Committee Clerk
David Lonsdale
Environment and Sustainability Committee
Environment Policy Adviser
National Assembly for Wales
Welsh Retail Consortium
Cardiff Bay CF99
1NA
Suite 103
209 City Road
Cardiff CF24 3JD
SeneddEnv@Assembly.Wales
david.lonsdale@brc.org.uk
Inquiry into the general principles of the Environment (Wales)
Bill – Evidence from the Welsh Retail Consortium
(WRC)
1
Introduction
1.1
The Welsh Retail Consortium (WRC) is the
authoritative voice of the retail industry in Wales, from
independents to large multiples.
1.2
The WRC leads the industry and works with its members
to shape debates and influence issues and opportunities that will
help make that positive difference. We care about the
careers of people who work in our industry, the
communities retail touches and competitiveness as a fundamental principle of the industry’s
success – our 3Cs.
1.3
Our members have been at the forefront of initiatives
to improve resource efficiency and reduce waste, as demonstrated
through the A Better Retailing Climate initiative. In
January 2013 our sister organisation the British Retail Consortium
(BRC) published a
comprehensive report detailing progress across a range of issues including
reducing waste and packaging and helping consumers make more
sustainable choices. This document also contained a new set
of targets and commitments to 2020 agreed by retail signatories.
A
2014 progress update was published in January 2015.
2
Executive summary
2.1
This submission focuses on the proposals in part 3 of
the Bill regarding carrier bags and makes the following key
points
·
The Welsh levy for single use carrier bags is a success and
has dramatically reduced single use carrier bag usage.
·
The purpose of the original charge and regulations was to
create a small behavioural nudge in the right direction
commensurate with the relatively low impact of carrier
bags. The relatively small scale of impact of carrier bags
does not warrant aggressive legislation.
·
Extending the levy to reusable bags is counter intuitive and
indeed could drive customers back to using single use
bags.
·
Increasing and extending the levy jeopardises public goodwill
towards this initiative and is likely to cause
confusion.
·
If
implemented, there will be a considerable cost to our
members.
·
The Northern Ireland experience suggests that there is no
environmental benefit from extending the charge to reusable
bags.
3
Success of the Welsh levy for single use carrier
bags
3.1
Given the success of Welsh single use carrier bag
charge in terms of public support and environmental impact, there
is no reason in our opinion to extend the levy to plastic reusable
bags for life. We do not believe that extending the carrier bag
charge will add anything to the existing regulations in improving
the environment. In fact, rather than encouraging customers to
reuse bags they might just revert to purchasing single use bags,
reversing the progress made in Wales.
3.2
One of our supermarket members reports a reduction of
over 90% in single use carrier bags in its stores in Wales.
This reduction has been accompanied by an increase in sales of all
reusable bags as customers adjust to the levy. Additionally,
this retailer reports that at times when customers forget their
bags, or purchase more than the bags they have can hold, an
inexpensive reusable bag is their usual preferred
option.
3.3
It is important to remember that the purpose of the
original charge and regulations was to create a small behavioural
nudge in the right direction commensurate with the relatively low
impact of carrier bags. The relatively small scale of impact
of carrier bags does not warrant aggressive
legislation.
4
Extending the levy to reusable bags is counter
intuitive
4.1
We welcome the fact that the Welsh Government intends
to continue to monitor the amount of reusable plastic carrier bags
distributed in Wales and would not use the proposed extended
enabling powers unless the sale of reusable bags continues to rise
and outstrip sales growth. However we do not believe that a
mandatory charge on low cost reusable plastic bags is appropriate
as it will penalise customers for doing the right thing and being
environmentally conscious.
4.2
Re-using bags is a totemic environmental behaviour
and the extension of this principle to other areas would make a big
difference in sustainable consumption. Extending the levy to
reusable bags is counter-intuitive for our customers who are being
encouraged to switch to reusable bags.
4.3
There is no evidence available to suggest that
extending the levy will have any further environmental
impact. In fact, extending the levy to reusable bags may have
the following unintended consequences:
·
Encouraging consumers to revert to purchasing single use
bags – which calls into question the purpose of the initial
single use carrier bag levy and its success to date in reducing the
number of single use bags distributed. Some retailers have
removed single use carrier bags from their stores and, in order to
remain competitive against their competitors in terms of being able
to provide a low cost bag option, would consider reintroducing them
if the 5 pence charge is extended to low cost reusable
bags.
·
Forcing customers to purchase more expensive and more durable
reusable bags. While reuse of these more durable bags is a positive
behaviour, it is worth nothing that they need to be used far more
than a low cost reusable bag in order to offset their carbon
footprint. An Environment Agency study found that while
conventional, lightweight carrier bags made from high-density
polyethylene (HDPE have the lowest carbon footprint of any type of
bag; a reusable carrier bag made from low-density polyethylene
(LDPE) has to be used at least 4 times to have less environmental
impact. In contrast, a heavier more durable bag, made from
non-woven polypropylene (PP) and a cotton bag would have to be used
at least 11 and 131 times respectively[1].
4.4
If a charge for low cost reusable bags is introduced,
it will have a greater impact on impulse shopping, which is more
likely to take place in small and independent retailers and in
local communities. It is also likely to have a greater impact on
lower income families who are less receptive to environmental
initiatives and more likely to make more frequent, smaller
purchases.
5
Costs to retailers
5.1
If the carrier bag levy was to be extended reusable
bags, introducing it would come at considerable cost to our
members’ businesses, for example in terms of IT and unique
bag bar-coding for Welsh stores.
6
Experience in Northern Ireland
6.1
One member states that it currently goes beyond the
requirements of the carrier bag charge in Wales and donates the
proceeds of its bag for life (low cost reusable bags) scheme and
its range of reusable bags to good causes. However, this is not the
same as donating 5p from each bag for life because they are more
expensive to source and replace. When the Northern Irish charge was
extended to cover bags sold for less than 20 pence in January 2015,
this retailer had to increase the price of a bag for life to enable
it to comply, making it uncompetitive with a single-use
bag.
6.2
Extension of the single use carrier bag charge
creates a ‘dominoes’ effect, in that increasing the
price of any bag makes the next bag up look attractive. One member
reports that since the extension of the charge in Northern Ireland,
bag for life usage has reduced by 50% but the more expensive
re-usable bags have gone up by roughly the same amount.
6.3
Another member reports that customer usage of single
use bags and bags for life in Northern Ireland is reverting towards
the same sort of levels experienced prior to the charge coming into
effect.
6.4
In conclusion the Northern Ireland experience
suggests that there is no environmental benefit from extending the
charge to reusable bags.
7
Profits from the sale of carrier bags
7.1
We welcome the fact that should Ministers choose to
make regulations requiring retailers to pass on the net proceeds
from the 5 pence carrier bag charge, these regulations would enable
retailers to pass on proceeds to any type of good cause rather than
restricting them to environmental good causes in
particular.
7.2
However, we believe that the current voluntary code
is the appropriate approach and is working well. We are keen to
work with our members and the Welsh Government to ensure that the
voluntary code continues to be effective.
8
Collection and Disposal of Waste
8.1
The concern here is whether retailers will have to
physically separate these streams of waste at store – this
can be an issue for smaller stores where space is very
limited. We would welcome confirmation on whether it is
acceptable for the waste contractor to collect these streams as
comingled recycling separated from general landfill waste.
This comingled recycling can then be sorted at the first level
Materials Recovery Facility (MRF).