KSB: Once in lifetime opportunity to tackle single-use cup waste and litter

KEEP Scotland Beautiful (KSB) has shared key points from their drafted submission to the ongoing Scottish Government public consultation on single-use cup charge – which remains open until 14 November 2024 …

OUR public perception data shows just how much single-use cups contribute to Scotland’s litter emergency – with 53% of people frequently spotting single-use (hot and cold) beverage containers littered across our country. 

This is why for the past seven years we have been carrying out research, delivering campaigns and testing innovative solutions with partners to tackle our problem with single-use cups through Cup Movement®. 

As an environmental charity we want to see more done to help people move away from their reliance on single-use items, and to reduce the valuable raw materials and CO2 emissions used in creating and disposing of them.

Paul Wallace, our Head of Operations, said: “Our key priority is to see a charge introduced. We’ve been pushing hard for action to be taken to reduce our consumption of single-use cups for many years and were pleased to see measures brought forward in the Circular Economy Bill.

“One thing we are sure of is that no single measure will be effective in changing behaviour on its own, but a charge will encourage people to reduce their reliance on single-use items and raise awareness of consumption habits and promote individual responsibility.

“We believe the charge offers a once in a lifetime opportunity to invest any proceeds generated to set up improved recycling infrastructure and support the development of effective and integrated borrow and reuse infrastructure making it easier for consumers and businesses to choose to do the right thing and help eliminate single-use cup consumption in most situations.”

In our response we are calling for:

• The introduction of a charge on all single-use cups as soon as possible.
• Proceeds from a charge to be used to make it easy for people to recycle effectively and/or to develop infrastructure which makes it the norm for people to borrow and return or use reusable alternatives.
• The level of charge to be no less than 25p as outlined in the EPECOM report in 2018; that the charge should be consistent across all suppliers; and, that the charge be at a level that is visible to the customer. This is necessary to drive shifts in habit.  Additionally, we recommend that the charge level is monitored and reviewed regularly over time to assess its impact in levering behaviour change.
• There should be as few exemptions as possible with regards to the single-use cup charge and so it is important to note that we believe exemptions, if given, should not be permanent and should be scoped out further once a charge is in place. There is an opportunity for proceeds from the charge to be invested in testing and trialling systems in exemption environments to capture learning and make it possible to remove the exemption at a later date.
• We believe funds generated from the charge, and any non-compliance fines, must be used to support, as far as possible, the phasing out of single-use cups through the promotion of behaviour change, encouragement of reuse and the facilitation of recycling, where appropriate.

We strongly support the introduction of a charge; however, we have concerns about allowing retailers and businesses to retain the funds, as was the case with the carrier bag charge. While the carrier bag charge has positively influenced consumption habits and reduced the use of plastic bags, we believe its full potential was not realised.

Should proceeds from a charge be retained by businesses and encouraged to be donated to good causes on a voluntary basis, as per the Single-Use Carrier Bag Charge (Scotland) Regulations 2014, we recommend that the Scottish Government commits to an annual ‘temperature check’ evaluation review to monitor:

– Effectiveness of charge in driving behaviour change of consumers;

– Implementation by businesses and retailers and cost incurred;

– The number of cups charged for; and

– Where proceeds of the charge have been used to do good.

Additionally, we would call for donations to be made to environmental good causes, not just good causes, in order to support a move away from single-use cups to a more circular economy model.

We are concerned that the current capacity and capabilities of local authorities will mean that the number of Fixed Penalty Notices (FPN) issued will be low, as will payment rates, as we have seen with other FPNs for environmental incivilities such as littering and dog fouling.

You can find out more about the work of Cup Movement® and read our reports if you want more information.   

We encourage everyone – consumers and businesses – to have their say on this important issue. The consultation is open until 14 November and you can click here to respond to the consultation.