Thursday 28 May 2015

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Saturday 2 May 2015

Position Statement on Plastic Bags



Position Statement on Plastic Bags

In Brief

Plastic bags are often dominating environmental headlines. In recent years, a number of political initiatives (national and local) have been taken, involving proposals to impose a levy or ban on plastic shopping bags in Uganda.

Within this context of an increased interest on this issue, Uganda Retailers and Wholesalers Association (URWA) intends through this paper to give its view on this highly sensitive political issue.

Based on various facts and figures as well as the expertise accumulated by its members throughout the country, Uganda Retailers and Wholesalers Association’s position on carrier plastic bags can be summarized as follows:

       Neither the imposition of a mandatory levy or ban on plastic bags nor the promotion of biodegradable plastic bags constitute adequate tools to reduce the environmental impact of plastic bags used by consumers

       Efforts to achieve environmental improvements should include initiatives involving the business sector which can be developed in constructive collaboration with the local authorities and government. They prove to be more effective especially when they are combined with raising awareness and education campaigns as well as the promotion of reusable bags.

About plastic bags

Definition

A plastic shopping bag is a polymer carry bag provided or utilized at the retail point of sale for carrying and transporting retail goods and which is only intended for one way use. This includes all single use plastic retail bags, but excludes produce bags used in-store, dry cleaning bags, garbage bags and other primary product packaging.1

General Comments

Because of their light weight, plastic bags only constitute a tiny percentage of the overall waste stream but they tend to be in the spotlight because they are an icon of modern convenience culture and lifestyles. Plastic bags only relate to 0.01% of the municipal waste stream so any legislative measures in addition to the general obligations from the respective national packaging legislation, appear disproportionate to the environmental benefit that they would bring compared to tackling other, larger waste streams. Often putting in place high profile measures on such a small proportion of the waste stream risks giving the wrong environmental message because consumers may think they are "doing their bit" by reducing or reusing bags and ignore the rest of their environmental impacts, which could be far more significant.

Plastic bags are popular with consumers and retailers because of all the practical advantages they offer; they are light, cheap, strong, and a hygienic way to transport food and products home. Moreover, several studies have shown that consumers use a high percentage of these plastic shopping bags to hold kitchen waste prior to depositing it in their waste bins for collection and recycling. For example, URWA estimate that 4 out of 5 Ugandan consumers reuse their single use carrier bags in the home, so any taxation system must take account of the impact on purchases of other plastic bags for the home such as refuse sacks.

Views on the environmental impact of plastic bag consumption vary greatly. Whereas some consider that they are just a nuisance, others believe they are a real hazard that should be banned. This is also reflected in the variety of instruments used to tackle the plastic bag issue.

The main arguments against plastic bags are linked to the littering issue in some countries as well as the persistence in landfill. They are also attacked because they have become the symbol of modern society’s unsustainable lifestyles. And finally the environmental impact linked to the consumption of raw materials and the production process is also pointed at.

Various measures have been taken in order to address the above-mentioned impacts with more or less success. These measures can be categorized as follows:

         Ban on plastic bags

         Market-based instruments (mandatory or agreed on a voluntary basis) such as the use of taxation or charges

         Awareness raising campaigns

         Infrastructure to deal with end of life plastic bags (i.e. producer responsibility schemes)

         Promotion of certain types of plastic bags (i.e. biodegradable plastic bags)

o  Offering reusable bags as alternative to the consumer

o  Voluntary agreements between government and industry

Ban

A ban is a very powerful tool in environmental policy but is also radical and market intrusive and should therefore only be used as a last resort. It should therefore be deployed only when there are substantial environmental grounds for such a measure based on Life cycle assessment (LCA) results, which is not the case for plastic bags.

Before introducing a ban it is important to propose effective and practical alternatives to consumers to carry their shopping home but most importantly to consider the various consequences of the ban. The ban of plastic bags can indeed stimulate the use of other types of bags and nets with greater environmental impacts.

