UK packaging producer responsibility system reform: partial business and regulatory impact assessment

9.0 Digital Impact Test

63. Changes to policy, regulation or legislation can often have unintended consequences, should government fail to consider advances in technology and the impact this may have on future delivery. This digital impact test is a consideration of whether the changes being made can still be applied effectively should business/government processes change – such as services moving online. Table 3 below details the evaluation of the proposed market restrictions on current and future digital developments. Overall, we consider that the proposed legislation will not have an adverse impact on digital technology developments.

64. In addition to the questions below, it should also be noted that the reform of the packaging EPR scheme will require new IT systems to facilitate the running of this scheme. As outlined in the UK IA, this will include carrying out functions such as tracking the packaging placed on the market, charging producers, and making the necessary payments from scheme administrators to stakeholders that are eligible for payments for managing packaging waste. These costs will be borne by the scheme administrator, with costs ultimately passed on to producers through the administrative fees paid to the scheme administrator and/or the regulators.

Table 3. Digital Impact Test Questionnaire.

Question 1. Does the measure take account of changing digital technologies and markets?

Potential changes in digital technologies and markets are being accounted for during the development of this legislation.

Question 2. Will the measure be applicable in a digital/online context?

Any legislation would apply equally to all obligated producers of affected packaging sold on the Scottish market, regardless of whether this packaging is sold digitally or through traditional offline channels.

The running of the scheme will be facilitated by new IT systems.

Question 3. Is there a possibility the measures could be circumvented by digital/online transactions?

No.

Question 4. Alternatively, will the measure only be applicable in a digital context and therefore may have an adverse impact on traditional or offline businesses?

Although digital technologies will be used to facilitate the running of the scheme, it is not expected that this will have an adverse impact on traditional or offline businesses. All businesses will be expected to comply with the new system.

Question 5. If the measure can be applied in an offline and online environment will this in itself have any adverse impact on incumbent operators?

No.