House of Commons - Plastic bags - Environmental Audit Committee

Plastic bags - Environmental Audit Committee Contents

2 Reducing bag use

16. The evidence we have received suggests that re-using bags is the most effective way to reduce their environmental impact. David Newman of the Italian Association of Composters told us that the best plastic bag is "the one you don't see and you don't use."[42] Professor Thompson of Plymouth University believed that "the clearest message ... is reduction in use".[43]

Behaviour change

17. There is strong evidence that a charge for plastic bag use leads people to use fewer bags. Dr Poortinga of Cardiff University, an expert in environmental psychology who evaluated the Welsh scheme,[44] told us that most charging policies for plastic bags have been effective.[45] He believed that a charge is a "habit disruptor" that forces shoppers to make a conscious decision as to whether they want to use a plastic bag or not.[46]

18. A charge is typically twice as effective in reducing the use of single-use carrier bags as voluntary approaches. Dr Poortinga reported that field experiments in which supermarket shoppers received prompts, or "persuasive normative messages", reduced carrier bag use by 20%-40%.[47] In a similar vein, the British Retail Consortium told us:

19. There is extensive research showing that simplicity is the key to successful behaviour change policies.[49] Dr Poortinga told us that the proposed exemptions in England for biodegradable bags (Part 3) and small retailers (paragraph 37) "gives mixed messages; for the consumer, it is not very clear", and concluded that "it would be less effective than a charge on all types of carrier bags".[50] The British Retail Consortium, similarly, believed that "if the charge is introduced as currently proposed, retailers will be faced with complex messages to communicate to shoppers."[51] Campaign for the Protection of Rural England and Waitrose arrived at similar conclusions.[52] The Welsh Government concluded that it is not necessary to take such a complex approach. Matthew Quinn from the Welsh Government told us:

20. Wales achieved a 76% reduction in single-use bags through a 5p charge, and Defra estimated that a similar charge in England would result in 4.2-5.6 billion (60-80%) fewer single-use plastic carrier bags being used and discarded each year.[54] Given that the proposed English scheme would have more exemptions that the one in Wales, it is likely that the reduction in bag use would be lower than the 76% achieved in Wales. Without additional complexity from exemptions for small retailers (which we discuss below) and for biodegradable bags (which we discuss in Part 3), it might achieve as large a reduction in bag use and littering.

21. Wales, Northern Ireland and Scotland have each set the charge at 5p, whereas the Republic of Ireland has set it far higher. Matthew Quinn told us that Wales "originally consulted at 7p, and that was set after economic work", but was reduced to 5p after retailers said it would be easier to administer at that level.[55] The charge in the Republic of Ireland was deliberately set six times higher than the average level that consumers reported that they would be willing to pay for a bag to strongly influence consumer behaviour, and led to a 90% reduction in use (paragraph 5).

22. Dr Poortinga suggested that in the longer term the charge might need to be raised in order to retain its effectiveness. Studies that have tracked carrier bag use have suggested that use may start to increase again some years after the introduction of a charge.[56] Ireland increased its charge to 22 cent (18p) in 2007, with the aim of keeping plastic bag per capita usage to no more than 21.[57] Northern Ireland originally proposed a rise in the charge to 10p in April 2014, but this has now been cancelled as, according to Defra, the charge has been so successful.[58]

23. Although there is evidence that higher charges can achieve greater impact, a charge set at 5p has been shown to be highly effective in Wales in substantially reducing use. Evidence from Ireland suggests that increasing the size of the charge, or having a credible threat to do so, is important for sustaining changed behaviours. The Government should implement a 5p charge for all single-use carrier bags, following the example of the scheme in Wales, but should review the level of the charge after two years to assess if an increase is necessary.

