Annex G: Socio-economic duty assessment on Single-Use Plastics Bill
How The Environmental Protection (Single-use Plastic Products) (Wales) Bill will impact upon those who experience socio-economic disadvantage.
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Policy aims and intended effects
In 2018, research undertaken by the European Commission found that 80 to 85% of marine litter, measured by beach litter surveys, is plastic, with single-use plastic (SUP) items representing 50% of the total marine litter. Whilst it can often be difficult to identify the source of this plastic, the research found the most littered items on European beaches were those associated with “on-the-go” food and drink packaging. In addition to the visual impact of plastic marine litter, it can also present a hazard to wildlife if eaten and contribute to widespread microplastics contamination in our food chain.
Studies in Wales suggest SUP litter is also prevalent in our local environment. For example, the Welsh Government’s compositional analysis of litter found plastic items made up 40% (by item count) of the total sample analysed. Welsh beach and street cleanliness have also confirmed the presence of many of the items found by the European Commission’s research.
To help tackle this plastic pollution, we propose to introduce a Single-use Plastics Bill (the Bill), which will make it an offence to supply or offer to supply (including for free) the following commonly littered and unnecessary disposable SUP products to a consumer in Wales. We believe this will help shift behaviours amongst both retailers and consumers towards more eco-friendly materials or reusable products.
- drinks stirrers
- drinking straws (including attached straws)
- cups made of polystyrene
- takeaway food containers made of polystyrene
- cup and takeaway food container lids made of polystyrene
- plastic-stemmed cotton buds
- sticks for balloons
- oxo-degradable products
- plastic single-use carrier bags (SUCBs)
This is a key priority for Welsh Ministers and contributes to our long-term ambitions of phasing out unnecessary single-use products, especially plastic, and sending zero plastic to landfill. Whilst we recognise some uses of disposable plastic are essential, such as those used in medical settings, we want to see a greater shift to more sustainable reusable products. Where single-use products are needed, they should be designed in a way which minimises impacts on the environment.
What evidence has been considered to understand how the proposal contributes to inequalities of outcome experience as a result of socio-economic disadvantage?
What information has been gained through engagement with those effected by the proposal/decision and specifically those who suffer socio-economic disadvantage?
Preliminary Impact Assessment (2019-2020)
Initial research was undertaken by the Welsh Government between October 2019 and January 2020. The overall methods used for the 2019-2020 research included stakeholder interviews and desk-based research. The research considered the economic, social and environmental impacts of our proposals. It noted there would likely be an increased cost to individuals as a result of purchasing alternative products, although as this cost is spread across a very large number of individuals and businesses, it considered the marginal impact on each is small. The modelling estimates suggested the market for the selected products could increase in sales value by around 11% based on the prices of plastic and non-plastic alternatives at the time. This additional cost would be borne by companies and consumers but could be significantly reduced if the price of non-plastic products is reduced as demand increases.
Benefits of the proposals included in a reduction in the visual disamenity costs - in that less plastic litter could increase tourism/ visitors to an area, particularly coastal regions, and improve the local economy.
Public consultation (2020)
A full public 12-week consultation was undertaken between July and October 2020. A total of 3,581 responses were received. This comprised of responses from disabled people, those representing protected characteristic groups, environmental NGOs, Local Authorities, Town & Community Councils, volunteer and community groups and retail and manufacturing trade associations. A large number of responses were the result of organised campaigns coordinated by Dŵr Cymru/ Welsh Water and environmental Non-Government Organisations (NGOs).
Whilst no quantitative data was submitted to support or strengthen the 2019-2020 research, useful additional qualitative information was gathered. This has been used to “sense-check” and inform our Impact Assessments. The majority of respondents to the consultation agreed with the assumptions made in our research.
When asked whether they believed the potential environmental and social benefits outlined in our proposals outweighed the potential impacts on people in Wales, 80% agreed. A number of respondents suggested any inconvenience resulting from the bans would be short lived and people would adapt quickly. The introduction of the single-use carrier bag charge was frequently cited as an example of a policy that led to long-term environmental benefits despite short-term disruption for retailers and the public. Others felt the availability of alternatives meant any inconvenience would be minor and the regulations were necessary for the good of the planet.
In general, respondents considered there were suitable non plastic alternative products already on the market for most of the products proposed in the bans, such as paper or cardboard straws and cotton buds, plates and balloon sticks, and wooden cutlery and drink stirrers, paper /cardboard or other types of plastic cups and food containers available, and alternative bags, available at comparative prices.
However, concerns were raised from a number of people, including those who share a protected characteristic, of the possible disproportionate impact of the proposed ban on flexible drinking straws for the following reasons:
- Some older and disabled groups rely on flexible plastic straws to eat and drink safely or independently, in a variety of settings.
- Some alternative products, such as glass or metal, could cause injury for some individuals who have conditions that cause tremors and spasms.
- Single use alternative straws do not provide the same flexibility/functionality as plastic straws and therefore are unlikely to be a suitable alternative item for people who are bedbound, those that cannot re-position themselves to drink from cups or tilt their head back, those with dexterity problems or painful conditions.
