Charging for single - use disposable beverage cups: consultation analysis

7. Impact assessments

Along with the consultation paper, the Scottish Government published five interim impact assessments of the proposals covering:

• Interim Equalities Impact Assessment
• Interim Fairer Scotland Impact Assessment
• Interim Island Communities Impact Assessment
• Interim Business and Regulatory Impact Assessment
• Interim Strategic Environmental Assessment

This chapter presents the analysis of responses to Q15 to Q19, which asked respondents for their views on each of the interim impact assessments. These questions were answered by a much smaller proportion of respondents. Many comments reiterated points and themes that have been described throughout this report, in particular, the general themes both for and against a charge that were detailed in the analysis of responses to Q2. The analysis in this chapter, therefore, focuses on specific themes about each of the interim impact assessments.

Q15: Please provide any further information or evidence that should be considered in the accompanying interim Equalities Impact Assessment

Just under one in five respondents answered this question. The most common themes, from most to least, were:

• Impacts on disabled people and people with health conditions.
• That there are no anticipated impacts or that there is no further information to consider.
• Impacts on children, young people and families.
• Comments specifically referencing the assessment.

Impacts on disabled people and people with health conditions

Several respondents, mostly individuals, detailed potential impacts on disabled people and people with physical and mental health conditions, resulting from a charge. Suggested challenges for disabled people included carrying and cleaning reusable cups, as well as hygiene risks. It was noted this group can rely on single-use cups when away from home and the charge may disproportionately impact them.

Suggestions to address these challenges included having exemptions for single-use cups for disabled people and discounted or free reusable cups, which could be funded by the charge. A few comments noted that the interim Equalities Impact Assessment correctly identified there would be a disproportionate impact on disabled people.

“People with movement issues cannot carry around reusable cups easily along with other equipment, e.g. a walker, wheelchair and walking stick” – Individual

“Disabled people may rely on purchasing beverages in single-use disposable beverage cups when away from home and it may be that reusable alternatives or the logistics around them are not conducive to aiding independent living. This could result in rising costs for those that require continued use of single-use disposable beverage cups.” - LARAC

No impact or further comments

Some respondents noted there would be no or minimal impact regarding equalities or protected characteristics, that no additional information is required, or commented that every user of single-use cups should have to pay the charge.

Impact on children, young people and families

Reduced affordability for families, the need for exemptions for those receiving free school meals and more general comments about the charge negatively impacting children and young people were noted by some respondents.

“This could adversely affect poorer families who cannot afford to purchase robust reusable containers, especially if children are within scope of the scheme as they will inevitably lose these containers regularly.” – Individual

Comments specifically referencing the interim Equalities Impact Assessment

Some respondents specifically referenced the interim impact assessment. This included positive comments about disproportionately impacted groups being identified in the assessment and agreement with what was stated in the assessment. Negative comments were also made, such as the view that there was insufficient analysis of the impact of the proposal, that the impact assessment stated there would be detrimental impacts on certain groups but that the implications were skipped over in the proposal, and the impact assessment made comparisons to the EU rather than the UK.

Other comments at Q15

Concerns around hygiene and reusable cups were mentioned by some respondents, as noted in Q2. A small number of respondents, the majority of which were organisations, suggested further consultation with groups with protected characteristics, especially disabled communities.

A few respondents commented on other groups that may be impacted by a charge, and one commented on the need for more understanding about these potential impacts. These included people on benefits, transient populations, pregnant people, minority groups, people who use single-use cups for religious reasons, and, more generally, negatively impacting disadvantaged groups. These groups were highlighted as possibly being at a disadvantage, but respondents did not tend to elaborate on why.

Negative impacts on older people were stated by a few respondents, such as hygiene risks for older people from reusable cups or challenges to carry reusable cups for those with mobility issues, although no explanation was often given. Some respondents also noted impacts on those living or working rurally.

Q16: Please provide any further information or evidence that should be considered in the accompanying interim Fairer Scotland Assessment

Just over one in ten respondents answered Q16. The most common themes relating specifically to this question, in order of most to least prevalent, were:

• Disproportionate impacts on low-income groups and the financial burden on consumers in a cost-of-living crisis.
• Suggested alternatives to the proposal (see Q19).
• Broad comments about the charge being unfair.
• The need to consider other groups.

Disproportionately impacts low-income groups and increased financial burden

Some respondents, most of which were organisations, suggested that the charge could disproportionately impact the poorest people in society – in particular, those on low incomes, in poverty, or in more disadvantaged communities. Another theme raised by some was that the charge could add a financial burden to consumers in a challenging time with the cost-of-living crisis.

These comments often reiterated the points raised in responses to Q2. However, it was noted in Q16 that these low-income groups may not have the option to purchase and carry a reusable cup and that the one-off upfront payment for a reusable cup could be a barrier. One respondent stated that the payment would not deter more affluent consumers from purchasing a single-use cup.