Bag material: environmental impact

24. Dr Swannell of WRAP told us that deciding on the best material for bags involved complex judgements, including its potential impact in the marine environment.[59] An Environment Agency study in 2006 (paragraph 13), comparing the resources and carbon emissions needed to produce, transport and dispose or recycle different types of bag, showed that thin plastic bags have the lowest environmental impact in terms of emissions (Figure 2).Figure 2: Carbon impacts of different types of bag

Type of carrier bag Carbon impact if not re-used
(kg CO₂, for a month's worth of bags)
Number of times used to have less environmental impact than a single-use plastic bag used once and thrown away

Thin single-use High-density polyethylene (HDPE) plastic bag 2.08

HDPE bag
with a prodegradant additive ('Oxo-biodegradable')
2.25

Starch bag[60] 4.69 2

Paper bag 5.52 3

Low-density polyethylene (LDPE) bag —thin bag for life 6.92 4

Non-woven PP bag—Thicker bag for life 21.51 11

Cotton bag 271.53 131

Source Environment Agency, 'Life cycle assessment of supermarket carrier bags: a review of the bags available in 2006'[61]

25. The Government has proposed that the 5p charge will apply only to single-use plastic bags. It would not apply to paper bags, or to others not containing plastic.[62] The Government is also proposing that biodegradable bags are exempt from the charge (Part 3).

PROPOSED EXEMPTION FOR PAPER BAGS

26. The evidence from life-cycle analysis suggests that a paper bag needs to be reused at least three times to make its emissions impact lower than that of a typical single-use plastic carrier bag (Figure 2). British Retail Consortium (BRC) told us that in the Republic of Ireland, which only applied the charge to plastic bags, some retailers turned to using paper bags instead.[63] BRC warned that not including paper bags in any charging scheme in England "would increase the environmental impact of single-use bags which runs contrary to the aims of the proposed charge."[64]

27. The Welsh Government decided to apply the charge to all bags in order to prevent such substitution. They told us:

Our experience from looking at the issue and speaking to colleagues is that, if you exempt some types of bags, there are substitution effects into those bags. If you exempt paper or compostables, you get more use of those. The work that the Environment Agency did for us suggested that those bags had a greater environmental impact in the round than a light-gauge, single-use bag. It did not look attractive for us to do that.[65]

The Government told us that it did not think that any increase in use of paper bags would be significant:

₂

However, there is little basis for the Government's assertion that paper bag use might only rise by 50%, which it presents as a worst case scenario. Given the current low levels of use of paper bags amongst high street shops, if large retailers transferred to using paper bags, the increase could be significantly higher than this.[67] There are few data currently collected and published about bag use amongst high street retailers, so this change would currently be hard for the Government to monitor.

Paper bags can have a greater emissions impact than plastic bags. Exempting paper bags from the charge, as the Government proposes, would weaken the message to reuse bags, diminish the impact of the charge and the likely reduction in the number of bags used and associated environmental benefits. The Government should therefore include paper bags in the charge.

Impact of re-using bags

28. The environmental impact of an individual carrier bag reduces if people reuse it many times. Figure 2 shows that some types of bag would need to be reused for shopping many times in order to avoid an emissions impact greater than that of a single-use bag. A reusable cotton bag, for example, would need to be reused over 130 times (equivalent to daily use for over 4 months) to have the same impact as a thin plastic bag used once. This would increase to 393 times if the plastic bag were used three times.

29. Using carrier bags for waste disposal, such as for lining bins, also reduces their environmental impact by displacing the need to purchase additional swing-bin and pedal-bin liners. As a result of the introduction of a carrier bag charge in Wales, WRAP observed an increase in purchases of these bin bags.[68] They estimated that 11 million more bin bags were sold in Wales in 2012 than there would have been had the carrier bag charge not been introduced. This equated to 80 tonnes of plastic; negating only 4% of the amount of material saved through the reduction in use of thin-gauge carrier bags.[69]

30. Defra consider that "the expected reduction in lightweight plastic bag usage, and anticipated trend towards re-usable bags, will minimise the impacts of the charge on consumers".[70]The Welsh Government told us that this was something that they had "looked at quite hard", but concluded that their scheme did not disproportionately affect those on low incomes, and added "if anything, it is possibly the opposite".[71]

