Introducing market 
restrictions on 
problematic single -use 
plastic items in Scotland  
 
Final Business and Regulatory Impact Assessment (BRIA)  
 
 
 
 
 
 
 
 
 
 
 
 
 
August  2021  Contents  
1.0 Title of proposal: Market restrictions on problematic single -use plastic items in 
Scotland ................................ ................................ ................................ ......................  4 
2.0 Purpose and intended effect  ................................ ................................ .............  4 
2.1 Background  ................................ ................................ ................................ ... 4 
2.2 Objective and rationale  ................................ ................................ ..................  5 
3.0 Consultation  ................................ ................................ ................................ ...... 8 
3.1 Consultation within Government  ................................ ................................ .... 8 
3.2 Public consultation ................................ ................................ .........................  9 
3.3 Business consultation  ................................ ................................ ..................  13 
4.0 Options  ................................ ................................ ................................ ...........  13 
4.1 Approach to modell ing the policy options  ................................ ....................  14 
4.2 Trends in market sales growth of the single -use items (plastics and 
alternatives)  ................................ ................................ ................................ ...........  15 
4.3 Trends in market shares  ................................ ................................ ..............  16 
4.4 Number and weight of items and prices  ................................ ......................  17 
4.5 Approach to assessing impacts of policy options  ................................ ........  17 
4.6 Carbon impacts  ................................ ................................ ...........................  18 
4.7 Impacts associated with different end -of-life waste management options  ... 18 
4.8 Direct and indirect costs of litter  ................................ ................................ . 20 
4.9 Waste collection costs  ................................ ................................ .................  22 
4.10  Enforcement costs  ................................ ................................ ...................  22 
4.11  Communication costs  ................................ ................................ ...............  22 
4.12  Costs to consumers and distributors  ................................ ........................  23 
5.0 Results  ................................ ................................ ................................ ............  23 
6.0 Scottish Firms Impact Test  ................................ ................................ .............  28 
6.1 Scottish Firms Impact Test results ................................ ...............................  29 
6.2 Supplementary business research on EPS food containers  ........................  36 
7.0 Competition Assessment  ................................ ................................ ................  38 
7.1 Identifying relevant markets  ................................ ................................ .........  38 
7.2 Overview of markets affected by single -use plastic restrictions  ...................  39 
7.3 Detailed Competition Assessment  ................................ ...............................  47 
8.0 Consumer Assessment  ................................ ................................ ...................  61 
9.0 Test run of business forms  ................................ ................................ .............  67 
10.0  Digital Impact Test  ................................ ................................ ..........................  67 11.0  Legal Aid Impact Test  ................................ ................................ .....................  68 
12.0  Enforcement, sanctions and monitoring  ................................ ..........................  68 
13.0  Implementation and delivery plan  ................................ ................................ ... 68 
14.0  Declaration and publication  ................................ ................................ ............  68 
15.0  Annex A: Indicative questions for Scottish Firms Impact Test interviews  ....... 69 
16.0  Annex B: Demand elasticities of food products ................................ ...............  70 
17.0  Annex C: Full NPV tables of individual items  ................................ .................  71 
 
 
  1.0 Title of proposal: Market restrictions on problematic single -use plastic 
items in Scotland  
1. This document is the final Business and Regulatory Impact Assessment (BRIA) 
for the introduction of  market restrictions on problemat ic single -use plastic items 
as identified in Article 5 of the EU Single -Use Plastics Directive (EU  SUPD ) 
2019/904 .1 The final BRIA builds detail onto the partial BRIA published on 12 
October 2020  and is written subject to the best available information at the time .  
2.0 Purpose and intended effect  
2.1 Backgro und 
2. The EU SUPD  proposes action on 10 single -use plastic  items  that account for 
approximately 70% of marine litter products found on European beaches. The 
directive promotes circular approaches and includes a set of ambitious 
measures  to reduce the impact of these single -use plastics items. One of the 
meas ures, conta ined within Article 5 of the Directive , is a restriction on placing  
selected single -use products on the market .  
3. These proposals build on a range of activity already undertaken as Ministers 
have sought to create a more circular economy which keeps products  and 
materials in high value use for as long as possible.  
4. In February 2016, Making Things Last: A Circular Economy Strategy for 
Scotland2 was published. Th is overarching strategy integrated the key elements 
of the Zero Waste Plan3 and Safeguarding Scotland’s Resources4 and built on 
Scotland’s zero waste and resource efficiency agendas. The strategy set out 
how a more circular economy would  benefit:  
• The environment – cutting waste and carbon emissions and reducing 
reliance on scarce resources . 
• The economy – improving productivity, opening up new markets and 
improving resilience . 
• Communities – more, lower cost options to access the goods we need 
with opportunities for social enterprise .  
5. The Scottish Government has acted to address the negative externalities 
associated with single -use disposable products through the introduction of the 
single -use carrier bag charge  in 2014 and its pending increase; the ban of 
 
1 European Union (2019) Directive (EU) 2019/904 of the European Parliament and of the Council of 5 June 
2019 on the reduction of the impact of certain plastic products on the environment, Article 3(3) .  
2 The Scottish Government (2016) Making things last  – A circular economy strategy  for Scotland .  
3 The Scottish Government (2010) Scotland’s Zero Waste Plan .  
4 The Scottish Government (2013) Safeguarding Scotland's resources - A programme for the efficient use of 
our materials . microbeads in 2018; and the ban of plastic -stemmed cotton buds which came 
into effect in October 2019. The S cottish Government will also introduc e a 
Scottish Deposit Return Scheme to increase recycling rates an d reduce littering  
of single -use drinks containers . Regulations were passed  by the Scottish 
Parliament in May 2020  and the scheme will become operational in due course .5   
6. The Expert Panel on Environmental Charging and Other Measures (EPECOM) 
was formed in May 2018.6 Its remit was t o advise Scottish Ministers on charges 
or other measures which may be adopted in Scotland  with the goal of 
encouraging the long -term and sustainable changes in consumer and producer 
behaviour  required to move towards a circular economy. In July 2019 the Expert 
Panel set out its recommendations to tackle the dependence on, and 
environmental impact of, single -use disposable beverage cups in Scotland . 
Included in its recommendat ions was support for the commitment within the EU 
Single -Use Plastic s Directive to ban expanded polystyrene beverage cups by 
2021 .7 The group published a second report Ending the Throwaway Culture: 
Five Principles for Tackling Single -use Items  in Septembe r 2020.8  
 
