Environmental Protection (Single-use Plastic Products) (Scotland) Regulations 2021: strategic environmental assessment - post adoption statement

A report on how we have taken environmental considerations, the Environmental Report and consultation findings into account when finalising the The Environmental Protection (Single-use Plastic Products) (Scotland) Regulations 2021.

3. How the Environmental Report has been taken into account

3.1.1 The market restrictions on the identified single-use plastic items would lead to changes in the products that consumers use; certain single-use plastic items, which have little to no opportunity to be reused or recycled will be phased out and replaced with single-use items made from recyclable, non-plastic materials. The market restrictions may also lead to an increase in the use of products that can be reused, further improving the impact from the market restrictions. The market restrictions may also provide an opportunity to adopt innovative solutions, or alternative materials, that reduce the demand for virgin fossil-based plastic.

3.1.2 The assessments analysed the impact of replacing each single-use plastic item (the Business-as-Usual baseline) with an alternative single-use item, manufactured using non-plastic (for most of them) and recyclable materials.

3.1.3 The market restrictions are expected to provide fewer negative impacts to the quality of Scotland's biodiversity. The elimination of the targeted single-use plastic items will remove these from local terrestrial and marine ecosystems. Whilst littering of alternative items may occur, these are expected to have fewer negative environmental effects on biodiversity at terrestrial sites of importance for nature conservation, including in particular those sites protected for their importance to wild birds which are particularly vulnerable to the effects of litter.

3.1.4 The Environmental Report has explored the impact of the market restrictions upon Scotland's soils. Oxo-degradable plastics are predominantly used as a mulch film within agriculture.[21] The fragmentation of this material into microplastics or to chemical decomposition may lead to their presence within the immediate and surrounding soil as well as other environments when washed from fields into local waterways. The assessment explored the impact of market restrictions of oxo-degradable plastics as well as single-use plastic items. The assessment shows that the restrictions – and adoption of items made from alternative materials – are expected to reduce the risks to soil quality which exist because of single-use plastic items and oxo-degradable plastics. The Scottish Government is collecting further evidence before taking action on oxo-degradable plastics.

3.1.5 A climatic and carbon assessment, which compared the targeted single-use plastic items, against the alternative items, demonstrated that a change in consumer behaviour, to adopt alternative items, would lead to a 59% reduction in carbon impacts, equating to carbon savings of 6,188 tonnes CO2e per annum, due to the shift from high-carbon fossil-based materials to low-carbon materials (e.g., paper).[22] It is noted that any increase in the use of reusable items, opposed to alternative single-use items, may generate further carbon improvements dependent upon the reusable item and its usage.

3.1.6 The market restrictions are expected to remove the targeted single-use plastics from use in Scotland. These materials are lightweight and contribute an insignificant volume, by weight, to waste streams. The use of alternative products will lead to a slight increase in the tonnage of wastes if single-use plastic items are replaced by products of heavier, alternative materials. It is anticipated that the waste tonnage may increase by 1,440 tonnes per annum however this can be addressed through greater application of multi-use items.[23]

3.1.7 The Environmental Report assessed the impacts of the market restrictions, and the alternative materials that would likely be used to replace the single-use plastic items, against landscape and visual impacts. The introduction of market restrictions, against all items within the scope of the market restriction, are expected to provide positive impacts by reducing plastic litter in the marine and terrestrial environments.

3.1.8 The assessment included consideration of the cumulative impacts of the market restrictions, when compared to the alternative materials. The assessments show that the measures will generate cumulative positive effects in respect of climatic factors, landscape/visual impacts and biodiversity related to reduced littering.

3.1.9 No cumulative significant negative effects have been identified during the assessments.

3.1.10 The assessment of the market restrictions presented in the Environmental Report has identified opportunities to mitigate potential negative effects and enhance positive effects associated with their implementation. Following assessment of the impacts of the market restrictions, the Environmental Report recommended that any chosen market restriction exhibits the following characteristics:

  • That the restrictions are implemented to reduce Scotland's reliance upon single-use plastic items.
  • That the market restrictions extend to the list of items outlined in the Environmental Report and consultation exercise.
  • That ongoing monitoring is implemented to assess the impact of the restrictions, on aspects such as litter, and identify any issues where further interventions are needed to address litter.

3.1.11 How has the assessments in the ER altered the shape of the final approach?

3.1.12 The preferred option is to adopt the market restrictions, with the exception of bowls, trays and platters and oxo-degradable plastics.

3.1.13 Proposed mitigation measures of relevance to all example schemes identified in the Environmental Report are summarised in Table 3.1.

Table 3.1 Mitigation of environmental effects

Environmental Effect

Proposed mitigation effort

Increased waste tonnages through the adoption of alternative single-use items

The Scottish Government will monitor the response to these restrictions and assess what more needs to be done to address our throwaway culture.

Section 5.4 of the Environmental Report states:

"Other recyclable alternatives, primarily made of wood or fibre, can be composted and so it would be imperative to increase access to and use of appropriate recycling infrastructure to ensure the capture of these materials for recycling."

The Non-Technical Summary to the Environmental Report also states as a key recommendation"Ensure recycling infrastructure is available to capture and recycle non-plastic alternatives".

Section 7.5 of the Environmental Report states:

"…it would be imperative to design a clear and targeted awareness campaign to ensure that citizens are well informed about the new measure and the best disposal route for alternative material in order to avoid unnecessary landfilling and to ensure that material value is preserved into any secondary use phase."

The actual impact upon Scotland's Greenhouse Gas emissions is dependent upon the alternative single-use items, or reusable items, used to replace the banned single-use plastic items.

The Scottish Government can continue to monitor the emissions associated with the market restrictions.

Section 4.4 of the Environmental Report states:

"The majority of single-use non-plastic items that would likely replace single-use plastic products are expected to achieve a reduction in greenhouse gas emissions. This intervention should not however undermine the substantial carbon savings attributed to shifting from single-use to multi-use items, such as replacing single-use plastic-coated paper cups with reusable cups…

Replacing single-use plastic products with reusable, non-plastic alternatives will hold obvious emissions benefits. If no product were required at all (single-use plastic or otherwise), this would ultimately achieve the highest carbon saving."

A potential increase in material demand to manufacture single-use, or reusable items, made from alternative materials.

Section 5.4 of the Environmental Report states:

"Single-use plastic items targeted by market restrictions are expected to be replaced by heavier single-use items made of paper or wood. This will lead to a shift in materials used from fossil-based materials to wood or paper which will require additional land and water resources…. This can be best addressed through greater application of multi-use items and particularly for frequently used items such as plates and cups....

More importantly, additional measures should be considered in order to reduce the generation of non-plastic single-use items and incentivise behavioural change towards the adoption of multi-use alternatives."

3.1.14 In refining and developing the preferred option, where relevant, Scottish Government has taken into account the above proposed mitigation measures.



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