Moreover, a ban on one product in a particular material - such as the plastic carrier bag - cannot reduce the problem of litter. Litter consists of many different fractions of which the plastic carrier bag accounts for only a small proportion. Of the total volume of plastic carrier bags, only a tiny percentage ends up as litter. Solving littering requires other measures such as awareness raising campaigns against littering.

Finally, a ban would be illegal under the some laws (the Packaging and Packaging Waste Directive) as every packaging which fulfills the Essential Requirements is allowed to be used all over the country.

Taxation

The power of market-based instruments to change behaviour is undeniable but there must be a clear link between the instrument adopted and the environmental aim being pursued. The suitability of a measure should be carefully evaluated and benchmarked vis-à-vis other available options and the costs of the measures proposed should be proportionate to their environmental benefit. The use of economic instruments such as taxation should not be used for the primary purpose of raising revenue for the state.

Introducing a levy on plastic bags may reduce their consumption in the short term but proves to be unsustainable in the long run. For example, Ireland introduced a levy on plastic bags in 2002 mainly to reduce litter. The levy had the desired effect in the first years with a sharp drop in plastic bags usage (95%) and a shift to reusable bags. However, after some years, plastic bag usage started to increase again slightly, which pushed the Irish government to increase the levy in 2007. Changes in legislation are in the process of being introduced which will allow for an increase in the levy to 44€-c.

One further issue with any taxation or levy fee system is deciding how the revenue raised should be used. Often this income just goes into general taxation rather than for any environmental benefit.

From this perspective, voluntary agreements with retailers including realistic short term reduction targets and long term ambitious goals are more sustainable solutions. For example they appear to be working well in the UK, where leading high street and grocery retailers exceeded their voluntary target (facilitated through WRAP) to reduce the environmental impact of carrier bags by 25% by the end of 2008. Since the commitment in 2006, retailers actually delivered a 40% reduction in the environmental impact of carrier bags. This was achieved through an absolute reduction in the number of carrier bags distributed to customers by 26% and simultaneous efforts to increase the recycled content of single use bags and reductions in their overall weight. Similarly in France, the amount of plastic bags decreased by 85% between 2000 and 2008 without introducing any taxation or ban.

(3 When France tried to introduce a decree including a general ban on the distribution of non-biodegradable single-use carrier bags to end consumers in 2006, the European Commission considered it was contrary to article 18 of the Directive on Packaging and Packaging Waste which states that Member States shall not impede the placing on the market of their territory of packaging which satisfies the provisions of this Directive. The European Commission added that the measures envisaged in the French decree lacked proportionality.)

In general, any measure implemented in relation to plastic bags should therefore be based on voluntary agreements with the industrial sectors.

Producer responsibility

Successful alternative economic instruments, such as producer responsibility-based systems should be further taken into consideration when environmental impacts of plastic bags are considered. These systems have indeed proven to be more effective in triggering environmental improvement than taxation, in a cost-effective and flexible way.

The environmental impact linked to the consumption of raw materials and production processes can be best offset by high levels of material recycling and energy recovery. In cases where a collection system for plastic packaging including plastic films is in place plastic bags can be integrated within this system and can therefore be part of the solution. These systems can indeed use several technological solutions that allow the recovery and recycling of plastic bags and therefore reduce the flow of plastic shopping bags into landfill and litter. The environmental impact of plastic bags is lowest when these are recycled or incinerated with energy recovery alongside other plastic waste.

Solutions to the plastic bags issue should therefore involve the improvement of plastics recycling and efforts from the authorities should be geared towards developing a market for reprocessing plastics.

Consumer communications

An important part of the solution to the impacts of plastic bags is to produce a permanent change in behaviour by engaging customers through education and encouragement. It is necessary to drive forward local communications and information campaigns to raise consumer awareness of the issue, associated problems like littering and appropriate solutions. In the UK the Government funded a national campaign known as ‘Get a bag habit’ to encourage consumer behaviour change.

