – Keep Scotland Beautiful

“This charge is about encouraging behaviour change and so it is important that the amount set is enough that it makes customers think about the choice they are making - whether to use a reusable cup or to pay the additional cost… The charge needs to be at a level that persuades large numbers to make the shift to using a reusable cup and we are content to follow the research that 25p is likely to incentivise nearly 50% of those buying a beverage to use a reusable cup.” – National Trust for Scotland

A fair and reasonable level of charge

The second most prevalent theme among those who selected a price per cup was that their option chosen was the ‘right’ level. While this theme included many respondents from across the range of prices, it was more likely to be mentioned by those who selected £0.25 in Q1, followed by those who preferred £0.30. These respondents typically described the price they had chosen as fair, reasonable, proportionate and not prohibitive. For example, it was felt that their selected price would not put people off buying a drink but would still be affordable if a consumer needed to pay the charge occasionally. More specifically, several respondents felt that their selected price would be affordable and not create any socio-economic disadvantage.

“We believe that £0.25 is a reasonable price for the introduction of this scheme. A price point higher than this is likely to exclude, rather than incentivise, a significant portion of the population.” - Birmingham Plastics Network (University of Birmingham)

“We think the price should not be punitive, to encourage good take-up by consumers and to not disproportionately impact businesses which may lose custom if the levy is higher.” – Reloop Platform

Around half of respondents in this theme coupled this view with the need to encourage behaviour change, stating, for example, that their chosen price was significant enough to make people consider or change their behaviour but not so high that it negatively impacts consumers. A few noted thought their chosen price would be acceptable to the public.

Minimises impact on business

Many respondents explained that their response to Q1 was based on their desire to minimise any negative impact on businesses selling drinks. While a range of respondents mentioned this, it was more likely to be mentioned by those who commented at Q1 that they would prefer a charge of £0.10 or less. Most individuals in this theme stated that if a charge is introduced, they would not, or could not, buy a drink in the future. It was suggested that this would reduce sales and potentially lead to job losses and business closures. Respondents, therefore, called for consideration to be given to balancing the proposal's aim with the need to protect businesses.

“10p would be a noticeable difference to most people but would not be unreasonable. From working in a small independent cafe, I feel any more would put people off and we would lose valuable sales.” - Individual

“Effectively all that happens is you increase the price of whatever product you drink that then becomes practically out of someone’s reach and can’t afford it, then putting pressure on the seller to stay in business” - Individual

Other reasons for selecting £0.25

£0.25 was the most frequently selected price, with many commenting this would be sufficient to create behaviour change and was the right level to charge. Other reasons for this price were noted by several respondents. These included that a similar small charge had generated behaviour change in relation to single-use carrier bags, agreement with this price as it was recommended in the consultation paper based on existing research and that it could represent roughly 10% of the average cost of a hot drink. A few noted that £0.25 is similar to the discount currently offered by some retailers for bringing a reusable cup.

“Partly based on advice given in the document, and partly because drinks are often more than 10 times this cost. It's a small percentage.” - Individual

Other reasons for selecting £0.50

£0.50 was the second most selected price point, just behind £0.25. As noted above, by far the most prevalent theme among this group was that the price per cup needs to be sufficient to encourage behaviour change, and over three quarters of those selecting £0.50 believed this would be the case if charging that price. Only some of those selecting £0.50 commented that this is a fair and reasonable price.

“The additional cost would have to be significant in order to make people think to bring their own cup. 50p each time is a lot, but it would be more likely to stop some customers who buy daily or multiple daily cups.” - Individual

Some respondents provided other reasons why they selected £0.50. These included the importance of curbing wasteful or environmentally damaging behaviour and minimising the use of single-use products, and comments describing takeaway coffee as a luxury item, meaning the consumer should also be able to afford a higher charge.

“People are willing to pay approximately £0.50 for dairy-free milks so why not for a paper cup.” – Individual

“A higher charge can serve to highlight the environmental impact of single-use cups more effectively. By imposing a £0.50 fee, the policy reinforces the idea that these cups are not just a minor inconvenience, but a significant environmental concern that justifies a substantial charge.” - Individual

Other reasons for selecting £0.20

Some respondents who selected £0.20 commented on the recurring theme that this appears to be the right level to charge. Several others provided a range of reasons for charging £0.20. Some commented that if the charge is introduced, it should be at the lowest level possible. A few suggested that even this low level could drive behaviour change, noting that a smaller initial charge applied to single-use carrier bags had generated change. Other reasons noted by a small number included that £0.20 is a round number and would require fewer coins or less change and that a lower amount would be easier for businesses to introduce and for consumers to understand.