31. Some have raised the potential for reusable bags to harbour dangerous bacteria that might cause food poisoning. Professor Hugh Pennington of University of Aberdeen has suggested that bacteria from raw meat or soil-covered vegetables could be transferred to the inside of a reusable bag and contaminate food.[72]The Welsh Government had sought advice from the Food Standards Agency and decided to exempt bags used for unwrapped foods. They told us that they had no evidence of any increased food poisoning as a result of the charge in Wales. Against that background, the Government's proposal to exempt bags used for unwrapped food is a sensible public health precaution.

32. 'Bags for life', thicker plastic bags designed to be durable enough to be used many times, will only be more environmentally sustainable if they are repeatedly reused. WRAP have collected evidence from Wales on the numbers of bags for life that were sold, using data from five retailers. Between 2010 and 2012, the number sold more than doubled, whereas those sold in the rest of the UK fell for those same retailers.[73] A study funded by the Welsh Government and Zero Waste Scotland found that whilst 79% of people in Wales say that they reuse a bag for life in supermarkets, only 51% actually do so. This is nevertheless nearly double the level observed in Scotland (28%), which currently does not have a charge.[74]

33. Some shoppers do not realise that they can return bags for life to be replaced, if they break. The Welsh Government and Zero Waste Scotland study observed over 9,000 consumer purchases in different shopping sites,[75] and found that:

Encouraging free replacement and recycling of bags for life at the end of their usable life reduces the cost to consumers, but more importantly could also help reinforce the habit of reuse. Retailers should clearly communicate to shoppers that they can obtain a free replacement at the end of the bag's useable life, so that the charge for bags for life this is a one-off cost. Supermarkets should ensure there are systems to recycle these bags.

34. Actual usage of more durable bags depends on people changing their habits to bring bags with them. A thin bag for life needs to be used four times as often as a single-use plastic bag used once, and thicker bags for life would need to be used 11 times as often (Figure 2). Ireland, recognising the need to incentivise this reuse has made plastic shopping bags designed for reuse exempt from its bag tax provided the retailer charges at least 70 cent (58p) for the bag—three times the charge for a standard bag.[77]

35. The Climate Change Act 2008 does not provide for a charge to be applied to multi-use bags. Analysis into consumer behaviour in Wales observed:

Overall, the increase (by weight) in bags for life purchased in Wales negated around 30% of the reduction in the weight of thin-gauge bags given out.[79] The Welsh Government is considering taking reserve powers to ensure that bags for life are priced higher.[80] The Government says that it would seek a voluntary agreement to charge higher prices for these bags in England:

However, evidence from Wales suggests that this is unlikely to be sufficient.

36. With the introduction of a charging scheme for single-use bags, the Government should be ready to introduce legislation to ensure that retailers sell 'bags for life' at an appropriate higher price than the charge for single-use bags, taking into account their greater emissions impact. The Government should set a minimum price for bags for life at a level which incentivises their reuse; perhaps a minimum of 10p for a thin and 20p for a thick bag for life that could subsequently be replaced for free if it breaks. The Government should ensure any additional proceeds of these charges also go to charity, with retailers allowed to recover the cost of such replacements.

Retailers

PROPOSED EXEMPTION FOR SMALL RETAILERS

37. The Government has proposed that only retailers with more than 250 employees would be covered by the mandatory charge. It is not consulting on this aspect of the scheme. The Government wants to "ensure that [small retailers] are not disproportionately burdened",[82] and cited a 3-year freeze on new regulation for businesses with fewer than 10 employees introduced in 2011.[83] Since provision for the charge was made in the Climate Change Act 2008, it is arguable that it is not a 'new' regulation—furthermore its proposed implementation in 2015 is beyond the timeframe of the 3-year regulatory freeze.