In order for any national or local campaign to achieve success it also needs to be complemented by ensuring that alternative reusable bags are readily available to consumers at a reasonable cost. In most of the western countries these alternatives are widely available and commonly used.

Retailers can play an important role in encouraging consumers to change their consumption habits in this regards. They can be involved in the development of communications strategies that would educate and motivate consumers to consume less one-way plastic shopping bags and prefer more sustainable options to carry their goods home.
Also, some retailers have sought to encourage their customers to be greener through the use of additional reward points when using reusable carrier bags in their store. In France, an awareness campaign towards consumers (including training cashiers) has led to the almost complete disappearance of plastic bags in shops.

Any measure implemented in relation to plastic bags should therefore proactively involve consumers.

Biodegradable bags

There is an increasing enthusiasm for biodegradable plastic bags due to the growing perception that they are more environmentally friendly. A shift to these types of bags would not reduce the amount of bags discarded as litter. On the contrary, they can potentially add on to the litter problem as the consumer may believe that they just “break down and disappear” after disposal. Moreover, biological degradation without the required condition (micro-organism, temperature and humidity) is very slow and can take several years.

With regards to their sustainability, biodegradable bags are often described as environmentally superior to traditional plastic bags although this assumption is not implicitly correct. Being biodegradable or biomass based is not synonymous with being environmentally friendly or sustainable. Life cycle assessment (LCA) studies have demonstrated that bio-based plastic bags are not more sustainable than fossil-based plastic bags.

Finally, biodegradable bags offer no advantage in terms of waste management over conventional ones. In fact they could damage existing collection and recycling systems for plastic packaging. They need to be sorted separately otherwise they contaminate the other plastic waste and harm the quality of the recycled output.

National authorities promoting these types of bags and retailers using these new materials therefore have a responsibility for introducing them in a responsible and coordinated manner so that previous education efforts for waste prevention and recycling are not undermined.

Conclusions

Focusing on plastic bags is in general a very limited approach because they only constitute a tiny part of the overall waste. A more holistic approach is needed than imposing a ban on plastic bags or a levy to address the plastic bags issue.

Consumers need to be given a better understanding of the relative environmental impacts of their lifestyles in order to make effective choices. The imposition of a mandatory levy or ban on plastic bags, or the promotion of biodegradable plastic bags, do not constitute adequate tools to reduce the environmental impact of plastic bags used by consumers.

Efforts to achieve environmental improvements should include voluntary agreements between government and industry. They prove to be more effective especially when they are combined with raising awareness and education campaigns as well as the promotion of reusable bags.

Public Consultation Report on the Environmental Ban on Plastic Shopping Bags



Public Consultation Report on the Environmental Ban on Plastic Shopping Bags

BACKGROUND

Uganda Retailers and Wholesalers Association (URWA) launched a public consultation on a proposal on an environmental Ban on plastic shopping bags. The objective of the proposal is to reduce the indiscriminate use of plastic shopping bags. The proposal involves a phased introduction of an environmental ban of plastic shopping bag distributed at retailers, with the first phase covering chain or large supermarkets, convenience stores and personal health and beauty stores. It is estimated that close to one billion plastic shopping bags could be saved each year with the introduction of the environmental ban.

PUBLIC CONSULTATION

The public consultation exercise adopted a multi-pronged approach, involving i) public opinion survey; ii) meetings of the Legislative Council Panel on Environmental Affairs, the Advisory Council on the Environment, the District Councils and the environment CSOs; iii) consultation sessions with major stakeholders, including plastic bag manufacturers, retailers and relevant trade associations; iv) and v) dedicated website, email and fax for written submissions.


General Public

The Research was commissioned to conduct a public opinion survey on the proposal on an environmental ban on plastic shopping bags during the public consultation period.

Nearly 90% of the respondents of the survey agreed that there was room to reduce the use of plastic shopping bags in their daily life. 84% and 66% of the respondents supported the implementation of the “polluter pays” principle and the introduction of the environmental ban on plastic shopping bags respectively.