“It is noted that the Fairer Scotland Assessment does acknowledge that low-income groups have the potential to be adversely impacted by a charge, although the charge is avoidable by using a reusable cup. However this could also be mitigated by making the charge at the lowest end of the scale with the option to increase this should this not achieve the desired impact.” – Aberdeenshire Council

“I think this is penalising people, often on low-paid jobs, who may not have an option to carry a reusable cup when they just want a hot drink during their day.” – Individual

“The impact will be proportionately more burdensome on low-income families. The only way to avoid payment is to buy reusable cups, but what low-income family can afford the one-off payment of £10 - £20 per cup” - Individual

Fairness and the need to consider other groups

General comments were made by some respondents, all of whom were individuals, on the proposal being unfair and the need to consider other groups. This included comments from one or two respondents around the following being unfair: exemptions, environmental degradation, allowing businesses to pollute – both in terms of carbon emissions and waste from single-use cups, and it is unfair to taxpayers, customers, young people and future generations who will have to pay for the consequences of environmental harm from previous generations.

Other comments at Q16

There were comments about the proposal being unfair on businesses and their staff; this is covered under Q18.

Comments specifically mentioning the interim Fairer Scotland Assessment were made by a small number of respondents. This included singular comments on a dislike of Fairer Scotland and that all issues are covered in the assessment.

Other themes raised by a few respondents included: The need for more thought on how this proposal will work in practice, data measuring, addressing evidence gaps and limitations of evidence used, co-designing implementation suggestions and to further consider impacts on homeless people.

General comments were made that there is no impact, no additional information is required or that the impact is unknown. Calls for there to be no exemptions and that the charge should apply to everyone equally, and the need for more consultation with relevant groups including those with lived experience, were also made.

Q17: Please provide any further information or evidence that should be considered in the accompanying interim Island Communities Impact Assessment

Q17 was answered by 67 respondents. Each theme was raised by a small number of respondents and mostly individuals, but the most common, in order of prevalence, were:

• That island communities should not be treated differently.
• Challenges with waste and recycling facilities on islands.
• Positive environmental impacts for island communities.

Island communities should not be treated differently

Some respondents commented that island communities should not be treated differently from mainland Scotland regarding the proposed charge and that there is no impact on island communities because of the charge.

“I live on an island. I think in this case there are no special reasons for different treatment.” – Individual

Challenges with waste and recycling facilities on islands

A small number raised what they described as an ongoing challenge with waste and recycling facilities on islands. A need for more litter collection and a suggestion to consider reusable cup schemes for people on islands was noted. One commented that given these challenges, the proposed charge would be positive for island communities.

“Waste disposal is a real problem for island communities, and any action to reduce waste arisings (such as the proposed charge) has to be very welcome.” - Individual

Positive environmental impacts on island communities

A few respondents noted potential positive environmental impacts for island communities that could result from the change. This included preventing single-use cups from ending up in the sea and landfill, and that mitigating climate change is more pressing for island communities.

Other comments at Q17

Cost-related impacts for island communities were noted by a few respondents. This included a reduction in costs for shipping single-use cups and mentions that it could increase some costs or reduce revenue, such as tourists deciding not to make purchases.

“Island communities already have higher costs to bear than the mainland and, whilst the tax will be the same, it is yet another cost that makes island living so expensive” - Individual

Some respondents stated that they had no additional information regarding this question or that the impact on island communities was unknown. One comment suggested that more research may be needed on single-use cups in island communities.

The need to consider consultation, communication and engagement with island communities was raised by a few respondents and there was a suggestion to inform tourists of the charge. It was noted this could support the implementation of the policy.

Q18: Please provide any further information or evidence that should be considered in the accompanying interim Business and Regulatory Impact Assessment

Q18 was answered by 89 respondents. The most common themes were:

• Potential negative impacts on businesses.
• Comments opposing the proposal.
• Suggested alternatives to the proposal (see Q19).

Potential negative impacts on businesses

A range of negative impacts on businesses that could potentially result from a charge were raised by some respondents, most of whom were from organisations, typically reiterating the themes which are detailed in the analysis of responses to Q2. Respondents raised a potentially disproportionate impact on small and medium-size businesses compared to larger businesses. Respondents also noted potential job losses that could result from the charge, as well as negative impacts on sales and the wider economy. It was also suggested that the proposal could detract from other sustainability initiatives put in place by businesses. Other concerns included hygiene risks for staff members with using reusable cups and the view that a high number of regulations is making it difficult for businesses generally.

“The cumulative cost of the high volume of regulations that are coming down the road for our sector makes the trading environment for retailers very difficult.” – Scottish Grocers’ Association

“[The proposed legislation] will without doubt bring some of the smaller businesses impacted, such as former police boxes that have been converted to coffee shops, to the end of their trading life. It will artificially create inflation in the consumer arena and give Scottish businesses an unfair disadvantage on the UK and European stage.” - Surgeons Quarter Limited

Comments opposing the current proposal or suggesting considerations

While some respondents explicitly stated that they do not support the charge, some others, most of whom were from organisations, stated that more work and time is needed prior to implementation, along with suggestions for its implementation. This included considerations around monitoring compliance, providing support and assistance to businesses for implementation – in particular small businesses - and a suggestion to consider a deposit return scheme once implemented.

