Plastic bag tax - the full BPF position

The British Plastics Federation (BPF) represents the interests of all sectors of the plastics industry; raw material and additive manufacturers, distributors and suppliers, moulders, converters, fabricators, machinery manufacturers and distributors and recycling companies.

The UK plastics industry opposes the idea of a plastic bag tax on principle, because it would unfairly discriminate against plastic materials and is based on a misinterpretation of the relationship between materials, the environment and the causes of litter.

1) Plastic packaging waste management is already legislated in the EU

• A tax on plastic bags would go against the spirit of producer responsibility legislation already in place addressing the recovery and recycling of plastic bags.
  
• Both plastic and paper carrier bags are listed as examples of packaging in 2004/12/EC (formerly 94/62) Directive on Packaging and Packaging Waste, and a recent ruling of European Court of Justice (Plato Plastik v Caropack, 11 September 2003), concluded that plastic carrier bags, as supplied to customers by retailers, are packaging. This means that the recovery and recycling of carrier bags has already been legislated for.
  
• Furthermore, an additional measure set up in a particular EU region or locality could go against the spirit of the Directive in its core aim to harmonise national measures in order to remove distortion of competition. 

2) Plastic bags are a social-economic and environmental success story

• Plastic carriers are lightweight, convenient and popular. A tax would discriminate unjustly against plastics and would represent an anti-competitive move and a serious restraint on trade, damaging jobs and on an industry already battling against over-regulation and under-investment.
  
• Plastic bags already achieve a tremendous rate of re-use by UK consumers, estimated as 80%, as cited by a UK Government survey in 2000 (NOP research for DEFRA’s “Are you doing your bit?” campaign Sep 2000).  These can be used as bin liners, dog fouling bags, or indeed, for future trips to the supermarket.
  
• Just 4% of crude oil consumption is used for all plastics, and only 2% for all films, of which plastic bags is a tiny proportion. 85% of oil is burned as fuel or heating.
  
• Plastic bags are extraordinarily energy-efficient in manufacture, and more so than paper bags. Not only do they prevent waste of goods carried, but the embodied energy can be recovered either by recycling or via energy-from-waste systems.
  
• Such a discriminatory measure could force consumer demand for tax-free paper bags.  However, the Winnipeg report (“The Winnipeg Packaging Project: Comparison of Grocery Bags”, Prof. Bob Fenton, Uni of Winnipeg) concludes that, “a tonne of plastic one trip bags contains about 105,500 bags. A tonne of paper one-trip bags contains about 18,000 bags i.e. roughly six times heavier per bag.”  The Franklin report (Franklin Associates Ltd, New York - 1981/1990) also found that paper bags occupy roughly ten times more space than plastics bags – as with weight, a vital factor in storage, transportation, waste collection and landfill.  A tax would be detrimental to the environment, particularly in terms of added transportation fuel consumption, as well as an extra cost burden on businesses.
  
• Retailers are already encouraging consumers to re-use and recycle carrier bags, including introducing in-store recycling banks and “penny-back” re-use schemes.  The industry continues to innovate better bags, using less material, and a greater percentage of recycled content.

3) A tax on plastic bags would not address litter

• Plastic bags are not a major contributor to litter, far less than 1%.  This is supported by statistics and surveys from ENCAMS (the organisation which runs the Keep Britain Tidy campaign).  In their Local Environmental Quality Survey 2001-2, plastic bags were found in only 5% of transects (a transect is a 50 square metres of space) whereas smoking litter was found in 82% and confectionery litter in 63%.
  
• The plastics industry believes that litter is a social-behavioural problem and not down to any specific product or material.  Even if plastic bags were a large litter component, a tax would do little to change people’s attitudes and effectively condones litter-dropping.
  
• Experience of the plastic bag tax in the Republic of Ireland is not positive.  It is suggested by RGDATA (the Irish grocery association) that every retailer has suffered costs of stolen wire baskets and trolleys, used in place of carrier bags, estimating a loss of 5,600 euros per outlet.
  
• In addition, reports suggest that the Irish have suffered an increase in shoplifting due to the fact that thieves are less conspicuous bringing in their own bags.   Retailers have made a conservative estimate that the cost from theft would be approximately 10 million euros per annum to the Irish retail trade, without consideration of increased administration and police costs.
  
• Some suggest that the Irish tax has achieved a 90% reduction in the consumption of plastic bags.  However, one of its effects was to increase the sale of bin bags by between 250 and 500%.  These bags will usually be of heavier gauge and weight than standard carrier bags, and so overall use of plastic bags in Eire will not have changed, and overall plastics consumption will have increased.

For its part, the UK plastics industry already puts a huge amount of effort into addressing litter. The BPF is a key member of ENCAMS, for example, and is involved in pioneering more imaginative solutions to deal with litter and local environmental quality across the UK.  There is a range of other potential measures, rather than a tax, which could be considered, and which could be adapted for each specific locality or region to take control of their own respective local environments.   These could include the following:

• Taking relevant opportunities to emphasise to the public that the offence of littering is unacceptable and unnecessary.  Local authorities and citizens alike should make full use of the powers contained in Part IV of the Environmental Protection Act 1990 to combat litter.
  
• Participating with ENCAMS’s People and Places Programme, a long-term strategy designed to help local authorities meet their responsibilities under the Code of Practice on Litter and Refuse. 
  
• In the same way that DEFRA has recently launched a Voluntary Code of Practice addressing fast food litter, ‘Food On The Go – A Voluntary Code of Practice for Local Partnerships’ (November 2004), perhaps something could be gained from a similar Code for retailers and bags.  A direct engagement of stakeholders with an interest in addressing litter to educate those who cause it would be much more effective than a tax.

If you have any further queries on this issue, please don’t hesitate to get in touch with the BPF, tel: 020 7457 5000, fax 020 7457 5045.  Further information on the issue is also available on the Carrier Bag Consortium's website - www.carrierbagtax.com

If you're still not convinced, or if you have any further queries on this issue, please do not hesitate to get in touch with us at the BPF, email aroberts@bpf.co.uk, or tel: 020 7457 5000, fax 020 7457 5045.