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%