Other reasons for selecting £0.30

Several respondents who preferred £0.30 felt this would encourage behaviour change, while some suggested this is the right level to charge. Some gave other reasons for selecting £0.30, many of which were similar to other respondents’ reasons for selecting £0.25. This included that £0.30 would typically represent 10% of the price of a hot drink, and that it is similar to the discount currently offered by some retailers for bringing a reusable cup. In addition, some noted that the research cited in the consultation paper, which recommended a £0.25 charge, was conducted in 2019, and that inflation meant this would now be approximately £0.30.

Other reasons for selecting £0.40

Only a few respondents preferred £0.40, with most commenting that this is sufficient to encourage behaviour change or citing other reasons similar to those outlined above.

“We have run with a 25p additional cost for 18 months with no discernible reduction in use. This suggests that a higher cost may be needed.” - University of the West of Scotland

Other suggestions for how to introduce any charge

Several respondents provided suggestions for how a charge could be introduced. Two themes were evident within this. Respondents commented on consumers’ familiarity with charging for single-use carrier bags and suggested that a charge for single-use cups should follow the same approach of using a small charge. A few noted that an initial low charge could be more acceptable to consumers and, therefore, encourage change.

The other theme was a request that the charge be regularly reviewed and, if necessary, increased over time if it does not have the desired impact or reassessed if any unintended consequences are identified. A few respondents suggested that, depending on the final approach used, a maximum charge as well as a minimum charge should be in place.

“Should the lower value of £0.20 not be deemed to have as much of a behaviour change as hoped then there is always the option to increase the cost at a later date, just like has happened with the carrier bag charge.” – Aberdeenshire Council

Part 2: Reasons why no charge should be introduced

After coding, just over one third of respondents in Q1 indicated that they did not support charging for single-use cups and that the minimum price per cup should be zero. These respondents, who were primarily but not solely individuals, raised multiple broad themes highlighting why they felt there should be no charge. These included:

• Concerns about the cost implications of a charge to consumers and businesses.
• General opposition to a charge.
• Dissatisfaction with the Scottish Government’s approach.

In the analysis below, similar themes have been grouped together, but the groups and themes within each group are presented from most to least prevalent. It should be noted that many of the respondents who raised these issues repeated their opposition to a charge or raised many of the same concerns in other questions. To avoid repetition, these issues have been described in detail below and referenced elsewhere in this report.

Specific concerns raised in the vending retail campaign responses as reasons why no charge should be introduced are also noted in this section and in Part 3.

Concerns about the cost implications of the proposals

Four themes highlighted specific concerns about the cost implications of the proposals. The most common theme among many respondents who advocated for no charge was that 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 the consumer. More specifically, many of these respondents noted that increased costs would be a particular challenge to individuals due to the ongoing cost-of-living crisis.

“During a cost-of-living crisis and when money is tighter than ever for every family in Scotland, putting a charge on cups is ridiculous.” – Individual

“In this economic climate it is not right to increase the cost of a product that many poorer consumers rely on. This is a levy that will affect the worse off only. Furthermore, a levy will distort market prices and leaves consumer welfare worse off in the long run.” – Consumer Choice Center

Related to this, some respondents suggested that the charge was likely to disproportionately impact more disadvantaged groups. While this point was raised frequently, it is the focus of Q15 and Q16, so it is explored in more detail in the analysis of responses to those questions.

“I am concerned about people with lower incomes being disproportionately punished for small indulgences.” – Individual

Several expressed the view that the proposed charge is a way for either the Scottish Government or businesses to make money, often describing it as a ‘tax’ or a ‘stealth tax’.

