SUBMISSION FROM ASDA STORES LTD
Environmental Levy on Plastic Bags (Scotland) Bill
Many thanks for your invitation to provide evidence on the Environmental Levy
on Plastic Bags (Scotland) Bill. I have attached a detailed response, outlining our
views on the questions that that you have raised.
We are generally concerned by this move towards “issues-driven” taxation rather
than a more comprehensive approach to tackling agreed problems. On Tuesday
5 July 2005, the government in the Irish Republic announced the introduction of
a tax on chewing gum, polystyrene food wrappers and cash machine receipts. If
a plastic carrier bag tax was introduced in Scotland could we also expect a
chewing gum tax to follow, and if so, how would this additional tax be collected?
Education not taxation must be the sensible and sustainable way forward.
Ian Bowles, our Corporate Social Responsibility manager, would welcome the
opportunity to discuss the issues raised in this response with you in more detail
and will contact you to arrange a meeting. We wish to be constructive. Ian is
available 0113 241 7653.
Environmental Levy on Plastic Bags (Scotland) Bill.
To what extent are plastic bags a problem, in terms of waste management
and their impact on the environment, including wildlife?
Litter management
In considering waste management, it is worthwhile starting with litter
management.
Plastic carrier bags are not a significant litter problem and there is absolutely no
evidence that they ever have been. Most litter on our streets is fast food
packaging, bottles and cigarette ends. HM Treasury estimate that only 0.3% of
litter comprises plastic bags of any kind. Therefore reducing the number of
plastic carrier bags we use will make little difference to the amount of litter on our
streets.
It is also claimed that windborne plastic bags originating from landfill sites are a
major cause of litter. However, most plastic bags in landfill are local authority
encouraged refuse sacks which make a significant major contribution to the safe,
healthy and efficient disposal of waste. Wind blown plastic bags of all types from
landfill sites are an issue to be addressed by improved landfill site management.
Landfill
Plastic carrier bags represent less than 1% of landfill volumes, taxing them would
be unlikely to deliver any significant reduction in the amount of waste at landfill.
They take up an insignificant amount of space in landfill yet provide essential
extra stability. This is in comparison to materials like paper and wood-based
products and putrescible waste. Such products are also most likely to become
major contributors to greenhouse emissions and groundwater pollution.
Without the containment offered by plastic refuse sacks, bin liners and carrier
bags, our society would risk greater public health hazards.
Bio-degradable bags
There is no consensus on the comparative benefit of so-called biodegradable
products. These will not de-grade in landfill sites if the conditions are not right.
This lack of consensus is reflected in the Landfill (Scotland) Regulations 2003 1
(implementing the EU Landfill Directive (1993/31/EC)) which imposes targets for
a reduction in the amount of biodegradable municipal waste disposed of to
landfill. Biodegradable bags, whilst suitable for applications such as home
composting, could also seriously contaminate established recycling programmes.
Impact on Wildlife
1
www.sepa.org.uk/groundwater/legislation/landfill_scotland_regs.htm
The impact of plastic carriers on wildlife is difficult to quantify. In the case of
beaches, for example, the Marine Conservation Society Beachwatch 2004 2
survey shows that all plastic bags - not just plastic shopping bags - comprise only
2.5% of litter compared with fishing debris 14.1%, sewage-related debris 9.3%
and shipping litter 2.2%.
The UK Government’s Charting Progress report 2005 3 , which assessed the
current state of UK seas states, “The current levels of beach litter are high”, and
that “marine litter remains a problem for coastal communities and the marine
environment.” The report concludes, “Litter on beaches is totally preventable”.
Such litter can, of course, be the result of either the illegal and irresponsible
dumping of waste at sea or by tourists and, as such, would not be significantly
reduced through the imposition of one levy in one country.
You may be interested to learn that three ASDA stores in Scotland, Bridge of
Dee, Dyce and Ayr, have ‘adopted’ beaches. Each month, in partnership with
the local council, our store colleagues carry out a litter pick to keep the beaches
clean, helping to create spaces and places that local communities can feel proud
of.
QUESTION: To what extent is the proposed levy likely to affect consumer
behaviour, and what alternatives to plastic bags are people likely to adopt?
Is a levy a suitable method of addressing the problem?
Current Consumer Behaviour - Recycling
Research commissioned by the UK Environment Department (DEFRA) and
WRAP proves conclusively that 80% of all householders reuse their plastic
carrier bag at least once for applications varying from bin liners to the safe and
hygienic containment of dog droppings 4 .
This level of reuse, an essential part of the hierarchy of good environmental
practice, is greater than reuse levels for any other consumer “disposable
product”. Even after such high levels of re-use, Analyses of Household Waste
Composition by DEFRA and WRAP together with numerous litter surveys
indicate that plastic carrier bags comprise far less than 1% of litter on our streets
or landfill.
This is mirrored by the HM Treasury Plastic Bag Tax Assessment 2002 stated
the UK use of plastic carrier bags “translates to about 0.3% of the municipal
waste stream.” “If the aim were to tackle the litter problem, it would be misguided,
as it would fail to address the fundamental cause of litter – people’s behaviour.
2
3
4
Marine Conservation Society Beachwatch 2004 - www.adoptabeach.org.uk/News/pressrelease05.htm
The UK Government’s Charting Progress report 2005 - www.defra.gov.uk/environment/water/marine/uk/stateofsea/
In 2005, the Scottish Executive introduced the ‘Dog Fouling (Scotland) Act’. Failure to clean up after your dog is now an
offence and results in a fixed penalty fine.