Other comments at Q18

Concerns were raised by some respondents that businesses could pass the cost entirely onto customers. One respondent suggested that the policy could unintentionally result in increased retail crime, specifically shoplifting which they noted is already rising due to due to the cost-of-living crisis and ongoing rising food prices.

A few individuals expressed a view that businesses should take responsibility for the environmental problem created by single-use cups. This included suggestions that the responsibility should equally apply to businesses, concern that businesses think more of profit than of the planet, support for businesses to use reusable cups, and for big businesses in particular to take greater responsibility.

“Business should face up to the environmental costs that they create and do not pay to resolve.” - Individual

A concern raised a few organisations was that the charge could increase administrative burdens and costs for businesses.

Q19: Please provide any further information or evidence that should be considered in the accompanying interim Strategic Environmental Assessment

Q19 was answered by 93 respondents. The most common themes were:

• Calls to consider alternatives to the proposal which respondents would more effectively create environmental improvements
• Concerns about the environmental impact of using reusable cups
• Positive environmental benefits arising from the proposal.

Consider alternative approaches

Some respondents suggested other solutions that they felt would be more appropriate. Again, these comments typically reflected themes raised in response to Q2 and included the need for improved recycling infrastructure, having more bins available - including in places where people tend to use single-use cups - to reduce litter, and making single-use cups more environmentally friendly with suggestions to use recyclable materials, paper cups, and fibre-based cups. Suggestions were also made to encourage recycling, provide anti-litter education, support cup innovation, and to consider mandatory return and take-back schemes.

While these were described in the analysis of Q2, a few respondents reiterated the findings from the WRAP report which they felt concluded that taxes, charges, or bans on cups have a net negative benefit, whereas mandatory take-back and recycling targets offer a net positive benefit, and therefore felt these other approaches should be prioritised.

Concerns about the environmental impact of reusable cups

Comments highlighting the need to consider the environmental impact, health impact or other concerns around reusable cups were made by some respondents, most of whom were from organisations. This included:

• Hygiene considerations and poor cleaning of reusable cups.
• Their manufacturing and the plastic required to make, and the disposal of reusable cups and potential littering of them.
• The potential for reusable cups to be of poor quality and then disposed of, with a suggestion to have a definition of a reusable cup to avoid this.
• The environmental impact of washing up liquid and hot water to clean reusable cups.
• The cost, and carbon cost, of the reusable cups.
• Potential to overestimate the number of times reusable cups are used.
• One comment was made about the potential consumption of microplastics from reusable cups.

“Consistent interpretation of measures is important, and consideration should be given to what constitutes a ‘reusable cup’ to avoid the potential unintended consequence of businesses stocking low-cost, low-quality plastic ‘reusable’ options to sell to consumers. This could potentially result in consumers discarding the cup due to poor quality. This potential behaviour would have a detrimental impact on the intended policy lever and would have negative environmental impacts.” – Consumer Scotland

“Making and producing reusable cups isn't great... Because these reusable cups produce CO2, have a detrimental environmental impact at materials extraction etc, and will end up in the general waste!” - Individual

Positive environmental benefits arising from the proposal

Some, mostly individuals, noted the positive environmental benefits that could result from this proposal. This included reduced litter, reduced energy consumption, benefits to wildlife, reduced resources used, and general support for the proposal and the environment.

“For years, no one ever has counted the cost to the public purse for cleaning up single-use packaging. The cost to the environment and nature can't be measured so it's time for a change” – Individual

“A single-use cup charge should reduce litter, improving community wellbeing, reducing the damaging impacts on our environment and wildlife (these impacts are far ranging).” – The GRAB Trust

Other comments at Q19

Some respondents, most of whom were from organisations, made comments specifically about the interim Strategic Environmental Assessment, such as comments expressing satisfaction with the assessment and that no further impacts are evident. Further comments suggested that this policy be implemented and that further policies be made in this area. Contrasting comments, such as the below, stated that there was insufficient evidence that the policy would achieve its aims.

“The interim assessment fails to provide sufficient evidence that this tax will equate to significant environmental gain.” - Individual

Comments on the need for bigger environmental change and on the Scottish Government's environmental policy were made by a few respondents. This included individual comments highlighting the need for a circular economy and to have targets to eliminate rather than reduce single-use products.

The need for more research prior to implementation and to monitor compliance was called for by a small group of respondents. This included calls for more consultation and for more research on the impact of reusable cups; for example, one respondent listed a range of priorities for research.

“Would be good to look at: 1 - waste volume reduction (and weight), 2 - land use reduction (land used to manufacture these disposable cups), 3 - revenue raised by the fee and potential positive environmental impacts, 3 - carbon reduction impact (Inc miles travelled), 4 - chemical use reduction impact, 5 - reusable cups impacts versus ceramic use (on site washable) impacts, 6 - best reusable cups for real material recovery”. - Individual

A few respondents made general positive comments. However, a small number raised doubts that the proposal would have a significant positive environmental impact or result in behaviour change, also noting that it may reduce cup innovation. The ongoing need for better disposal and recycling infrastructure for single-use cups, even if the charge is implemented, was raised by a few respondents.