“Visitors to our country are unlikely to have reusable cups with them and will therefore have to pay a charge each time they purchase a beverage. This amounts to a further tax on tourists as Scotland’s local authorities prepare to introduce visitor levies.” – UKHospitality Scotland

“This is another tax on the consumer which is unfair on people who simply want a coffee. Dictate what disposable cups should be made of, rather than add a stealth tax.” – Individual

“In the events industry, this would be seen as a tax on customers as there would be no alternative available for customers to bring their own reusable cups at concerts and festivals.” - Skye Live LTD / The Reeling LTD

The potential negative impact on businesses, especially small businesses, was noted by some respondents. More detail about these concerns is provided in the analysis of responses to Q8, Q11 and Q18 in particular. However, the main concerns included that an increase in cost could reduce the number of customers and sales, and that additional costs could be incurred because of introducing the charge.

“I would further add that this change would disproportionately impact upon small business in Scotland. Larger enterprises have a management structure that monitor legal policies, plan for them and then implement them across their business locations. Small business owners don't have this option and are already working excessive hours. Considering and implementing this change must be done on top of all the other commitments and will only further complicate the running of the business.” - Small Independent Hospitality Business

Organisations were more likely to raise business impacts, especially those in the vending retail and manufacturing / packaging sectors. As well as noting additional burdens, a few respondents in these sectors, such as the Foodservice Packaging Association and The Packaging Federation, used the same wording to note that “The charge will have an adverse impact on sales of beverages from foodservice retailers who are already struggling with increasing costs of heating, labour, business rates, rent and ingredients”. More specifically, a few others cited the independent Ecuity Consulting economic impact assessment which suggested that a 25p levy applied across the whole of the UK could lead to £646 million in lost sales, over 11,000 job losses, and £173 million in broader economic costs, and an Irish Economic Analysis by Jim Power Economics which estimated that a 20-cent levy could cause an 8.23% decline in coffee sales, risking approximately 4,244 jobs – which these respondents felt would be comparable to potential impacts in Scotland.

Opposition to a charge

Opposition to introducing a charge was expressed in three slightly different themes. Most commonly, several respondents in Q2 and subsequent questions made brief statements that they do not support the introduction of a charge, that there should be no charge, or that the proposals should not go ahead. At later questions, particularly Q8 and Q9, some of these respondents reiterated their opposition to highlight this meant they were unable to answer the questions being asked. In Q2, some retail organisations including a few manufacturer / packaging organisations and all the vending retail campaign responses explicitly opposed the charge, with the latter group doing so repeatedly throughout their responses.

“I disagree with this scheme and it's heavy-handed approach.” – Individual

“The AVA supports the aims and objectives of the Scottish Government in seeking to develop a fully circular economy… However, we strongly feel that the introduction of levies and taxes on single-use packaging are not fair, proportionate or reasonable. They will create an additional layer of burdens for business and will be counterproductive resulting in a range of unintended consequences.” - AVA: The Vending & Automated Retail Association

Some respondents expressed the view that the proposals would not work or felt that evidence was needed to show that they would achieve their aim.

“I don’t think it would change behaviour at all. To put a cost on paper cups is unacceptable.” – Individual

“Regardless it will not act as a deterrent, unlike plastic bags the public simply will not take their own cups to outlets for a refill.” – Glasgow Marriott Hotel

“We believe this charge will instead change consumer behaviour on the decision of whether to consume a drink or not, rather than on using a reusable alternative. Based on the price of the drink, either the charge is high enough to disincentivise buying a drink at all (e.g., a family on a fixed or low income may not be able to afford four soft drinks rising in cost from £4 to £5), or is low enough that the consumer will simply consider it an annoyance (e.g., an alcoholic drink increasing from £7 to £7.25 is not enough to incentivise behaviour change).” – Scottish Retail Consortium

Dissatisfaction with the Scottish Government

Four less commonly mentioned themes highlighted general dissatisfaction with the Scottish Government or their approach to introducing the charge. The most common was a theme highlighting dissatisfaction or criticism of the Scottish Government, with many respondents perceiving incompetence or lack of progress on other issues or policy areas. Similarly, some others expressed the view that the proposals were a waste of time or taxpayers' money and felt that the Scottish Government should focus on other issues or priorities such as health, education and reducing homelessness.

Some called on the Scottish Government to stop interfering in people’s day-to-day lives, or to reduce interference and the ‘nanny state’. More specifically, a small number expressed opposition to net zero or environmental policies. A few respondents, mostly individuals, expressed a view that the consultation assumed a charge would go ahead and focused on its implementation rather than exploring whether a charge should be used.