2.2 Objective and rationale  
7. The Scottish Government proposes to introduce legislation which introduces 
market restrictions on  specific disposable single -use plastic products . The 
evidence summarised  in this document  will be used to inform the policy -making 
process . 
8. Potential non -plastic alternatives that exist for the specified single -use products 
have been identified as part of the BRIA process. Targeted exemptions to the 
market restrictions to support independent l iving and provide access to single 
use plastic items where necessary for medical needs have been included in the 
draft regulations. Those exemptions will be considered in the Equality Impact 
Assessment (EQIA) which accompanies this BRIA.  
9. When disposed of i ncorrectly, single -use plastic products end up in our rivers, 
lochs, and seas and cause significant harm to the marine environment as well 
as to the public’s enjoyment of Scotland’s natural landscapes. The disposable  
single -use plastic products specified i n this impact assessment are some of the 
most commonly -found products of plastic litter washed up on Scotland’s shores .9 
 
5 The Scottish Government (2020) The Deposit and Return Scheme for Scotland Re gulations 2020 . 
6 The Scottish Government (2018) Expert Panel on Environmental Charging and Other Measures (EPECOM) .  
7 The Scottish Government (2019) Single -use disposable cups: EPECOM recommend ations .  
8 The Scottish Government (2020) Ending the throwaway culture : Five principles  for tackling single -use items 
(EPECOM) .  
9 Marine Conservation Society  (2019) Great British Beach Clean 2019 .  10. Scotland has significant water resources including: 18,743 km of coastline ,10 
125,500 km of rivers and 25,500 lochs .11 These resources are vitally important 
in a number of areas as they support a variety of wildlife, tourism and 
recreation and provide domestic and commercial water supplies.  
11. Once in the environment plastic litter can persist for hundreds of years  caus ing 
enormous harm to ecosystems . Impacts include mortality or sub -lethal effects 
on plants and animals through entanglement , physical damage, and it can  
enter food chain s when  ingest ed. When plastic enter s the marine environment 
it eventually break s down into microplastics which have the potential to 
accelerate accumulation of chemicals throughout the food chain, with potential 
negative impacts  on human and ani mal health.  Most plastic waste eventually 
comes to rest on the seabed and in doing so can facilitate the invasion of alien 
species .12 
12. Chemicals added during the manufacture of plastics can enhance durability, 
act as a colorant, plasticizer, stabilizer or increase flame retardancy. Some of 
these chemicals are classified as persistent organic pollutants (POPs) and 
endocrine disruptor chemicals (EDCs) and will further harm terrestrial and 
marine life if ingested as microplastics.13 
13. For context, plastic decomp oses  around  100 times more slowly than a 
biodegradable material such as paper .14 Some plastic items can last for a few 
decades, whereas others may last for over 500 years. Table 1 below 
demonstrates the comparison of decomposition times between plastics an d 
biodegradable materials .15 
Table 1: Decomposition rates of plastics and biodegradable materials  
Item Decomposition rate  
Paper towel  2-4 weeks  
Newspaper  6 weeks  
Wax carton  3 months  
Plywood  1-3 years  
Plastic grocery bag  10-20 years  
Styrofoam cup  50 years  
Plastic beverage bottle  450 years  
Fishing line  600 years  
 
10 Marine Scotland (2021) Facts and figures about Scotland's sea area (coastline length, sea area in sq kms) . 
11 Scottish Government (2016) Key Scottish Environment Statistics 2016.  
12 Deudero S., Alomar C. (2015) "Mediterranean marine biodiversity under threat: Reviewing influence of 
marine litter on species" in Marine Pollution Bulletin, Volume 98.  
13 Gallo, F et al (2018) “ Marine litter plastics and microplastics and their toxic chemicals components: the need 
for urgent preventive measures ”, in Environmental Sciences Europe, Volume 30.  
14 Reso urce Futures (2019) “A preliminary assessment of the economic impacts of a potential ban on 
expanded polystyrene food and beverage containers”, p.23.  
15 Ibid. 14. It is expected that  market  restrictions on a  range of  single -use disposable  
products  will:  
• Reduce the volume of plastic waste created . 
• Reduce the amount of plastic waste entering Scotland’s  rivers, lochs and 
seas . 
• Reduce the number of products  littered  where reusable substitutes exist . 
• Encourage wider b ehaviour change around material choice . 
15. Achieving these strategic objectives will help Scotland progress towards its 2025 
waste targets, accelerating Scotland’s transition from a ‘linear’ economy which 
is environmentally unsustainable an d energy - and resource -intensive  to a more 
resource -efficient and sustainable circular economy.  
16. With reference to the National Performance Framework ,16 directly applicable 
strategic objectives are :  
• We value and enjoy our built and natural environment and protect it and 
enhance it for future generations.17 
• We reduce the local and global environmental impact of our consumption 
and production.18 
17. Directly applicable from the Measurement Set are:19  
• Reduce greenhouse gas emissions . 
• Improve Scotland’s reputation . 
• Improve people’s perceptions of their neighbourhood . 
• Improve the condition of pro tected nature sites . 
• Increase natural capital . 
• Improve the state of Scotland’s marine environment . 
• Reduce Scotland’s carbon footprint . 
• Reduce waste generate d.  
 