38. The evidence we received suggested that many small retailers oppose the exemption and would like to participate. The Minister told us that Defra had not received any submissions from retailers wanting to be excluded from the scheme.[84] National Federation of Retail Newsagents told us:

Association of Convenience Stores also wanted a wider coverage of retailers included in the scheme:

39. The Government's solution is to suggest that small businesses can choose to charge for bags if they wish.[87] British Retail Consortium called the exemption for companies employing less than 250 people "not logical, and will further confuse consumers with some smaller supermarkets having to charge and others being able to provide free polythene bags". They were concerned that franchise operations might be exempt, and that the charge could be applied differently to stores within the same group, which would be "confusing for customers and place some retailers at a competitive disadvantage based solely on their business model".[88] Campaign to Protect Rural England highlighted a rural dimension to the exemption for small businesses, which could potentially reduce the effectiveness of the charge in discouraging littering:

British Retail Consortium told us that small businesses would not be worse off under a mandatory charge if they were subject to lower reporting burdens, as was the case in Wales:

Marks and Spencer favoured replicating the Welsh charging model, where only retailers with more than 10 employees would be required to report statistics and cost and revenue data for the scheme.[91]

40. The Government's proposed exemption for small retailers is unnecessary, and risks adding undue complexity to the scheme, reducing its environmental impact and reduction in bag use. There is compelling evidence that small retailers want to be included in the mandatory scheme as a voluntary approach could be counter-productive. The Government should include small retailers in the scheme, but exempt those with 10 employees or fewer from detailed reporting requirements. As in Wales, all shops should be required to publicise in-store the proceeds and where the money raised is spent.

PROCEEDS AND ENFORCEMENT

41. The Climate Change Act 2008 enables the Government to require sellers of goods to charge for single-use plastic bags that they supply to their customers.[92] Defra proposes that Trading Standards Officers (TSOs) would be responsible for enforcing the charge, as they are in Wales and will be in Scotland, because "TSOs are already responsible for enforcing packaging requirements in England, so adding plastic bag enforcement would slipstream in with this current work".[93] The Government recognises that civil sanctions may be required, and is considering how they should be introduced.[94] We heard that in Wales "there have been no prosecutions, but there have been a number of trading standards warnings given, and a number of trading standards reports and inquiries into specific cases."[95] Keep Wales Tidy told us that only six businesses have been found to be in breach of the charge, and that this has been seen as an indication of the scheme's success.[96] For consumers to accept the charging scheme, public trust in it is vital so Trading Standards should undertake intelligence-based enforcement of the charge.

42. The Government expects that the charge will raise around £70 million for charity.[97] The Government's consultation stated that it "will not collect the proceeds of this charge in England, which will stay with the organisations collecting them. We will encourage these organisations to donate the profits to good causes".[98] The Government has no powers to force a retailer to give money from the bag charge to a particular organisation, but "expects that the retailers will act as they have done in the other countries of the UK and donate the proceeds to good causes".[99] Wales told us that they have reserve powers for directing payments, but have opted for a voluntary arrangement on where the funds should go.[100] Keep Wales Tidy told us that they "support the voluntary agreement and would like to see the whereabouts of the proceeds continuously monitored and publicised."[101]

43. Whilst we support the use of funds for good causes, such as environmental charities, we are concerned about potential abuse of the scheme. The Government should set clear rules for transparent reporting and for retailers to publicise prominently in store where the funds are going. It should ensure tough sanctions exist to prevent retailers having a conflict of interest about which charities are supported and ideally shoppers should decide which local charity the funds go to, as already happens in some stores. If there is evidence of retailers abusing this approach, the Government should follow the example of the landfill tax and plastic bag tax in the Republic of Ireland by centrally collecting and allocating funds for environmental projects.