Part 3: Other themes raised at Q2

Several other themes not directly related to a specific charge level were evident in responses to Q2. Most were raised by a combination of those who supported a charge and those who did not, and by a mix of organisations and individuals. These themes, from most to least prevalent, included that:

• Encouraging reusable cups is not practical for consumers or for hygiene reasons.
• There is a need to consider alternatives to the proposal.
• The proposals should not apply to recyclable or biodegradable cups.
• There could be a positive impact from the proposals.
• The proposals could potentially have negative impacts on other policies and approaches.

Encouraging reusable cups is not practical for consumers for hygiene reasons

Many respondents, primarily individuals, stated that they or others would not want to, might not be able to, or might not remember to, always carry a reusable cup with them and therefore disagreed with having to pay an additional cost when buying a drink. Several noted the challenge of carrying around a solid or ‘bulky’ item, with challenges for specific groups noted by a few respondents e.g. disabled people, older people or motorcyclists. Some others explained that the proposals should not be considered in the same way as the charge for single-use carrier bags; where shopping is typically a planned activity and people know they will need a bag, but buying a drink can often be a more spontaneous decision meaning people would not always have a reusable cup to hand. Practicalities related to vending machines are addressed in the next chapter as part of the analysis of responses to Q8.

“Although we actively encourage the use of reusable containers over unnecessary single-use packaging, current evidence suggests that the majority of the population – especially when considering an ‘impulse’ buy such as coffee – would not have a reusable container available as the consultation suggests. The additional cost provided by the charge may then reduce sales rather than encouraging a shift in consumer practices.” – Ecosurety

Hygiene considerations were also raised by some individuals and organisations. There were two strands to these comments. Respondents highlighted their concerns about the cleanliness of reusable cups, for example, questioning whether and where they would be able to clean their cups after use and whether retailers would be willing to handle or clean dirty cups before they are used again. More specifically, a few respondents raised concerns in the light of COVID-19 about paying a charge for a single-use cup, which they were choosing to use to minimise the spread of viruses.

“What should a person serving takeout drinks do if they are presented with a dirty reusable cup by a customer? How can anyone be certain that they are filling a clean cup? Surely this has major implications for food hygiene and the transmission of infection via milk and coffee machines?” – Individual

“There are also health and hygiene considerations associated with the use of reusable cups. Expert findings from Professor David McDowell of Ulster University report higher risks of cross-contamination and foodborne illnesses with reusable systems compared to single-use… Consumers should have the option to use hygienic single-use cups without incurring extra costs, especially when adequate facilities for cleaning reusables are unavailable. There are also contamination issues for workers when handling what are technically contaminated vessels.” – UKHospitality Scotland

Need to consider alternative approaches

Calls for alternative approaches, or considerations to ensure the effectiveness of a charge in encouraging behaviour change, were made by many respondents. Multiple themes were evident in these comments.

Most frequently, several respondents commented on the need to encourage change through incentivising rather than penalising consumers and businesses. While most of these comments called for a ‘carrot rather than stick’ approach, others noted that some retailers already have initiatives in place to encourage the use of reusable cups and suggested more emphasis on making such practices more widely available.

“We do also have an incentive for customers who bring their own cups which has been successful. Making that more attractive might be more likely to change the behaviour of regular users.” – Individual

Some respondents felt that if the charge intends to encourage people to use reusable cups, these need to become more widely available and more affordable, with more cleaning facilities available. A few called for approaches whereby retailers supply a reusable cup for a charge, then refund the consumer when the cup is returned.

“Schemes like the highland cup movement on the NC500 where you got a returnable takeaway cup would be better.” – Individual

Calls for the responsibility to be placed on the suppliers of single-use cups, rather than on consumers, were made by some, while a few called for larger commercial organisations to have this responsibility. Suggestions included ensuring suppliers use recyclable single-use cups, have recycling facilities, or move towards more sustainable approaches.

“The onus should be on the seller of the items to find an alternative to single-use items, or an industry tax on single-use plastics. Stop charging the customer for the negative effects of big businesses pushing convenience!” – Individual

Similarly, some other respondents made more general calls for greater innovation and promotion of alternative recyclable or biodegradable cups. These respondents suggested that the Scottish Government should focus on this rather than introducing a charge, with a very small number suggesting that a charge could stifle further innovation.

