Charging for single - use disposable beverage cups: consultation analysis

6. Implementation

This chapter presents the analysis of responses to Q12 to Q14. These questions asked respondents to provide insight into the challenges and timetable needed to implement a charge on single-use disposable cups and explored what assistance the Scottish Government could provide to help implement a charge. Please note that these questions were directed at suppliers of single-use disposable cups, i.e. those who would be levying the charge. While this means that fewer than one in ten respondents answered each question, some of those who responded did not identify as suppliers at the classification question but answered regardless.

Q12: (Please only answer this question if you are a supplier of single-use disposable cups) What are the challenges you face to introducing the charge?

Q12 was answered by one in seven respondents. The most prevalent themes were:

• The potential impact on trade.
• The cost of implementation.
• Administrative concerns.

Negative impacts on trade and customers

Some respondents, mostly organisations, highlighted the possible impacts of a charge on trade as a challenge, particularly the increased cost to customers. Respondents highlighted the potential for reduced sales due to increased costs, or that they may need to absorb the charge to keep prices affordable for customers and avoid reduced sales.

“Sales and profit impact: The introduction of a single-use cup charge could significantly impact the overall customer experience, potentially deterring customers from making impulse purchases of single-use drinks and complementary items, such as snacks or additional food. This shift in behaviour may lead to a noticeable decline in sales and average spend per visit, ultimately reducing profit margins.” - Scottish Wholesale Association

A few respondents suggested that customers could be angry, disappointed, or abusive when learning of the charge, which would be challenging for staff to handle and possibly negatively impact trade. A few respondents also expressed concern that independent shops would not be able to compete with high-street chains or their prices.

A few also noted that because reusable cups vary in size, it could be challenging to know whether the correct price is being charged for the volume of drink being sold, which could, in turn, lead to undercharging and lost revenue.

Implementation costs

An equal proportion of respondents mentioned the costs of implementing a charge. A few spoke generally of costs a business could incur during the transition, such as adapting their premises and equipment to accommodate more dishwashing for reusable cups, time and training needed to update point-of-sale systems, and reprinting signage and menus. A few others noted that the introduction of DRS and EPR is already costing businesses, and the introduction of a single-use cup charge would be a further additional cost.

The vending retail campaign response raised concerns about vending machines, specifically those where cups are distributed automatically. This was elaborated on by AVA: The Vending & Automated Retail Association in their response.

“We disagree with the implementation of a cup charge, in part because of the practical implications. Almost two thirds of beverage equipment is Free Vend to the consumer/employee, so there is no mechanism within the equipment to charge at point of dispense. (AVA Census & Market Report 2023: Large, free standing is 35% free vend, Tabletop 80% free vend). To apply payment units to existing ‘free vend’ equipment would cost the industry, comprised primarily of independently owned SMEs, approximately £60million” – AVA: The Vending & Automated Retail Association

Administrative concerns

The potential administrative burden associated with reporting requirements, data collection and compliance was mentioned by a few.

“This move should require the charge to be levied but not impose unnecessary reporting requirements. We need to implement these changes in a way that people support, not oppose.” – Fyne Ales Ltd.

A few other organisations raised questions about the unique administrative difficulties of charging a fee for the cup when there is no fee for the beverage, such as at school events or hospitals. While the consultation paper notes that no charge would be placed on beverages that were not sold, a few respondents noted possible grey areas, such as parent-led school events with voluntary donations rather than charges.

Less mentioned challenges

A few respondents mentioned other unique challenges or had questions about challenges. These included:

• Concerns about hygiene and food safety.
• Issues with specialised locations and sites, such as festivals where the infrastructure for reusable containers is not organised or a license prohibits bringing in open containers.
• That reusable cups will not be returned, leading to a financial loss to the supplier.
• Competitors not complying with the regulations.
• Queries over how it will impact Epos systems, nature of recording systems, whether an unfair advantage would occur in relation to other UK businesses or create confusion for visitors to the UK.

Suggestions to overcome challenges

A few respondents provided suggestions to overcome potential barriers to implementation. These included producing or providing:

• Public awareness or information campaigns.
• Legislation to identify the point in the supply chain where the charge is applied.
• A clear and concise guide for exemptions.
• Explicit explanation of enforcement procedures to ensure a level playing field.
• A list of approved manufacturers, if the charge were to sit with the manufacturer.

Q13: (Please only answer this question if you are a supplier of single-use disposable cups) How much time do you think it would take for your business to prepare to implement the charge? Please provide reasons for your answer.