16 The Scottish Government (2021) National Pe rformance Framework . 
17 The Scottish Government (2021) National Outcome: We value and enjoy our built environment and protect it 
and enhance it for future generations . 
18 The Scottish Government (2021) National Outcome: We  reduce the local and global environmental impact of 
our consumption and production .  
19 The Scottish Government (20 20) National Performance Framework - National Indicator Performance . 18. Enacting market  restrictions  on specific single -use plastic products  will 
contribute to objectives set out in the Climate Change  (Emissions Reduction 
Targets) (Scotland) Act 2019 .20 
19. The Climate Change Plan: Third RPP 2018 -2032 was published in February 
2018 and sets out plans to achieve decarbonisation of the economy in th e 
period to 2032, making progress towards the target of reducing emissions by 
80% by 2050.  An update to the Climate Change Plan was published  in 
December  2020.21 
20. In 2015, the Scottish Government signed up to support the United Nations 
Sustainable Development Goals.22 The ambition behind the goals is to end 
poverty, protect the planet and ensure prosperity for all as part of a new 
sustainable development agenda. Market  restrictions on the specified  single -
use plastic products  will have a positive impact on a number of these goals, 
most explicitly Goals 12, 13, 14 and 15:  
• Responsible Consumption and Production . 
• Climate Action . 
• Life Below Water . 
• Life on Land . 
21. Finally, e nacting market restrictions on specific  single -use plastic product s will 
contribute to the Green Recovery Plan objectives set out in Protecting 
Scotland, Renewing Scotland, the Government’s Programme for Scotland 
2020 -21:23  
“We will ensure our rural economy and Scotland’s rich natural resources and 
biodiversity are central to our economic, environmental, and social wellbeing.”  
3.0 Consultation  
3.1 Consultation within Government  
22. The Scottish Government Environment and Forestry  Directorate has engaged 
with other relevant teams across the Scottish Government regarding the 
potential impacts of the policy on, for example:  
• Socio -economic inequality issues such as low income, low wealth, and 
area deprivation . 
 
20 The Scottish Parliament (2019) Climate Change (Emissions Reduction Targets) (Scotland) Act 2019 . 
21 The Scottish Government (2020) Securing a green recovery on a path to net zero: climate change plan 
2018 –2032 - update  
22 United Nations (2020) UN Sustaina ble Development Goals . 
23 The Scottish Government (2020) Protecting Scotland, Renewing Scotland: The Government’s Programme 
for Scotland 2020 -2021 . • Different  geographic communities including island communities . 
• People  experiencing disabilities and their carers.  
• Businesses , including the food and drink industry and the hospitality 
sector.  
3.2 Public consultation  
23. A partial BRIA document was published alongside the S cottish Government 
consultation paper on the introduction of  market restrictions. Th e consultation 
was launched on 12 th October 2020 and ended on 4 th January 2021 , seeking 
views on the items to be covered by the restrictions, and how the restr ictions 
might be implemented.  The consultation contained 8 questions with a mix of 
open and closed (tick -box) questions , including topics such as:   
• Items to be covered.  
• Exemptions  
• Future market restrictions  
• Environmental, economic, and social impacts  
• The i mpact  of COVID -19 
24. The analysis was based on 2,689 responses, comprising of 787 substantive  
(personalised) responses from 90 organisations and 697 individuals , and 1,902 
campaign responses (submitted using a standard template), in this case 
provided by Friends of the Earth S cotland .  
25. Organisational respon ses were submitted by  environmental charities, third 
sector and community organisations  (29); packaging manu facturers and other 
types of manufacturing organisations (22);  food, drink, tourism, and other 
business organisations (16) ; public sector organisations (11); environmental 
consultancies and resource management organisations (8); and a small group 
of other organisations that did not fit into any of the preceding categories ( 4).  
26. A full analysis of the consultation responses and key messages was published 
on 17th March 2021 and is available here.  
Summary of public consultation findings  
27. There was strong overall support  from both organisations and i ndividuals for 
market restrictions to be introduced on single -use plastics supplied in a 
commercial context.  
28. Among individuals, 94% were in favour of a ban o n all the items specified in 
the consultation paper  
29. Among organisations, the proportion in favour of a ban ranged from 76% for 
single -use plastic plates, to 91% for single -use balloon stick s and food and 
beverage containers made from expanded polystyrene. In general, packaging manufacturers and other types of manufacturing organisations were les s 
supportive of market restrictions on the specified items than other respondents.  
30. The 1,902 respondents who submitted their responses through the Friends of 
the Earth Scotland campaign expressed support for market restrictions on all 
the specified items . 
31. Respondents who were in favour of market restrictions on all the proposed 
items  acknowledged the convenience of single -use plastics but thought:  
• The harm to the environment caused by these items was, in most 
cases, greater than any benefit they provided .  
• They were a symbol of Scotland’s throwaway culture .  
• None of the items in the proposed list could be considered ‘essential’ .  
• Their continued production and use acted as a deterrent  to innovation 
and/or wider use of existing, greener, and more sustainabl e alternatives . 
• Existing alternatives were, in many cases, cheaper than the equivalent 
single -use plastic item.  
32. Respondents in favour of market restrictions on all the proposed items also 
argued that regulation was needed to ‘make change happen’ and that b anning 
these items was preferable to charging consumers more for them.  
33. Some respondents supported restrictions on most, but not all, of the single -use 
plastic items specified in the consultation paper . Individuals in this group often 
identified as disabled and/or raised concerns of the potential implications for 
disabled people. Most organisations in this group were food, drink, tourism or 
other businesses , or manufacturers. These organisations highlig hted where 
exemptions should be made , for example in vending machines or in bio -based 
and compostable take -away  packaging. Some organisational respondents in 
this group  called for life -cycle assessments to identify social, economic, and 
environmental impac ts of potential alternatives to the single -use plastic items 
that are proposed for restrictions.  
34. A small group of respondents opposed market restrictions on at least half of 
the specified items. This group mainly comprised manufacturing organisations 
or food, drink, tourism,  and other business organisations . They argued that , in 
certain contexts, there were no better alternatives available and they opposed 
a ‘blanket, one -size-fits-all’ approach to dealing with single -use plastic 
products .  
35. Respondents were mostly supportive of restrictions on the non -commercial 
supply of single -use plastics  in tackling Scotland’s throwaway culture . Those 
opposed to such restrictions (all of whom were packaging or other 
manufacturers) highlighted the potentia l costs of alternatives for charitable and 
community food groups and the NHS, or they argued that bio -based 
compostable single -use items should be permitted where reuse is not possible 
for health, safety, practical or economic reasons.   
36. 94% of respondents supported the proposal to introduce a restriction on the 
manufacturing of the specified single -use plastic items, with similar levels of 
support among individuals and organisations as a whole. However, food, drink, 
tourism and other business organisations and manufacturing organisations 
were divided in their views.  
 
