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
communitiesretail
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).