Written evidence submitted by The Industry Council for Research on Packaging and the Environment (INCPEN)

INCPEN is a research body established in 1974 to consider the environmental and social impacts of packaging. INCPEN members represent all stages of the supply chain.

Summary: It is INCPEN’s view that the proposed charge on carrier bags in England will have no beneficial impact on the environment. Worse, the proposed exemption for biodegradable bags will result in the closure of UK plastics reprocessing with consequent job losses.  It will also give a very confusing message to consumers.

It will not reduce litter or save resources and will impact disproportionately on poorer people who have to use public transport and will still need bags to take their shopping home.

Introducing a bag levy for no other reason than to address what some have described as ‘an iconic symbol of our consumer society’ is unjustified and ill advised. If that were a valid reason for a levy then one should presumably be applied to all other symbols such as mobile phones and trainers.

 

  1. When first proposed the bag levy was claimed as a litter reduction measure, but in reality carrier bags are not a significant part of litter accounting for 0.03% (source Keep Britain Tidy litter count 2008).

 

  1. In 2010, eight years after the introduction of a levy on plastic carrier bags in Ireland, bags of all kinds (not just thin plastic ones) constituted just 0.25% of litter (compared to 0.22% in 2002) according to the Irish Litter Monitoring Body.

 

  1. There is no evidence that the antisocial practice of dropping litter is impacted by such a levy and there is no correlation between the number of bags used and the number that get littered.

 

  1. An exemption for biodegradable bags will have a number of negative impacts. If gives a misleading, confusing message to the public.  Whether a material degrades or not is not relevant to its environmental impact – paper degrades, glass is inert; neither is better than the other.

    Large amounts of regular plastics carrier bags are currently recycled to make polythene film.
    It will not be possible to keep used biodegradable or oxo-degradable separate from regular plastic bags.  Even a very small amount contaminates the regular plastic and means it cannot be recycled because quality of the finished product would be jeopardised. 

 

  1. This will bring an end to UK reprocessing of plastics bags, further reducing the decline in UK manufacturing and resulting in UK job losses. 

 

  1. Biodegradable, compostable bags are typically as much as 7 times more expensive than regular thin plastic bags.  Oxo-degradable bags are closer in price to regular ones so it is inevitable that manufacturers will switch to oxo-degradable bags.

    These bags, in common with all regular plastic bags, will be manufactured in the Far East.  All bag manufacture moved to the Far East over 10 years ago because raw material and manufacturing costs are much cheaper than European. The oxo-degradable additive is produced in the USA. 
     
  2. There is not likely to be any reduction in the amount of plastic film produced as a result of a levy.  To the contrary, it is likely that greater volumes of heavier plastic film will be used to manufacture heavier ‘Bags for Life’. More tailor-made bin liner bags and bags for other purposes will be purchased by people who currently re-use traditional bags for these purposes. 

    In 2011 the UK Environment Agency carried out a major study of supermarket carrier bags Life cycle assessment of supermarket carrier bags: a review of the bags available in 2006 that concluded a thin plastic bag does least damage to the environment of any carrier bag and is an environmentally responsible way for consumers to carry their groceries home. 

 

  1. The EA study found that natural-fibre bags made from cotton would have to be used more than 131 times in order to have the same low impact. Paper bags would have to be reused 3 times to match the performance of thin plastic.

 

  1. The levy on plastic carrier bags in Ireland has had a net negative environmental effect.  It resulted in more lorries on the roads (to deliver heavier alternative types of bags to shops) and more plastic being used as sales of tailor-made bags for bin liners and other purposes replaced the carriers. Statistics published by HM Customs and Excise show the amount of all types of plastic bags and sacks used in Ireland in 2001 (before the levy) was 29.8 thousand tonnes and in 2006 it had increased to 31.6 thousand tonnes.

 

  1. The restriction on carrier bags is not justified on environmental grounds, given that the EA study found that it was the least bad option. Trying to compare the ‘advantages’ and ‘disadvantages’ of the proposed levy is meaningless, and suggesting as an alternative a complete ban on lightweight carrier bags is clearly environmentally negative and disproportionately hard on the poor. 

 

  1. It makes no sense to compare bag levies and bans introduced in other countries, such as Bangladesh, where plastics of all types can block drains and river courses. Those countries lack the UK’s efficient waste collection and disposal services. The best solution in such countries is not to ban one type of material but to introduce western-style waste management practices.

 

  1. Nor does it make any sense to impose additional costs on families already struggling in the tough economic climate. They will still need to get their shopping home, wrap used nappies and other smelly waste before disposal, line rubbish bins etc.

    Instead of reusing free thin bags  - which 80% of households do according to a DEFRA/WRAP study conducted by IPSOS MORI in 2007 - they will now have to buy new bags specifically for these tasks.

 

  1. It also seems unfair to place the burden of administering a levy scheme on local authorities which are already hard-pressed.

 

  1. There is a very easy way to reduce the environmental impact, small though it is, of getting shopping home. Consumers simply need to take their own bags and keep reusing them either for shopping again, bin liners or other purposes.  If they need more bags then shops, as they do now, can make a range available.  Shop staff can help by asking customers if they really need a bag or can add their shopping to a bag they already have. This would have no administrative and enforcement costs and was enable consumers to choose the least harmful environmental option.

 

INCPEN would welcome the opportunity to supplement this with oral evidence.

 

8 December 2013