37. Respondents supporting this restriction thought the manufacturing industry 
needed to take greater responsibility for environmental damage . If the 
commercial supply of the  specified items was going to be effectively banned in 
Scotland, then it was viewed as  ‘inconsistent’ to permit companies to continue 
to profit from the manufacture and export of  these items to other countries.   
 
38. The most common reason given for opposing a restriction on manufacturing 
the items  was that this would risk Scottish companies becoming uncompetitive  
internationally , given that such restrictions will not exist in many other 
countries.  (These concerns are addressed in the Competition Assessment. ) 
 
39. 80% of respondents were opposed to  additional  exemptions to the proposed 
market restrictions , while 20% supported additional exemptions . There were 
however differences between organisational and individual views on this issue. 
Most individuals did not support further exemptions, wh ilst organisations had a 
roughly 50/50 split between opposition and support. Manufacturing , food and 
drink, tourism, and other business organisations were more likely than other 
organisations to support additional exemptions.  
 
40. Support for a dditional exemptions was mostly focused on groups of items or 
‘materials’ , and around two main sectors :  
 
• Medical, care, an d independent living .  
• Food, drink, and catering . 
 
41. Those opposed to additional exemptions argued that a minimal approach to 
exemptions should be adopted to provide clarity for all parties; to avoid 
loopholes which would potentially undermine the aims of the market 
restrictions ; and to increase the effectiveness of the legislation, encourage 
innovation and maximise the environmental benefits.  
 
42. Exemptions were supported where single -use plastic straws were required for 
medical reasons or to support indepen dent living. Respondents suggested that 
disabled people should be consulted to determine how best to implement the 
proposed exemption , and called for reusable, recyclable, or compostable 
straws to be developed and made available to these groups instead.  
 
43. Suggestions were also made for how access to plastic straws could be made 
available for those who needed them , whilst still restricting use for the general public. The two main views given here were that plastic straws could be 
provided on prescription or through health and social care services , and that 
they should be made available only upon request ; in hospitality venues, for 
example.  
 
44. More than 94% of respondents , and 79% of organisations,  were in favour of 
additional market restrictions for single -use plastic items. The 1,902 
respondents who submitted responses through the Friends of the Earth 
Scotland campaign  wanted to see additional market restrictions cover plastic 
wet wipes and plastic tampon applicator s. The main reasons given by 
supporters was the immediate and long -term damage caused by  single -use 
plastics and the shift away from these items as part of a broader move to a 
‘greener’, low carbon economy.   
 
45. The main opposition to additional market restrictions  came from packaging 
manufacturers and other types of manufacturing organisations.  Comments 
here included:  
 
• Single -use plastics served an important purpose and that effective 
alternatives were not always available . 
• Other effective ways of deal ing with problematic single -use plastics 
were already planned or being pursued  (e.g. EPR, taxes, recycling 
initiatives) . 
• Non-plastic alternatives could also cause environmental harm . 
 
46. Environmental, economic, or social impacts relating to the proposed market 
restrictions were identified by just over a quarter of respondents. Organisations 
were more likely than individuals to do so. The main impacts discussed were:  
 
• Environmental impact s of alternatives to single -use plastics . 
• Impact s of littering . 
• Opportunities and challenges for business . 
• Need for support for businesses following the changes . 
• Role and influence of ‘big business’ in achieving change .  
• Global trade in and use of single use plastics . 
• Impacts on health and wellbeing . 
• Financial impact s on individuals . 
• Impacts on equality groups .  
 
47. 57% of respondents said the COVID -19 pandemic had resulted in changes to 
the market or wider economy that were not fully accounted for in the 
consultation. Organisations were more likely than individuals to think this. 
Respondents thought that COVID -19 had brought economic and social 
changes which had a potential impact on the single -use plastics market , and 
the wider aims of the proposed ma rket restrictions. Changes were identified 
within the retail, hospitality and catering, service, health and social care, leisure  and recreation  sectors , and in people’s working arrangements (including home 
working).  
 
48. Respondents also identified changes in public attitudes and behaviour s, and 
increased costs for businesses. While there was broad agreement over 
COVID -related changes, there was less agreem ent over the appropriate 
response to these changes and the implications for introducing market 
restrictions on single -use plastic items.  
 