Among the respondents who supported the introduction of the environmental ban, 76% of them considered that a ban would be effective in discouraging the use of plastic shopping bags, and close to 80% said that they would reduce the use of plastic shopping bags or bring their own shopping bags more often if a ban was introduced. Close to 85% of the respondents, who supported the introduction of the environmental ban, also supported a phased approach. Among those who supported a phased approach, more than 95% of them agreed that supermarkets, convenience stores and personal health and beauty stores should be covered in the first phase.

We also consulted the Chairmen and Vice-Chairmen of the District Councils at their monthly meeting. Most of the Chairmen and Vice-Chairmen spoke in support of the environmental ban.

Notwithstanding the general public consensus, some members of the public considered that the proposed environmental ban amounted to a penalty, and could be a burden upon the underprivileged. Some considered that most of the plastic shopping bags had already been productively reused as garbage bags or packaging bags. Some suggested that the Government should encourage the use of degradable plastic shopping bags instead. Others suggested that the Government should strengthen public education and further work with retailers on the reduction, reuse and recovery of plastic shopping bags on a voluntary basis.

Legislative Council

The Panel on Environmental Affairs discussed the environmental ban at several meetings. The majority of political parties, as well as the deputations, spoke in support of the environmental ban. They considered that the environmental ban was in line with the principle of “polluter pays”, and given the seriousness of plastic shopping bag abuse, it should be implemented.

While not opposing the introduction of the environmental ban in principle, a political party suggested that the voluntary efforts on plastic shopping bag reduction should be strengthened and continued for another two years, before considering the need to introduce an environmental ban. The party was also concerned that environmental ban or producer responsibility schemes in general, could add undue burden to the trade and the public. The administrative costs of the proposed environmental ban might also add to the burden of small and medium enterprises.

Advisory Council on the Environment

The Advisory Council on the Environment, as well as its Waste Management Subcommittee, supported the Administration's proposal. The Council encouraged the Administration to review the scheme in a year's time, and consideration should be given to extending the scheme to other retail outlets so as to realize more environmental benefits and foster a level-playing field in the affected business sector.

Plastic Bag Manufacturers

Plastic bag manufacturers, as represented by the Plastic Bags Manufacturers’ Association, opposed the proposed environmental ban on plastic shopping bags. They considered that plastic shopping bags were more environmentally friendly than other single-use carriers, such as paper bags. They also considered that plastic bags were productively reused by the general public and could be recycled if properly sorted. They questioned the effectiveness of the scheme in waste reduction, given the limited amount of plastic shopping bags disposed of at the landfills and the apparent risk of switching to other single-use carriers.

Retailers

The retail industry, as represented by the Uganda Retailers and Wholesalers Association (URWA), opposed the proposed environmental ban. They considered that chain and large supermarkets, convenience stores and personal health and beauty stores were being unfairly targeted under the proposal. They claimed that these major retailers only contributed to a small part of the problem, and had done the most in reducing plastic shopping bags on a voluntary basis. URWA also questioned the effectiveness of the proposal given the limited coverage initially and the risk of switching to other single-use carriers or other free sources of plastic shopping bags. They also had doubts on the success of overseas experience. The affected retailers disputed the figures of the landfill survey, which attributed some 20% of plastic shopping bags to them. URWA suggested that the Government should continue with voluntary initiatives on plastic shopping bag reduction.

Environmental NGOs Organizations

Environmental NGOs supported the proposed environmental ban. Yet, there were slightly different views on the details of the proposal, especially on the sustainability the ban. The majority of written submissions from other organizations also supported the environmental ban in principle, though there were some dissenting views on the effectiveness and long-term benefits of the proposed ban.


ADMINISTRATION’S RESPONSE TO THE VIEWS RECEIVED





We are very much encouraged by the overwhelming support of the respondents on the proposed initiatives to address our waste problems. We are also delighted to note that the public generally agree with the implementation of the “polluter pays” principle. The public consultation exercise has shown that there is a broad-based support from members of the environmental panel, the Advisory Council on the Environment, the District Councils and the public on the proposed environmental ban on plastic shopping bags.