If the levy was imposed, consumers may take home less carriers bags but would
instead purchase single-use bin liners – this was the experience in the Republic
of Ireland. This suggests that, whilst carrier bag use falls, the amount of plastic
in municipal waste streams stays the same or indeed increases.
Alternatives to Plastic Carrier Bags
Most retailers operate "bags for life" schemes where a charge is made for a
strong and durable plastic bag. ASDA have recently introduced the ‘Green Bag’
made from woven polypropylene and designed for re-use. The ‘Green Bag’ is
100% recyclable, machine washable and at 58p, it’s very affordable.
Some retailers may adopt paper bags to replace the plastic bags covered by the
levy. This would have a dual negative effect. One, there is no incentive on
customers to change behaviour and secondly, paper is more energy-intensive to
create and transport than plastic and takes up more space in landfill. It would be
worse from both an environmental and a waste management point of view. And
again, consumer may buy more single-use bin liners because they would not use
paper bags for this purpose.
Is a levy a suitable method of addressing the problem?
There appears to be little clarity on the “problem” which the proposed tax is
designed to solve.
We have illustrated that carrier bags form a very small proportion of litter and
waste to landfill. Indeed, plastic bags perform and important containment role in
waste management. It is also the case, as proven in the Republic of Ireland, that
whilst carrier bag use may fall, plastic bag use does not. Consumer will buy
single-use bin liners rather than using carrier bags.
The solution to litter has to be a comprehensive approach aimed at changing
attitudes and behaviour. Such an approach would address all litter through a
combination of public education, enforcement of the litter laws and local authority
cleansing programmes.
What are the likely environmental impacts of the proposed levy, including
the likely impacts of alternatives?
There is no more environmentally-friendly option, including paper and
degradable bags, than the conventional plastic carrier bag. A carrier bag tax will
effectively drive people to more environmentally-damaging alternatives.
When the plastic carrier bag tax was introduced in the Republic of Ireland (RoI),
there was an initial 90% reduction in the use of plastic carrier bags, but one
unforeseen consequence was a 300% increase in black plastic bin liner sales.
As highlighted above, plastic carrier bags are re-used time and time again. The
UK Government’s own estimates suggest that four out of five people re-use
single trip plastic carriers in the household. Replacing these bags would cost
more in resources and energy. So a tax is likely to mean more plastic is
produced, not less.
Only about 2% of all the oil consumed in Europe is used for all plastic film
packaging and plastic carriers are a very small part of even this percentage. The
vast majority of oil, nearly 85%, is burned as fuel in cars and lorries or for heating
and power. A carrier bag tax will make no real difference to oil consumption.
The energy usage for plastic carrier bags is far less than for the equivalent paper
bag as plastic films are amongst the most energy-efficient packaging material
produced today. Even after use and re-use, we can recover this energy through
clean, safe energy-from waste plants to provide district heating and electricity for
homes, hospitals and schools as widely practised in Denmark, Switzerland, in
fact, throughout the EU.
Plastic is the lightest of all carrier bag materials so it takes much less fuel to
transport and creates less damaging exhaust emissions than any alternative. A
paper bag weighs roughly six times more than a plastic carrier, is four times
more expensive and takes up ten times more space for storage and landfill.
Plastic has genuine environmental advantages across its full life cycle.
What are the likely effects of the proposed levy on businesses, including
retailers?
The experience in the Republic of Ireland (RoI) has demonstrated that a tax on
plastic bags has unintended consequences. In many cases, retailers in response
to consumer demand switched to paper bags in retail outlets. This has severe
environmental costs in terms of transport and fuel usage as paper takes up ten
times the storage volume of plastic bags.
Additionally, there has been a high level of theft from the shelf as well as theft of
wire baskets and trolleys all of which have environmental impacts as well as
economic effects for retailers and ultimately the price the consumers pays.
Is the method provided in the Bill for enforcing the levy appropriate and
workable?
We would strongly suggest that the structure of retailing in the UK also makes it
wholly impracticable for local authorities covering small geographical areas yet
served by major national and international retail operations to expect that a
plastic bag tax could be efficiently or effectively imposed or policed within their
geographical area.
The method being proposed is complex and would be difficult and, therefore,
expensive, for a national retailer to comply. We would have to manage
relationships with every local authority in Scotland. Also this tax proposal does
not take into account the administrative costs borne by the authorities - both local
and national - in order to police the scheme and which will be paid for by the
public.
In the Republic of Ireland the ‘environment levy’ is paid by the retailer directly to
the Collector General either by cheque or via the internet on ‘Revenue on-line’.
Local Authorities have a role of ensuring compliance with the levy:
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Ensuring that the levy is charged by accountable persons to their customers
Taking appropriate action in cases where it has been established that the levy
has not been so charged
Maintaining continued public and business awareness in relation to the levy
QUESTION: What should funds generated by the levy be spent on? Should
these funds be ‘ring-fenced’ for this purpose? Should this be specified in
more detail in the Bill?
The Irish bag tax has not generated any significant funds for the ‘environmental
good’ and we have seen no evidence of any kind of schemes which have been
funded by the plastic bag levy since it was introduced in April 2002, some three
years ago. Once administration costs are deducted, there may be no net income
generated by a plastic bag tax. This might explain the lack of publicity in Ireland
regarding genuine net income (following deduction of administration costs by
authorities etc) and the application of any such income to bona fide
environmental projects in that country.
The much more substantial funding generated from the Landfill Tax has already
supported many excellent environmental projects and served key aims of
preventing and reducing waste sent to landfill. The Landfill Tax is administratively
far more practical and equitable as it applies to all forms of municipal waste
regardless of material type.