49. Other comments mostly involved endorsement of the proposed  market 
restrictions and/or  to emphasise the need for urgent action in this policy area. 
Respondents wanted the Scottish Government to ‘go further’ to address the 
problem of plastic and to facilitate a move to a more sustainable , ‘greener 
economy’. Respondents also called for the (r e)introduction of the Circular 
Economy Bill to the Scottish Parliament. These comments were made by the 
1,902 respondents from the Friends of the Earth Scotland campaign , and other 
individuals. Some  manufacturing, food, drink, tourism, and other business 
organisations  provided information about ongoing work to improve the 
sustainability of products and stressed the importance of a collaborative 
approach in  progressing work in this area.  
3.3 Business consultation  
50. The aim of the e ngagement with businesses was to identify : (1) the current state 
of the market for the specified single -use plastic  items in Scotland; (2) the 
evidence  base related to individual items (e.g. sales volume; unit cost per item ); 
(3) industry views  around the impact of market  restrictions for the items; and (4) 
the potential for uninte nded consequences of market restrictions.  
51. To understand the full impacts of the legislation on small, medium, and large 
businesses, discussions were held with an appropriate cross -section of affected 
stakeholders . 
52. Results of the business consultation have informed and will be presented in the 
Competition Assessment and Scottish Firms Impact Test sections.  
4.0 Options   
53. The Scottish Government is aligning  policy with EU SUPD Article 5, to 
consider  the introduction of market restrictions for the following items:  
54. Single -use plastic cutlery (forks, knives, spoons, chopsticks).  
55. Single -use plastic plates .  
56. Single -use plastic straws.  
57. Single -use plastic beverage stirrers.  
58. Single -use plastic balloon sticks.  59. Single -use food containers24 made of expanded polystyrene  (EPS) and 
extruded polystyrene (XPS) , including their covers and lids .  
60. Single -use cups a nd other beverage containers made of EPS and XPS , 
including their covers and lids.25 
61. Given that the Scottish Government has committed to implementing 
regulations in line with the EU SUPD Article 5, only one policy option is 
compared to the business -as-usual scenario.  
62. Therefore, the two options  considered  are:  
63. Baseline: No policy change – business as usual. The baseline against which 
the costs and benefits of the introduction and implementation of t he market 
restrictions on the single -use plastic items  are evaluated.  
64. Option 1: Scottish legislation will restrict the supply  and manufacture  of the single -use plastic  
items listed above. Specific exemptions will apply to the restrictions to ensure medica l, health, 
and wellbeing purposes as well as independent living. 26 
4.1 Approach to modelling the policy options  
65. The cost -benefit model focuses on the switch from the restricted single -use 
plastic items to the most -likely alternative single -use products. In line with 
earlier studies conducted for the Department for Environment, Food and Rural 
Affairs (Defra), the model also assumes a decrease in overall use of single -use 
items (plastic and alternati ve) over time, under both the business -as-usual 
scenario and Option 1. Part of this decrease is driven by a shift towards 
reusable products. Owing to limited comparability of the application of 
reusables as well as a lack of evidence, we have not sought to  produce a 
separate model for reuse .27  
66. Legislation concerning the restrictions is expected to be laid by the end of 
2021 . For the purposes of this document we have assumed regulations are 
laid in November 2021 and  come into force on 1 June  2022. To reflect the 
expected timeline, the model uses 2021 as a base year and assumes a 
transition period between November 2021 and June  2022, when the 
restrictions have not yet been implemented.  
 
24 Used for on -the-go food which is ready to eat and does not require further preparation.  
25 For simplicity , both EPS and XPS  items will be referred to as EPS throughout the rest of this assessment . 
26 Scottish Government (2020) Introducing market restrictions on problematic single -use plastic items in 
Scotland: Partial Business and Regulatory Impact Assessment (BRIA) .  
27 It is diffic ult to anticipate and model the impact of restrictions on single -use plastics products on trends in 
reusables. First, their applications are less directly comparable. For example, food and drink outlets cannot 
easily switch to giving out reusable straws wi thout systems in place to recover the items and associated 
consumer behaviour change. Second, like -for-like assessment of price is not straightforward, as it must be 
based on a ‘functional unit’, representing one use of the item. This requires reliable dat a on how many times 
each item is reused, on average, which is not available.  67. The Scottish Government recognises the uncertainty around  the potential 
impact the United Kingdom Internal Market Act 2020 could have on the effect 
of these regulations, if lower standards are applied elsewhere in the UK.  
68. Due to the uncertainty of the impact of the United Kingdom Internal Market Act 
2020 the mod elling used in this BRIA assumes that the draft regulations are 
fully effective.  
4.2 Trends in market sales growth of the single -use items ( plastics and 
alternatives)  
69. The model includes assumptions regarding the overall growth in market sales of 
all the single -use items in question: both the single -use plastic items  covered by 
the restrictions and their most -likely alternatives. The assumptions regarding 
market trends h ave been informed by previous studies conducted for Defra, 
which looked at the impacts associated with similar restrictions on selected 
single -use plastic items.28 The assumptions around market sales growth in these 
previous impact assessments incorporated  population forecasts specific to 
England. To account for any differences in population forecasts, the model has 
been adjusted to account for these differences between the forecasts produced 
for England and Scotland .  
70. The negative growth trends reflected i n the assumptions below are driven by 
rising awareness of the population around the negative effects of single -use 
items, the desire of businesses to avoid the costs of non -plastic single -use 
alternative products, and a gradual shift towards reusable produ cts. 
71. Research by Resource Futures found that many wholesalers were announcing 
a switc h to plastic -free alternatives at the time the research was conducted.29 
This observed trend was projected to continue , with the assumption that this 
would be in a linear fashion . This is recognised as a simplified version of the 
market  and in reality , it is likely that switching would occur in a non -linear fashion,  
however, it is difficult to provide a robust forecast of this. A Low, Central and 
High scenario approach was therefore taken  by Resource Futures . We have 
adopted a similar approach, using  Central figures in the model as follows : 
72. For cutlery and plates, the model assumes an annual market growth trend of -
1.1 per cent under the baseline, and of -2.1 per cent under Option 1.  
73. For balloon sticks, the model assumes an annual market growth trend of -1.1 
per cent under the baseline, and an annual change of -3 per cent under Option 
1. The faster decline in the use of single -use balloon sticks compared with 
 
28 Resource Future s on behalf of Defra (2018a): A prelimin ary assessment of the economic impacts of a 
potential ban on plastic cutlery, plastic plates and plastic balloon sticks , A preliminary assessment of the 
economic, environmental and social impacts of a potential ban on plastic straws, plastic stem cotton buds and 
plastics drinks stirrers ; and Resource Futures on behalf of Defra (2019) A preliminary assessment of the 
economic impacts of a potential ban on expanded polystyrene food and beverage containers . 
29 ibid single -use cutlery and pla tes reflects the fact that alternatives to plastic balloon 
sticks are less readily available, and that it is easier to avoid their use.  
74. In the case of beverage stirrers and straws, the model assumes a marginal 
annual increase in sales of 0.16 per cent  under the baseline and an annual 
reduction of -1 per cent under Option 1.  
75. Finally, in the case of EPS food containers and EP S cups, the model assumes 
an increase of 2.9 per cent in the sales of single -use items under both scenarios. 
This increase is primarily driven by the strong growth in the food service sector 
itself (reported to be as high as 7 per cent p.a.), as reported in  a previous study.30 
76. Note on the potential short -term impact of the pandemic on demand for single -
use products: the model has been adjusted to take into account GDP forecasts 
published by the Office for Budget Responsibility (OBR), and associated impacts 
on market growth trends. The adjustments took into account the difference 
between GDP growth rate forecasts between the time of the previous studies for 
Defra (2018 and 2019) and the latest GDP growth rate forecasts published by 
the OBR in November 2020.  
77. Taken together, the forecasts imply a significant drop in the annual growth rate 
of single -use products in 2020, followed by a rebound in growth between 2021 -
2023. Despite this potential rebound in the short -term, the overall number of 
single -use items in t he market is expected to be lower than it would have been 
in the absence of the pandemic. The potential impacts associated with the 
pandemic on market growth rates are not modelled beyond 2023.   
4.3 Trends in market shares  
78. The market shares of the individual single -use plastic  items and their most -likely 
alternatives were based on previous assessments undertaken in England for the 
Department for Environment, Food & Rural Affairs (Defra).31,32  In line with views 
expressed by stakeholders, the model assumes the  2020 market shares of 
products in England and Scotland to be the same. Annual changes in the market 
shares of the restricted single -use plastic  items were also informed by these 
previous studies, while incorporating new information on the availability of 
alternatives.  
79. Baseline assumptions on changes in market shares of the restricted single -use 
plastic  items are as follows : 
 