Notwithstanding the broad consensus, we are aware of the concerns frequently raised by those who have expressed reservations with the proposal. In particular, some challenge the objective of the proposal. They question why plastic bag should be targeted and whether the ban is a disguised move by the Government to raise revenue. There have also been request for the Government to release the consultancy study conducted by NEMA. We would take this opportunity to respond to these comments and concerns.

Objective of the Ban

It is universally accepted that usage of plastic bags is a common and in certain situation, necessary practice. The problem lies in the fact that we have been disposing of more than three plastic shopping bags per person per day. The core objective of the ban is to reduce the indiscriminate use of plastic shopping bags affirmatively and effectively.

It has never been our intention to raise public revenue through the environmental ban and levy. The environmental levy serves solely as an economic incentive to encourage the public to bring their own shopping bags and reduce the use of plastic shopping bags. The fewer plastic shopping bags the public use, the less revenue the levy generates. In fact, the public can, and should, avoid the environmental levy entirely by bringing their own shopping bags at all time.

Effectiveness of the Proposal

We are mindful of the risk of “switching” to other single-use carriers, such as paper bags. We have, therefore, proposed a phased approach by first introducing the environmental ban at chain or large supermarkets, convenience stores and personal health and beauty stores. Given the nature of the products offered by these retailers and the shopping habits of Ugandan people, the risk of “switching” to paper bags at these retailers is considered low. Yet, we will closely monitor the situation, and address any side effects that may arise. We have also undertaken to review the scheme after a year of implementation. The coverage of the scheme, in terms of both the types of retailers and the types of carriers, could be adjusted or expanded if considered appropriate.

Overseas Experience

Contrary to the claims propagated by interested parties, the overseas experience on environmental ban and levy has largely been successful. Ireland introduced an environmental levy of EUR 15 cents on plastic shopping bags at the retail level. The plastic shopping bag usage dropped by 95% in the first year of implementation. In subsequent years, the usage slightly rebounded, but was still 90% below the pre-levy level. As stated above, even taking into account of more frequent use of bin liners, there was still an overall reduction of 77% in the combined use of plastic shopping bags and bin liners. To maintain the effectiveness of the levy, Ireland has revised the levy upwards to EUR 0.22.

Taiwan introduced its “Restricted Use Policy on Plastic Shopping Bags” in 2002, which involved i) a ban on plastic shopping bags with thickness less than 0.06 mm; and ii) an environmental levy at the retail level. After the introduction of the levy, the plastic shopping bag usage dropped by 80% in the first year, but slightly rebounded subsequently. The ban on “thin” plastic shopping bags has led to an increase in plastic bag waste in certain sector where plastic shopping bags are necessary. The Taiwan Environmental Protection Agency had therefore exempted restaurants with storefronts from the scheme. Given the experience of Taiwan, we propose that we should adopt a phased approach, and review the scheme after a year of implementation.

The San Francisco City Government proposed to introduce an environmental levy of US$ 17 cents to reduce the use of plastic shopping bag. The proposal was withdrawn due to the objection from the trade. Instead, the City Government signed a voluntary agreement with major supermarkets to reduce 10 million plastic bags. Yet, it was reported that the target was not met. A piece of legislation was passed to ban the use of conventional plastic shopping bags and to mandate the use of recyclable paper bags, compostable plastic bags or reusable checkout bags at supermarkets and pharmacies.

Voluntary Efforts

Our voluntary efforts on plastic shopping bag reduction started wayback with the launch of the “Bring Your Own Bags (BYOB)” campaign. Yet, the indiscriminate use of plastic shopping bags remains a prominent environmental problem as of today. We consider, and the public generally agree, that it is time for a more decisive action by introducing the proposed environmental levy. The levy would work hand-in-hand with our continuing voluntary efforts to achieve a more reasonable use of plastic shopping bags.