“Surely compostable is better and should continue to be encouraged - a broad-brush application of the 25p charge will mean that the compostable container market falters as these are currently presumably slightly more expensive for the retailer to buy but are a more sustainable option and should be encouraged - you want to encourage an industry to strive to improve its environmental credentials and a blanket 25p charge will not do that.” - Individual

The proposal should not apply to recyclable or biodegradable cups

Several respondents, primarily individuals who favoured a very low charge or no charge at all, questioned why a charge is being proposed when, to their knowledge, many single-use cups are either recyclable, biodegradable or compostable. These respondents felt it unfair to charge because a cup was single-use, without considering the materials the cup is made of. A few organisations, such as Seda UK Ltd and Benders Paper Cups, provided details on how widely recyclable or compostable cups were used in the UK.

“Many coffee shops already provide recycling facilities for their cups so why should I have to pay for this?” - Individual

“We oppose introducing charges on single-use disposable cups. Paper coffee cups if collected separately are not a waste material, rather they are a valuable circular resource with a potential source of high-quality fibre.” – Confederation of Paper Industries

Similarly, a few respondents who supported a charge called for different charges to apply to different types of single-use cups, with lower charges applied to more environmentally friendly options. Scottish Grocers' Federation and Scottish Retail Consortium also noted that a standard minimum price would represent a different proportion of the total cost of a purchase depending on the drink.

“There should be a 2 tier system for pricing. Plastic cups, including vending machines (no exceptions), should be charged at a higher rate to encourage re-useable or biodegradable variants. A biodegradable plastic cup is still a significant improvement on plastic. Single-use biodegradable cups should have the lower charge. The lower charge should be 20p, with the higher charge being double.” – Individual

“It is worth noting that the charge represents a very different value depending on the cost of the item purchased. If a retailer is selling a small filter coffee for £1, they will now have to charge £1.25 with the proposed cup charge added, representing a 25% increase in price. A larger, more premium drink may increase from £5 to £5.25 with the cup charge added, representing only a 5% increase in price.” – Scottish Grocers’ Federation

Positive comments about the proposals and its potential impact

Several respondents left positive comments about the proposal. Most commonly, respondents explained their support for the charge by highlighting their dislike of single-use products, with a few calling for them to be banned completely. Others suggested that the proposal is a good approach and called for it to be extended to other single-use products such as single-use cutlery and food containers.

Beyond this, some felt that if the charge encourages behaviour change and reduces waste then it will benefit the environment, and a few made very general supportive comments. A few, such as Keep Scotland Beautiful, welcomed the inclusion of biodegradable and compostable cups, which they felt were still challenging to dispose of sustainably.

“Scottish Environment LINK members welcome the proposed introduction of a charge in the absence of an outright ban. Single-use cups are often unrecyclable and regularly result in increased litter, while the use of plastics has a wider environmental impact through contribution to climate change.” – Scottish Environment LINK

“We support the prioritisation of tackling the global climate emergency and believe that a charge on single-use disposable beverage cups has the potential to contribute to reducing environmental harm and challenging the ‘throw-away culture’.” – Evangelical Alliance Scotland

Potential negative impacts on other policies and approaches

Some organisations, including the vending retail campaign response, expressed the view that a charge for single-use cups would be counterproductive to other approaches and policies, such as the four-nation policy mandating paper cup takeback in the Extended Producer Responsibility (EPR) for Packaging, the Deposit Return Scheme (DRS), and the Internal Market Act. However, since this consultation closed, it was decided on a four-country basis that the mandatory retailer takeback of paper cups as part of the EPR is no longer going ahead.

Other themes raised about introducing a charge

Several respondents raised concerns about transparency, questioning how the charge and use of net proceeds would be monitored to ensure it is applied fairly. While this is explored more in the analysis of responses to Q9 (use of net proceeds) and Chapter 5 (enforcement), respondents used Q1 to raise concerns, in particular, the need to ensure that businesses do not use a charge to exploit customers, or that businesses or the Scottish Government do not waste money raised. Some respondents specifically cited the increase in the charge for single-use carrier bags over time, expressing the view that retailers now see this as a money-making opportunity.

“You reference the 10p plastic bag scheme - however, bags aren't 10p anymore, are they? You can be charged almost £1 for a bag that falls apart after ten uses. And if the whole bag scheme was to combat plastic use, then why are we charged for paper bags too?” - Individual

Some called for other actions to make recycling easier or reduce littering, including providing more bins and improving recycling facilities. A few felt that educating the public about these issues would be more beneficial than introducing a charge.