30  Resource Futures on behalf of DEFRA (2019) A preliminary assessment of the economic impacts of a 
potential ban on expanded polystyrene food and beverage containers . 
31 These calculated the relevant market shares based on consumption data provided by large companies.  
32 Resource Future s on behalf of Defra (2018a): A preliminary assessment of the economic impacts of a 
potential ban on plast ic cutlery, plastic plates and plastic balloon sticks , A preliminary assessment of the 
economic , environmental and social impacts of a potential ban on plastic straws, plastic stem cotton buds and 
plastics drinks stirrers ; and Resource Futures on behalf of Defra (2019) A preliminary assessment of the 
economic impacts of a potential ban on expanded polystyrene food and beverage containers . • Single -use plastic  cutlery and plates: a 10  percentage point per annum (p.a.) 
reduction in market shares, capped at 10 per cent of th e total market.  
• Single -use plastic  beverage stirrers and straws: a 10  percentage point p.a. 
reduction, capped at 1 per cent of the total market.  
• Single -use plastic balloon sticks: a 10  percentage point p.a. reduction in 
market shares, capped at 10 per cent of the total market.  
• EPS food containers and EPS cups: a 1 percentage point p.a. reduction.  
80. Under Option 1, the model takes into account the timeline for policy 
announcement (November 2021) and implementation ( June  2022), and 
assumes full compliance with the restri ctions  once they come into force in June  
2022, while factoring in the exemptions for single -use plastic  straws and balloon 
sticks. As a result, market shares for most items are assumed to reduce to 0 per 
cent by June  2022 . A market cap of 1 per cent is assumed for single -use plastic  
straws, and a cap of 0.1 per cent is assumed for single -use plastic  balloon sticks 
from June 2022 on.  
81. During the transition period between November 2021 and June  2022, the model 
assumes that 20 per cent of the adjustment occurs in the first three months of 
the transition period and 80 per cent of the adjustment takes place in the final 
three months. Within  each three -month adjustment period it is assumed that 
market shares adjust in a linear manner.  
4.4 Number and weight of items and prices  
82. Information from the Strategic Environmental Assessment (SEA) published by 
the Scottish Government for the same market res trictions was used to calculate 
the number and weight of single -use plastic and alternative items.33  
83. The prices of single -use plastic and alternative items in Scotland have been 
estimated based on a study carried out related to a similar policy change in 
Wales. This used the averages of prices found on the websites of several 
wholesalers, which supply UK -wide, and therefore the figures did not need 
adjusting for the Scottish market.34 The model assumes that prices remain 
constant for the period analysed  and are calculated exclusive of VAT , as taxes 
are treated as transfer payments.  
4.5 Approach to assessing impacts of policy options  
84. The cost -benefit model considers the quantifiable impacts associated with the 
restrictions. The costs and benefits associated with each impact are analysed 
 
33 The Scottish Government (2020) Introducing market restrictions on problematic single -use plastic items in 
Scotland: Strategic Environmental Assessment - environmental report .  
34 Cole, G; Worth, C; Powell, K; Reeve, S; Stevenson, S; Morgan , N; Walker, H (2019)  Preliminary research to 
assess the impacts of a ban o r restrictions in sale in Wales of items in the EU's Single Use Plastics Directive. 
Cardiff: Welsh Government, GSR report number 32/2020.  over a 10 -year period (i.e. between 2022 -2031) and a net present value (NPV) 
is calculated for each impact. The NPV calculations use a discount rate of 3.5 
per cent, consistent with HM Treasury Green Book guidance.35  
4.6 Carbon impacts  
85. A decline in the use of the restricted items, coupled with a shift to the most -likely 
single -use alternative products typically made of wood and paper, has significant 
implications for carbon emissions at both the production and end-of-life waste 
management stages. The cost -benefit model evaluates the carbon impacts 
associated with the baseline and Option 1, using carbon factors published by 
Zero Waste Scotland.36  
86. The carbon factors are compiled using a life -cycle approach and th erefore 
encompass production or embodied impacts (regardless of whether production 
occurs in the UK or abroad), and disposal impacts, including emissions related 
to collection and transport, and to the waste management process. In addition, 
the carbon fact ors include avoided production impacts whereby waste is 
prevented and recycled (regardless of whether this occurs in the UK or abroad). 
Zero Waste Scotland  reports different carbon factors for different types of 
materials, as well as for waste generated, and whether it is recycled, composted, 
landfilled or incinerated at the end -of-life stage. Further, the carbon factors differ 
depending on whether the waste  is generated by households or non -
households.  
87. To monetise the carbon impacts associated with changes in the carbon footprint 
and emissions of single -use plastic  and alternative products, the model uses 
carbon prices published in the Green Book by HM Treas ury. The Green Book 
reports both traded and non -traded value for carbon prices,37 depending on the 
type of emissions reductions and whether these come from sectors within the 
EU Emissions Trading System (EU ETS).38 According to the UK Government’s 
and the European Commission’s guidance on the EU ETS, energy -intensive 
industry sectors including oil refineries, as well as pulp, paper, and cardboard 
are covered by the scheme. Therefore, the model applies the traded value to 
calculate the carbon impacts associa ted with emissions.  
4.7 Impacts associated with different end-of-life waste management options  
88. The model looks at four different end -of-life management options for the 
restricted single -use plastic  items and their most -likely alternatives, namely:  
• Landfill  
 