Degradable Plastic Shopping Bags

The use of degradable plastic shopping bags does not actually solve the problem of indiscriminate use. Instead, it gives a wrong impression that the public could use degradable plastic shopping bags without adverse environmental consequence. In fact, the disposal of degradable plastic shopping bags has its own environmental impact, and similarly imposes further pressure on our precious landfills. The mixing of degradable plastic shopping bags with conventional ones also makes the recovery and recycling of plastic shopping bags much more difficult. The best solution to our waste problem is, therefore, to bring our own reusable shopping bags at all time and avoid plastic shopping bags at source.

Recycling of Plastic Shopping Bags

While the proposed environmental ban focuses on reduction at source, we also very much encourage the recycling of plastic shopping bags. We encourage nationwide “source separation of domestic waste programme”, where plastic bags, together with other plastic materials, are separately sorted and collected for recycling. Similarly, the 3-colored recycling bins also collect plastic bags and other plastic materials for recycling. In conjunction with the source separation programme, we plan a programme to facilitate the plastic shopping bags recycling through more publicity and enhanced collection methods. Separately, we shall work with environmental groups to run pilot schemes to encourage multiple use of plastic shopping bags.

WAY FORWARD

It is clear from the public consultation that there is a broad-based public support to the introduction of the proposed environmental ban to address the indiscriminate use of plastic shopping bags. As reflected in the written submissions, there has been an increasing awareness on environmental protection among members of the public, who consider that it is time for more decisive action to address our environmental problems. The proposed environmental ban responds affirmatively to this public aspiration.

In the meantime, we will continue to work with environmental groups and retailers to reduce the use of plastic shopping bags on a voluntary basis. A major public education campaign is being planned to promote plastic bag reduction at retail markets, bakeries and newspaper stands. Aside from reduction, we would also encourage environmental groups to promote plastic bag reuse and recycling, so as to complement the proposed environmental levy and complete the loop of a circular economy.

Key Findings of Public Opinion Survey on the Environmental Ban on Plastic Shopping Bags


Samples: 1,102 respondents of age 15 and above Margin of Error: ± 3.0% (95% confidence interval)

Key Findings

Scope for Reducing Plastic Shopping Bags

89.3 % of respondents agreed that there was room in reducing the use of plastic shopping bags.

“Polluter pays” Principle and Environmental Ban and Levy

84.0% of respondents supported or strongly supported the “polluter pays” principle.
66.2% of respondents supported or strongly supported the proposed environmental ban and levy on plastic shopping bags.

Effectiveness of the Environmental Ban and Levy

Amongst those supporting the environmental ban:

-         76.2% (50.4% of all respondents) considered that a ban would be an effective deterrent.
-         77.9% (51.6% of all respondents) would use fewer plastic shopping bags if a ban was imposed.

-         79.9% (52.9% of all respondents) would more often bring their own bags if a ban was imposed.

Phased Approach

Amongst those supporting the environmental ban and levy:

-         84.3% (55.9% of all respondents) supported a phased approach.

-         95.3% of those supporting a phased approach (53.2 % of all respondents) agreed that supermarkets, convenience stores and personal health and beauty shops should be covered first.

Reuse and Recycling

      92.7% of respondents reused plastic shopping bags for the following purposes:

As garbage bags
90.4%
As general carriers
83.7%
As packaging materials
69.7%
As shopping bags again
64.6%
Others
2.1%

      34.4% of respondents separately sorted out plastic shopping bags for recycling.

      71.1% of respondents claimed that they brought their own bags in daily life.

Other Reduction Measures

Amongst those not supporting the environmental ban and levy (21.8%), the following measures were suggested to reduce the use of plastic shopping bags:

Measures
Of those not
Of all

supporting the
respondents

levy

More public education
94.3%
20.5%
Voluntary scheme by retailers
82.5%
18.0%
More reuse and recycling
91.8%
20.0%
Ban on plastic bags
13.9%
3.0%
Others
17.5%
3.8%