Scottish bag tax impact assessment flawed, says PAFA

PAFA (Packaging and Films Association) has said that the Scottish Government’s recently released “Partial Business and Regulatory Impact Assessment” on carrier bag charges is flawed because it fails to take into account the significant impact reductions achieved through voluntary means, as well as the major likely effects on jobs at the 22 Scottish firms that supply carrier bags.

The Scottish government recently confirmed it is going ahead with the introduction of a 5p levy on plastic bags from October 2014.

Barry Turner, PAFA CEO, said: "This Impact Assessment admits there is 'uncertainty over a number of estimates and assumptions' yet continues to advocate punitive legislation against what it persists in calling single use bags - although more than 70 percent are actually re-used. It also agrees there will be 'an increase in demand for bin liners and dog waste bags' and ignores the 50 percent reduction in virgin polymer (for example through increasing recycled content) that we have achieved on a voluntary basis at no cost to the consumer.”

In contrast, says PAFA, the proposal in Scotland will be a major cost to households which is unnecessary and will come at a time when people can least afford it. The industry organisation says the true costs of pushing the proposed legislation onto the political agenda have been ignored and the real effects on Scottish jobs have been overlooked.

“It is now more than 10 years since the Scottish Government embarked on its programme to legislate against carrier bags. We have to wonder how many tens of millions of pounds of taxpayers money have been spent on getting this far when that money could have been spent on initiatives that bring true significant net environmental benefit and create jobs rather than destroy them in the 22 Scottish companies they have identified in the bag supply chain in Scotland," said Turner.

PAFA says its members, who manufacture and supply a wide range of flexible and rigid protective packaging, have led the way in responsible and sustainable actions to dramatically reduce the impacts of their own products. “We are constantly innovating to create products that save food waste and prevent product damage whilst at the same time reducing our carbon impacts at every stage,” continued Turner. “Although carrier bags are a small part of this industry we have voluntarily more than halved bag impacts. We now use less virgin material, far more recycled plastic and have helped bring about a significant increase in front of store recycling bins for bags.”

Michael Flynn of Intelipac, Chairman of the Carrier Bag Consortium – a PAFA lobby group – said: “The case presented in the latest Scottish Government Impact Assessment ignores the solid science – including Environment Agency evidence - which points to plastic carriers being the most convenient, resource-efficient, recyclable means of getting goods home if they are used, re-used, recycled or recovered. It is clear Scotland is attempting to justify yet another tax on consumers without a realistic assessment of the unintended consequences of switching to higher impact materials and killing off Scottish jobs.”