35 HM Treasury (2020): The Green Book, Central Government Guidance on Appraisal and Evaluation - Social 
time preference rate (STPR), p.45 -46. 
36 Zero Waste Scotland (2011 -2021) Carbon Metric Publications . 
37 Department for Business, Energy & Industrial Strategy (2020) Green Book supplementary guidance: 
valuation of energy use and greenhouse gas emissions for appraisal .  
38 European Commission (2021) EU Emissions Tra ding System (EU ETS) . • Incineration (energy from waste, EfW)  
• Composting  
• Recycling  
89. Together, these waste management options are assumed to account for around 
99 per cent of the waste generated from the relevant single -use plastic  and 
alternative items in a given year in Scotland. T he model assumes that the rest 
of the waste generated (approximately 1 per cent) is littered.  
90. To calculate the impacts associated with each of the end -of-life management 
options above, the cost -benefit model makes assumptions regarding the 
percentages of waste single -use plastic  and alternative items that are landfilled, 
incinerated, composted or recycled. The model assumes that these percentages 
are constant over the period analysed. The assumptions have been informed by 
previous impact assessments conduc ted for Defra in relation to similar market 
restrictions on single -use plastic  items in England.39  
91. In the case of recycling, the model deviates from the assumptions used in the 
Defra studies regarding the percentage of single -use plastic  and alternative 
items that are recycled, on the basis of insights from Zero Waste Scotland into 
recycling systems in Scotland.  
92. Whereas the Defra studies assumed that some of the single -use plastic  items 
within the scope of the restrictions were recycled, the model does no t include 
recycling as an end -of-life waste management option for the single -use plastic  
items, as none of the items are currently targeted for collection in Scotland.  
93. In the case of alternative single -use items, the model assumes that the 
alternatives to  single -use plastic  balloon sticks and EPS cups are the only items 
of which a share is recycled , but only a very small proportion . By contrast, 
alternatives to single -use plastic  plates, cutlery, straws, beverage stirrers and 
EPS food containers are assumed not to be recycled, since these items are 
contaminated after use, and often poorly separated even if recycling is viable.  
94. Scotland is currently scheduled to introduce a landfi ll ban on biodegradable 
municipal waste in 2025. The definition of biodegradable is such that almost all 
residual waste (of which the single -use plastic  items form a part) would be 
covered. This assessment therefore currently assumes the management route 
for single -use plastic  items disposed of as residual waste post -2025 would be 
Energy from Waste r ather than landfill. We note however that Scottish 
Government is developing a route map identifying how to best achieve its 2025 
 
39 Resource Future s on behalf of Defra (2018a): A preliminary assessment of the economic impacts of a 
potential b an on plastic cutlery, plastic plates and plastic balloon sticks , A preliminary assessment of t he 
economic, environmental and social impacts of a potential ban on plastic straws, plastic stem cotton buds and 
plastics drinks stirrers ; and Resource Futures on behalf of Defra (2019) A preliminary assessment of the 
economic impacts of a potential ban on expanded polystyrene food and beverage containers . waste commitments and optimise waste policy with wider climate goals beyond 
2025.  
95. To calculate costs or benefits associated with different end -of-life waste 
management options, the model uses gate fees charged for waste recycling, 
recovery, treatment and disposal options. These are base d on a survey looking 
at gate fees charged to local authorities in the UK for different waste 
management options.40 Given the landfill ban on biodegradable municipal waste 
that will be effective after 2025, a gate fee of £99 is assumed for all end -of-life 
waste management options except recycling from that year on.  
96. To account for the income local authorities receive for materials provided to 
recycling facilities, the model uses price indicators for relevant materials. Price 
indicators for multigrade paper are applied to the two categories of alternative 
single -use items that are recycled (the cardboard alternatives to balloon sticks 
and EPS cups). Price data was collected and averaged over a five -year period 
to smooth the fluctuation in prices.41  
4.8 Direct and indirect costs of litter  
97. Single -use items that are littered by consumers have three distinct impacts 
associated with them:  
• Direct costs associated with the clean -up of items that have been littered.  
• Indirect disamenity costs from seeing litter on the ground.  
• Indirect costs from the negative effects of plastic pollution.  
98. The cost -benefit model accounts for the first two but owing to a lack of data and 
suitable methodologies, it was not possible to include the indirect costs from the 
negative effe cts of plastic pollution, which affect territorial , land-based  and 
marine natural capital. As a result, the benefits of Option 1, in terms of the 
avoided impacts of plastic pollution, are under -counted.  
99. To estimate the direct costs  associated with cleaning up litter , the model uses 
assumptions based on previous work conducted for Defra that around 1 percent  
of items are littered each year. These assumptions also take account of the 
different degradation rates involved for different types of materials.42 An estimate 
for the costs associated with each tonne of litter clean -up, enforcement and 
education is provided based on a previous study assessing the scale and costs 
of littering in Scotland.43 
 