Views on whether suppliers could choose the price they charge

Q3: Alternatively, Scottish Ministers could require suppliers to charge in regulations but leave it up to suppliers to choose the price they charge for a single-use beverage cup. This approach would be supported by guidance provided by the Scottish Government. This is similar to the approach that taken in the Netherlands. Do you prefer this approach?

Audience	Sample size (n=)	% Yes	% No	% Don’t know	% No answer
All respondents	1068	13	74	12	2
All answering	1050	13	75	12	-
Individuals	870	14	73	13	-
Organisations:	180	10	84	6	-
All retail	113	10	86	4	-
- Retail - Vending	73	0	100	0	-
- Retail - Convenience / Hospitality	33	33	58	9	-
Retail - Trade Association	4	0	75	25	-
- Retail – Events / Festivals	3	0	67	33	-
Manufacturer / packaging	13	15	77	8	-
Environmental NGO	15	0	93	7	-
Public sector inc. local authority	15	13	87	0	-
Quality / consumer protection	4	0	75	25	-
Wholesaler	4	0	75	25	-
Waste management	2	50	50	0	-
Other	14	0	0	0	-

Three quarters (75%) of those answering Q3 disagreed with the approach of leaving it up to suppliers – i.e. the business levying the charge - to choose the price they charge for a single-use beverage cup. One in seven (13%) preferred this approach, and the remaining 12% were unsure. Opposition was recorded among both individuals (73%) and organisations (84%). Similarly, at least three quarters of most types or organisations disagreed with this approach, except for convenience / hospitality retail where 58% disagreed and 33% preferred leaving it up to suppliers to choose the price they charge.

Q4: Please provide reasons for your answer to question 3.

Just under nine in 10 respondents answered Q4. In line with the views recorded in the closed question, the most common themes outlined reasons in support of a standard minimum price. The most prevalent themes were:

• That a standard minimum price is simpler, clearer and fairer.
• Potential negative consequences of allowing businesses to choose the price they charge, such as competition between businesses undermining the policy intention.
• Concern that businesses could overcharge.
• Positives of allowing businesses to choose the rate they charge, such as greater business autonomy and consumer choice.

A standard minimum price is simple, clear and fair

Many respondents, most of whom answered no to Q3, stated that a standard minimum price would be simpler, less complicated and less confusing than allowing businesses to choose the price they charge. In line with their higher levels of disagreement at the closed question, environmental NGOs and public sector bodies were more likely to raise this theme as a reason than other types of organisation. It was suggested a standard minimum price could make it easier to explain the charge to consumers, as they would know what they should be charged consistently across all businesses. In turn, it was felt that this clarity and transparency would enable consumers, particularly those on low incomes, to make an informed decision about their purchases.

It was also suggested that a standard minimum price may help to support behaviour change away from single-use cups. One concern was that some businesses may choose to absorb the charge instead of passing it on to customers, which could be the incentive for consumers to switch to reusable cups. It was also suggested that a standard minimum price could be easier for businesses to manage, more likely to reduce competition between businesses and minimise tensions between businesses and consumers.

“I feel a uniform cost, like the plastic bags system, is easier for consumers to navigate and see the effect of not using a reusable alternative.” – Individual

“A standard charge seems fairer and more transparent to the consumer. Voluntary elements as proposed in Q3 are likelier to be got round/not effectively implemented. Consumers should see a transparent, universal cost as this is likelier to drive behaviour change.” - Plastic-Free Dalgety Bay

Many respondents raised comments about a standard minimum price being fairer, all of whom answered no to Q3. In particular, it was noted that a standard minimum price could be fairer for businesses by reducing potential competition between businesses to minimise the charge, avoid market distortion, and reduce the risk of larger businesses outcompeting smaller businesses. A standard minimum price was also noted as being fairer for consumers, which in turn could support behaviour change.

“To ensure fairness, transparency, and market consistency, the SWA recommends that any charge for single-use cups should be standardised and clearly communicated to consumers. This approach would prevent price variations that could disproportionately impact different businesses, particularly smaller operators, and would promote a level playing field across the sector.” - Scottish Wholesale Association

Several respondents, all of whom answered no to Q3, also made general comments supporting a standardised price. These comments referred to the single-use carrier bag charge and urged the establishment of a similar standardised charge.

