Pwyllgor Newid Hinsawdd, yr Amgylchedd a Seilwaith /
Climate Change, Environment and Infrastructure Committee
Bil drafft Diogelu'r Amgylchedd (Cynhyrchion Plastig Untro) (Cymru)/
Draft Environmental Protection (Single-use Plastic Products)(Wales) Bill
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Ymateb gan Sefydliad Siartredig Rheoli Gwastraff/ The Chartered Institution of Wastes Management (CIWM)
The Chartered Institution of Wastes Management (CIWM) is the leading professional body for the resource and waste management sector with a purpose to move the world beyond waste. Representing over 5,600 individuals in the UK, Ireland and overseas, CIWM has a mission to unite, equip and mobilise its professional community to lead, influence and deliver the science, strategies, businesses and policies for the sustainable management of resources and waste. CIWM has ten regional centres across the UK and Ireland, including CIWM Cymru Wales, that are run by member volunteers.
CIWM Cymru Wales organise an extensive programme of technical meetings, site visits, symposia and social events. Representing over 350 waste professionals working in local and national governments, agencies, private waste companies, consultancies, social enterprises as well as education and research centres, CIWM Cymru Wales provides a forum for professional debate and the opportunity for members to meet and socialise through a strong network of professionals.
Draft Environment Protection (Single-use Plastic Products) (Wales) Bill
1 The Climate Change, Environment, and Infrastructure Committee is considering the draft Environmental Protection (Single-use Plastic Products) (Wales) Bill, which is due to be introduced to the Senedd early in the autumn. The draft Bill makes provisions to ban commonly littered single-use plastic items.
2 It would be helpful if you could frame your response around the following terms of reference:
3 Whether a Bill is needed to introduce a ban on commonly littered single-use plastic items;
4 CIWM Cymru Wales surveyed its members during the consultation on Plans to Reducing single use plastic in Wales and this surveyed indicated via members that “the slow progress of voluntary measures taken by communities and businesses to move away from unnecessary single use plastics is too slow, therefore the ban is required (79%)”.
5 From a wider UK perspective, CIWM in response to the EFRA Call for Evidence on Plastic Waste 2021 indicated that there were other mechanisms due to come in over the next few years, of which many if not all of these will have an impact on single use plastic.
6 The advantages and disadvantages of using a Bill rather than secondary legislation to introduce a ban;
7 CIWM Cymru Wales believes the use of a Bill to introduce a ban indicates the importance of single use and sets primary legislation. Plastic is likely to change and there needs to be, within any legislation, flexibility for future requirements; this has already been seen with a move from single use plastic to other single use materials.
8 CIWM Cymru Wales suggests A Single Use Product Bill as the strong message coming from the Plans to Reducing single use plastic in Wales member’s survey was that “Welsh Government should take care that the proposed ban does not simply push manufacturers from one single use item material to another e.g., from plastic disposable cutlery to wooden (bamboo) cutlery which is also disposed of once used”.
9 CIWM Cymru Wales also suggests that green procurement is needed by the public sector to fully support recycling markets, encouraging more material to maintain a circular ‘life’.
10 Whether the provisions of the draft Bill will deliver the policy intention;
11 CIWM Cymru Wales strongly believes the Bill has to take account of single use material, not just plastics. This would indicate how important single use is to Wales and support its original one planet living with reuse and refill as a priority.
12 CIWM Cymru Wales believes that local authority funding is paramount to enable them to enforce the changes this Bill outlines, without this it seems difficult to achieve the policy intention.
13 Members undertaking thePlans to Reducing single use plastic in Walessurvey indicated that “The prohibition of specifically named items is not helpful and a law that stipulates a level of need or some kind of test of usefulness (including the availability of alternative materials and life cycle comparisons) would be more beneficial”. CIWM Cymru Wales believes this would limit the rush for alternatives that may not deliver the intended policy and ensure that manufacturers don’t just use cost as the basis for their material type decisions.
14 Whether there are any potential barriers to the implementation of the draft Bill’s provisions (including the United Kingdom Internal Market Act 2020);
15 As the Bill mirrors the EU Single Use Directive CIWM Cymru Wales assumes there will not be potential barriers to implementation.
16 Whether the powers in the draft Bill for Welsh Ministers to make subordinate legislation are appropriate;
17 CIWM Cymru Wales supports the power to amend the Schedule that indicates which product(s) are within the regulations and what, if any exemptions there are. This allows for any further materials or uses that come to market and are deemed inappropriate. CIWM Cymru Wales assumes any changes will be consulted on.
18 Whether there are any unintended consequences arising from the draft Bill;
19 CIWM Cymru Wales asks for a clear definition of reuse and refill. This may seem a strange ask but this is to prevent the unintended consequence of the relabelling of single-use items as reusable.
20 We are all aware of the impact that Covid had on going back to single use to prevention contamination, but since then there is the issue of single use cutlery then being packaged in a single use plastic outer!
21 CIWM Cymru Wales reiterates the Bill must not be the reason there is a rush to use another material (in plastics place), which could have a knock-on impact on the resources and waste sector in relation to recycling or treatment.
22 The financial implications of the draft Bill (including for businesses and consumers).
23 There are good examples of reuse systems that need to assessed for use in Wales, as in Bristol the CanCan scheme, where coffee shops sign up and coffee users grab a coffee in a reusable cup and take it back to a café on the scheme where it is washed and reused. This type of scheme CIWM Cymru Wales believes is essential with a significant tourist base like Wales.
24 Welsh Government should be encouraged to support reuse and refill; there is an upfront cost, but the container becomes cheaper over time (and uses), reducing the impact of the material’s global footprint.
25 Reuse and refill support the circular economy and there is less residual material to collect and process, reducing fossil fuel usage for collection systems, helping support good air quality.
26 CIWM Cymru Wales are aware that there will need to be a transition period to enable business to adjust the changes proposed in the Bill, to use stock that has recently been purchased and to enable business to source and procure replacements.
27 CIWM Cymru Wales is aware that there have been subsequent changes with increases in oil, which adds a price to plastic, making alternatives a more economic possibility and reuse and refill eminently feasible.