- Purchasing straws made from other materials could impose additional costs to users as individuals are likely to require straws several times a day if they are reliant on them to eat and drink.
- Products sold that are suitable for re-use would require them to be cleaned/sterilised between each use creating inconvenience for users.
Exemptions to mitigate impacts
We recognise for some disabled people or those with accessibility needs, flexible plastic drinking straws are a necessity so they can eat and drink safely and independently. Our proposals include exemptions to protect access to SUP straws for those who need them. Once the ban is in force, SUP straws will be available for purchase at pharmacies, given on request, for example at hospitality or catering premises or provided for medical reasons, as follows:
- Pharmacies (including on-line) - are able to buy SUP straws from manufacturers or wholesalers so individuals who need them, or someone on their behalf, can purchase them for use at home or elsewhere.
- Premises providing food or drink – will still be able to buy SUP straws from manufacturers or wholesalers to give to someone who require them to eat and drink independently, or someone requesting a straw on their behalf. It is important to note that customers do not need to provide proof of need when requesting SUP straws.
- Medical purposes - Health professionals are able to supply SUP straws where required, this includes for use in hospitals and other medical settings.
By taking an approach that is consistent with other parts of the UK, the exemption provides clarity for people on how to access SUP straws wherever they are located. It also provides clarity and consistency for businesses.
Have protected characteristics been considered?
In developing the Bill, we have taken account of the feedback provided in relation to supporting the need of protected characteristic groups. In addition, we have facilitated additional discussions with the health and social care sector, and a range of protected characteristic groups to ensure we have fully understood individual requirements and feedback to the consultation.
Groups representing disabled people felt the removal of flexible plastic straws would cause carers of all ages additional caring and financial burdens. Many unpaid carers report that caring results in a negative and often lasting impact on their physical and mental health, but as with the rest of the population, many people with existing disabilities or long-term conditions also take on caring responsibilities.
The Well-being of Wales 2021 report, which provides insight on the state of the nation and the progress that’s being made against the Well-being of Future Generations Act 2015 well-being goals, provides data which demonstrates that individuals, who have a limiting long standing illness or disability, may already be socially and financially disadvantaged. Life costs you £583 more on average a month if you're a disabled person. Families of disabled children on average, face extra costs of £581 a month. For almost a quarter (24%) of families with disabled children, extra costs amount to over £1,000 a month.
The inclusion of exemptions to enable flexible plastic drinking straws to remain available for individuals or carers in low-income families ensures they are not further financially dis-advantaged by our proposals.
It was also noted a reduction in the number of plastic products being littered will help ease the financial burden on Local Authorities who are ultimately responsible for keeping our streets and roadsides clean. The cost savings can then be re-directed for use by other services that benefit the community.
Provide a summary of evidence and links
How could the proposal potentially further exacerbate inequality of outcome experienced as a result of socio-economic disadvantage?
Please provide detail regarding inequalities of outcome likely to be impacted and those people and communities likely to be impacted
Disabled people and others are likely to be impacted. Mitigation of these impacts is expected through the exemptions described above.
Provide a summary of evidence and links
How could the decision potentially improve outcomes for those who experience socio-economic disadvantage?
Please provide detail regarding outcomes that will be improved and for who.
Our proposals will have a significant positive impact on this issue by reducing the amount of SUP products littered and a long-term positive impact of reducing the amount of plastic polluting the environment, contributing to climate change. Our proposals will also provide cleaner green and natural spaces like beaches, forests, parks and countryside which has the potential benefit of improving mental and physical well-being as people enjoy their local environment more, which can also lead to greater social cohesion as people socialise and interact more with others in their community.
Provide a summary of evidence and links
How will you monitor the impact of this decision? (Please consider wider outcomes)
Our policy objective is to reduce the use of commonly littered and unnecessary SUP products, to prevent the negative impact from plastic pollution on our environment, wildlife, health and wellbeing and to respond to the climate and nature emergency.
Our communications and guidance will be developed for and in collaboration with relevant organisations, to provide information on products being banned or restricted, exemptions and timescales for phasing out the products.
The guidance will be supported by awareness raising to ensure everyone is aware of the need for some products to remain available to individuals who rely on them. It will also explain how we expect these products to be accessible and provide retailers specific guidance on this.
A post implementation review of the legislation, no later than five years after it has come into force, will assess the effectiveness of the policy objectives, including tackling the climate and nature emergency, reducing SUP littering, behaviour change to more sustainable alternatives. We anticipate this would include:
- Identifying and evaluating the impact the legislation has had on the use of SUP products and the associated behaviour of consumers in Wales;
- Identifying and evaluating the impacts the legislation has had on protected characteristic groups.
- Identifying and evaluating what impacts the legislation has had on businesses in Wales.
- Identifying and evaluating the extent to which the legislation has succeeded in encouraging a shift to reusable products.
- Identifying, where possible, and evaluating, the extent the legislation has had on reducing littering of SUPs following its implementation
Provide a summary of evidence and links