44. The Climate Change Act 2008 enables the Government to require organisations to keep records relating to charges for single-use carrier bags, and to publish these. Administrative costs and VAT would be deducted from the money passed on to good causes. In Ireland, administration costs were relatively low, at around 3% of revenues, because reporting and collection was integrated into existing VAT reporting systems.[102] Defra told us that it expected retailers' administration costs to be "about £6 million" (over 6%), "leaving a VAT take of about £19 million".[103]

45. Research shows that a majority in England (81%) is willing to pay a 5p charge if the money goes to charity.[104] This is in line with our conclusions in our 2011 report on Environmental Taxes, that taxpayers are significantly more likely to accept green taxes if they are clearly set up to support environmental aims rather than as a vehicle for raising money for the Treasury.[105] Under current proposals the Treasury intends to take VAT from the proceeds from the bag charge (just under 1p of the 5p), which would otherwise go to charity. The estimated £19 million raised in VAT should be spent on new environmental programmes and to cover the costs of monitoring the effectiveness of the scheme. This would help reinforce the wider environmental objectives of the charge and maintain public support.

Wider environmental benefits

46. Research suggests that a majority of people in England (54%) support the introduction of a charge. Dr Poortinga told us he believed that it will become more popular after its introduction because support for the carrier bag charge in Wales increased from 59% before it was implemented to 70% afterwards. He noted that similar positive attitudinal changes have been observed for other environmental and behavioural change policies.[106]

47. Research suggests that a proportion of people consistently over-state their pro-environmental behaviours (a gap between stated intention and observed actions).[107] There is evidence that the charge could help close this gap. 10% of shoppers in Wales told researchers that they take new single-use bags from shops; observations showed that in reality around 15% do so. This divergence was considerably less than in Scotland (25% and 66%), which does not yet have a charge.

48. Keep Britain Tidy told us that a charge could help stimulate good environmental behaviour more generally on waste prevention and reuse.[108] In Wales, more people reported that the charge was an effective way to reduce waste and litter after the introduction of the scheme,[109] and research showed that the charge in Wales "may be a factor in increasing pro-environmental awareness and behaviours".[110] Professor Richard Thompson told us "I believe a considerable number of consumers are keen to do the right thing, but are confused as to what the right thing is",[111] which reinforces the need for the Government to ensure its approach is simple, easy to follow and consistent.

49. As we discussed in Part 1, the proposed charge could help reduce levels of littering. Economic psychology suggests that charging can lead some people to justify negative social behaviours if they feel they are paying for a service.[112] It is sensible not to directly link the proceeds of the charge to fund litter collection, as it might lead some to justify littering. However, giving bags a value should incentivise their reuse, and reduce the numbers disposed of thoughtlessly. More research is needed into how people respond to the charge including the impact on littering and recycling. The Government should ensure that retailers collect and submit data on bag reuse, and monitor how the charge affects wider behaviours to ensure the scheme has as significant an environmental impact as possible.

42 Q111 [David Newman] Back

43 Q111 [Professor Thompson] Back

44 Poortinga, W, Whitmarsh, L. Suffolk, C. (2013) 'The introduction of a single-use carrier bag charge in Wales: Attitude change and behavioural spillover effects'. Journal of Environmental Psychology 36: 240-247 Back

45 Q3 Back

46 Dr Wouter Poortinga (BAG 001), para 18 Back

47 Dr Wouter Poortinga (BAG 001, para 17 Back

48 Q35 Back

49 For instance, in March 2010 the Cabinet Office and Institute for Government published Mindspace: Influencing behaviour through public policy, which discusses the scope for using behavioural sciences in policy-making. This discusses the importance of simplicity as part of 'salient' messages to encourage behaviour change. It also identifies that changing the 'default' option, and ensuring consistent messaging are also important. Cass Sunstein, whose book 'Nudge' (Penguin, 2009) with Richard Thaler inspired a lot of the work of the government's behavioural insights work, has recently written a book 'Simpler: The Future of Government' (Simon and Schuster, 2013) in which he makes the case that complexity is costly and potentially harmful. Back

50 Q13 Back

51 British Retail Consortium (BAG 028), para 2.1 Back

52 Q39 [Neil Sinden]; Waitrose (BAG 027), para 7.2 Back

53 Q11 Back