Audience	Sample size (n=)	% Within a couple of weeks	% One month	% Two to three months	% Upwards of six months	% No answer
All respondents	1068	0	1	1	4	94
All answering	67	3	15	19	63	-
Individuals	21	5	24	14	57	-
Organisations:	46	2	11	22	65	-
All retail	27	4	19	22	56	-
- Retail - Vending	0	-	-	-	-	-
- Retail - Convenience / Hospitality	23	4	22	26	48	-
- Retail - Trade Association	2	0	0	0	100	-
- Retail - Events / Festivals	2	0	0	0	100	-
Manufacturer / packaging	3	0	0	0	100	-
Environmental NGO	1	0	0	100	0	-
Public sector inc. local authority	8	0	0	38	63	-
Quality / consumer protection	1	0	0	0	100	-
Wholesaler	4	0	0	0	100	-
Waste management	0	-	-	-	-	-
Other	2	0	0	0	100	-

Q13 was directed at suppliers of single-use disposable cups and was only answered by 67 respondents; given their opposition to a charge, Q13 was not answered by the vending retail campaign respondents. Among those who answered, 63% indicated it would take their organisation upwards of six months to prepare to implement the charge. Convenience / hospitality retailers recorded a wider range of timescales, ranging from 4% who could be ready in a couple of weeks to 48% requiring at least six months. Most other organisations who answered indicated that they would need at least six months to prepare. Q13 was answered by 58 respondents. A few of those answering reiterated their closed question response by stating a time frame rather than providing reasons for their answer. Those ranged from very small amounts of time to over two years. The most prevalent themes raised by those answering were the need for time to:

• Establish the necessary systems and procedures.
• Raise public awareness of the charge.
• Clearly communicate with businesses about the charge to minimise confusion.

Time to establish the necessary systems and procedures

The most common theme, mentioned by some and mostly by organisations, was that time was needed to establish systems and procedures to facilitate the introduction of a charge. This included changes to the point-of-sale system, updating menus and signage, and procuring reusable cups. Others noted that they would also need to put data recording and collecting systems in place depending on the final requirements.

“ASSIST FM feel that this will take over six months to have the administration process in place, to allow for staff training, updating of systems and the purchase of reusable cups. This will also give the Scottish Government time to promote the charge in the public domain.” - ASSIST FM - Local Authority Networking Group

Time to raise public awareness of the charge

Some suggested that time was needed to ensure communication from the Scottish Government about the new charge had reached the public to limit confusion or aggressive behaviour around the time of implementation.

“To ensure appropriate communications have been made with stakeholders, two to three months would support.” - National Services Scotland

Other themes at Q13

Confusion during the implementation process was highlighted as a concern by a few respondents. They noted that this could be offset by clear communication with businesses about regulations, which is discussed in greater detail at Q14.

Upskilling staff on new systems and procedures was mentioned by a few.

A few respondents highlighted concerns about barriers that may make the implementation more difficult. These included, from most to least prevalent:

• Requests for more details about the charge to provide a greater understanding of the time and funding needed to implement any procedures.
• A lack of time or funds to implement the changes.
• Other legislation retailers are currently adapting to, such as HFSS (high fat, sugar or salt) restrictions, upcoming vaping regulations, adjustments due to Minimum Unit Pricing (MUP) and Extended Producer Responsibility (EPR).

Q14: (Please only answer this question if you are a supplier of single-use disposable cups) What could the Scottish Government do to assist in helping your business implement the charge?

Q14 was answered by 72 respondents. The most prevalent suggestions for Scottish Government assistance were for:

• Raising public awareness.
• Clear regulations and guidance.
• Financial assistance.

Communication to raise public awareness

The most common request, mentioned by some and almost entirely by organisations, particularly public sector bodies, was for a public information campaign to help consumers understand the charge. Respondents emphasised the public should be informed of the level of the charge, when it will be implemented, and how and where money raised will be distributed. Suggestions recommended advertising on television, radio and social media.

“An extensive consumer communications campaign to ensure the public understand the charge, so businesses do not have to justify the charge as part of their own strategy and are protected against customer backlash." - UKHospitality Scotland

“It’s important to clarify, as part of the above education and advertising piece, the criteria for reusable cups, ensuring that only cups designed for repeated use, with sufficient durability and hygiene standards, are accepted.” - Scottish Wholesale Association

Providing clear regulations and guidance

Some respondents highlighted the importance of clear communication with the vendors and suppliers of single-use cups, providing them with clear regulations and guidance to simplify the implementation of the new charge. Consumer Scotland for instance, called for clarity on whether the charge would remain the same or increase in line with inflation and felt this should be clearly communicated to avoid confusion among consumers and allow businesses time to prepare for implementation.

“Clear plain English guidance, with clear plain guidelines and goals. Set out in plain text what they want from the business, how to record and achieve what it wants without jargon or complicated law speak all over the documents. Make it plain and simple to understand and carry out.” – Individual

Providing financial assistance

Grants and other types of financial assistance were mentioned by a few respondents as something the Scottish Government could provide to help with the transition. One individual noted that it could be grants for independent shops to offset the costs for the first year, and another two suggested the Scottish Government could fund reusable cups, with one suggesting a grant to allow traders to add logos or brand names to the cups to advertise the shop.

Equitable enforcement

A few respondents noted the importance of treating all suppliers equally. They supported legislation that includes strong enforcement procedures to ensure all suppliers are applying the charge and that no businesses benefit from not complying.

“Lay out your proposed method - whereby you will ensure all will pay equally.” – Individual