Charge could create competition which undermines businesses and the policy

Many respondents, most of whom responded no to Q3, commented that businesses levying the charge could undermine each other if they can choose the price they charge. It was also suggested that if businesses choose the price they charge, there would be competition between businesses to keep the charge as low as possible and not lose trade. Potential disadvantages to smaller businesses due to businesses choosing their own price were highlighted by many, in particular, that it could be easier for bigger businesses to absorb some or all of the charge and reduce the cost to consumers, but for smaller businesses to do so could mean reducing their margins to an unsustainable level.

“This approach may be unfair to some businesses that want to take this change seriously and charge a fair amount for the single-use cups, who may lose business over the competition who may be charging the minimum to gain market shares.” – Individual

“One of the objectives of the charge is to ensure retailers who “do the right thing” are not disadvantaged versus those who don’t. If the charge itself varies from retailer to retailer, this would not achieve this objective and would also confuse customers who may then incorrectly blame the retailers for the charge.” - The City of Edinburgh Council

Many respondents, mostly individuals who responded no to Q3, suggested that allowing businesses to choose the price they charge could undermine the policy approach and implementing a charge more generally. For some of the same reasons detailed above, respondents noted that businesses may charge nothing or the minimum amount possible, which may not lead to the behaviour change intended from this policy.

“This has two potential effects:

1. The charge fails to meet its objectives in reducing single cup usage as the cost is set so low so as not to have any significant impact on the volumes being used

2. If a supplier sets the rate higher than local competitors then they run the risk of losing business and potentially going out of business with the economic impact this has. Loss of jobs, loss of income to local economy, allows suppliers to increase price as they are no longer facing competition.” - Individual

Businesses could choose to overcharge

Concerns that businesses could choose to overcharge their customers, take advantage of the charge or make a profit were raised by many respondents, most of whom were individuals who responded no to Q3. This included concerns that businesses could focus on profit over the environment, reducing the impact of the charge and negatively impacting consumers. A few respondents left brief comments expressing distrust in businesses being able to set their own prices, with suggestions they may choose to focus on higher prices to increase their profit over any benefits to consumers or the environment.

Positives of businesses choosing the price they charge

Many respondents, mostly individuals, supported the alternative approach of allowing businesses to choose the price they charge. These respondents felt businesses are best placed to determine a charge and that this approach gives businesses greater flexibility, autonomy and control. Respondents also expressed the view that businesses know their customer base and how much extra they could charge them.

“It means suppliers are able to regulate what they are charging for products and can retain some control over the end cost to the consumer” - Knockenhair Hospitality

A further positive of this alternative approach noted by some respondents was that it could allow for flexibility in the types of cups consumers are charged for. Specifically, it could mean businesses are able to charge less for biodegradable, recyclable or other more sustainable cups than for other types of single-use cups. A small number felt this approach could empower businesses to take more responsibility for moving towards reusable cups or more environmentally friendly single-use cups.

A few respondents felt that allowing businesses to choose the price they charge could give consumers more choice, enabling them to select which business to use based on how much they charge for cups. A few others suggested that greater competition between businesses could keep costs down for consumers.

Challenges enforcing an alternative approach

Several respondents suggested that it could be challenging to enforce, regulate, and monitor an approach where businesses choose the price they charge. There were concerns that additional flexibility could mean businesses may not properly implement the charge, find loopholes, or be non-compliant, with respondents highlighting the need for businesses to be accountable.

Other comments at Q4

Should businesses have the option to choose the price they charge, several respondents advocated for there still to be a minimum price, with businesses free to charge a higher price. This approach was felt to provide a balance between offering more flexibility and providing a degree of consistency for businesses and consumers and supporting behaviour change. A few respondents also suggested setting a maximum charge.

Some respondents noted that businesses can currently charge for single-use cups to incentivize consumers to use their own reusable cups. While most did not expand on this point, a few cited it as a reason not to proceed with the proposal.

Comments were raised by some respondents that the charge should be placed on businesses rather than consumers. A few respondents made comments indicating misunderstanding of the term ‘supplier’ referring to the supplier of cups, rather than businesses that sell to consumers and will be levying the charge.

“It needs to be a responsibility of the suppliers to provide a disposal ecosystem that actually solves the problem, not simply passes the problem on to others.” - Individual