40 WRAP (2019) Gate fees 2018/19 report Comparing the costs of alternative waste treatment options   
41 letsrecycle.com compiles prices per tonne for different materials on an ex works (EXW) basis (EXW is a 
shipping arrangement in which a seller makes a product available at a specific location, but the buyer has to 
pay the transport costs. ) Paper prices wer e downloaded from : https://www.letsrecycle.com/prices/  
42 Resource Futures on behalf of Defra (2019) A preliminary assessment of the economic impacts of a potential 
ban on expanded polystyrene food and beverage containers .  
43 Zero Waste Scotland (2013) Scotland’s Litter Problem: Quantifying the scale and cost of litter and fly tipping .  100. In terms of the indirect (disamenity) costs  of littering, it is assumed that the 
disamenity costs are perceived on a per -item basis rather than on the basis of 
the weight (or volume) of the items littered. The model draws on previous work 
by Zero Waste Scotland in applying an esti mate of “willingness to pay”, reflecting 
what the population may be willing to pay for a cleaner environment on a per -
item basis.44 This cost estimate is then combined with the number of single -use 
items under the baseline and Option 1, to estimate the ind irect (disamenity) 
costs associated with terrestrial and beach litter. As in the case of direct littering 
costs above, the model takes account of the differences between single -use 
plastic and alternative items in terms of degradation rates.  
101. Estimates for  the amount of beach litter attributable to EPS food and drink 
containers were  informed by  qualitative and quantitative research.45 It should be 
noted that n o composition data was available for beach litter which clearly 
identifies EPS food and drink contai ners as separate items.  
102. Total beach litter composition was informed by analysis of ten years ’ survey data 
from the Marine Conservation Society,46 and the impact assessment for the EU 
SUPD.47 From this, it was estimated that ‘Polystyrene (small)’ and ‘Polystyrene 
foam’ accounted for 9% of litter found on beaches. It was estimated  that 20% of 
this was from EPS food and drink containers , given that the majority of EPS is 
used for  consumer goods packaging. This 20% was then split into the individual 
products on the same ratio as applied to terrestrial litter within the impact 
assessment. From this, the estimate of the proportion of beach litter attributable 
to EPS items is as follows in Table 2: 
Table 2. EPS beach litter by product  
Product  Proportion of total beach litter (%)  
Beverage cups  0.14 
Takeout containers and to -go boxes  0.43 
Food trays and chip cones  0.43 
Pots  0.05 
 
103. An important factor within this methodology is the comparison of the 
decomposition rates between EPS items and biodegradable alternatives. This 
is an important element in distinguishing the benefits gained from the use of 
 
44 Zero Was te Scotland (2013) Scotland’s Litter Problem: Quantifying the scale and cost of litter and fly tipping . 
45 Resource Futu res on behalf of Defra (2019) A preliminary assessment of the economic impacts of a potential 
ban on expanded polystyrene food and beverage containers .  
46 Nelms et al. (2017) Marine anthropogenic litter on British beaches: A 10 -year nationwide assessment using 
citizen science data .  
47 European Comm ission (2018) Impact Assessment, Reducing Marine Litter: action on single -use plastics and 
fishing gear . alternative items compared to EPS.  Non-plastic alternatives to single -use plastic 
items tend to  decompose at a much faster rate, so there will be observable 
impacts on beach litter from the substitution of plastic to non -plastic single -use 
items . 
4.9 Waste collection costs 
104. In addition to the e nd-of-life waste management and littering costs described 
above, the cost -benefit model uses a simple approach to provide an estimate 
for waste collection costs incurred by local authorities. Waste collection costs 
are modelled for all end -of-life waste ma nagement options (including landfill, 
recycling, composting and EfW), using information on councils’ refuse collection 
services to estimate the approximate cost associated with waste collection.48 
105. To provide a more robust estimate of the economic impact on  waste collection 
services, the analysis would need to look at the wider costs such as gate rejects 
and higher gate fees paid for contaminated bins, and costs of disposal at the 
materials recovery facility (MRF) out gate. This was not possible owing to dat a 
constraints.  
106. The analysis excludes landfill tax, as this is a form of transfer payment , defined 
as a redistribution of income through a payment where  no goods or services  are 
being paid for. Transfer payments are excluded from cost -benefit analysis under 
the Green Book methodology.  
4.10 Enforcement costs  
107. The introduction of the restrictions will lead to enforcement costs for local 
authorities, such as audits, investigations or legal cases. It is assumed that most 
enforcement will take place via Trading Standards Scotland  and in combination 
with other duties, and therefore the additional staff time requirements will be low.  
108. The cost -benefit model estimates the ongoing costs associated with 
enforcement using a bottom -up approach, taking into account the 
administrative and legal services required.49 The model assumes a light -touch 
approach to enforcement, and calculates the costs based on 0.1 person per 
local authority to carry out the associated administrative tasks and 0.05 person 
per local a uthority for legal advice.   
4.11 Communication costs  
109. The introduction of the restrictions will be accompanied by a communications 
campaign . The cost -benefit model includes an estimate of these costs, based 
on current plans.   
 
48 Audit Scotland (2000) Benchmarking refuse  collection, A review of councils’ refuse collection services  and 
information provided by Zero Waste Scotland.  
49 Scottish Government (2005) Based on the approach in Proposed plastic bag levy - extended impact 
assessment final report . 4.12 Costs to consumers and distributors  
110. The move away from single -use plastic  items to single -use alternatives can, in 
some cases , imply slightly  higher prices, as products made of wood and paper 
can cost more than single -use plastic  items. The cost -benefit model assum es 
that any increases in the prices of alternative items are passed onto the end 
consumer (i.e. full transfer of change s in item costs ). This is consistent with 
Defra impact assessments of similar restrictions on single -use plastic  items.50 
As note d above (see ‘Prices of items’), cost impacts are based on wholesale 
prices , exclusive of VAT . 
111. The extent to which additional costs will be experienced by consumers will 
depend on the willingness and ability of individual businesses in the supply chain 
to absorb them. This depends on factors such as profit margins , market 
positioning51 and own price elasticities of demand . How noticeable the cost 
increase is to an individual will also depend on the context of the purchase. 
Where a small number of items is pr ovided along with a food or drink purchase, 
the costs to consumers are ‘hidden’ and any cost increases would be marginal. 
Cost increases would be more noticeable to consumers buying items in bulk 
from retailers.  
112. There was in sufficient  data and evidence  available to model the split of the 
additional costs from higher prices between businesses and consumers. 
However, this does not have any effect on the net NPV results.  
5.0 Results  
113. Table 3, below , summarises the cost impacts on each stakeholder group under 
the two scenarios assessed. It shows the NPV values under the baseline 
scenario and Option 1, for each impact and the affected  stakeholder. The net 
benefit  or cost is calculated by deducting the NPV under the baseline scenar io 
from the NPV under Option 1.  A higher NPV is represented as a benefit to 
society, therefore a negative change to the NPV represents an increased cost, 
and a positive change to the NPV represents an increased benefit . The table  
shows that the economy -wide impact of introduc ing the market restrictions , over 
a ten -year period , would be -£13.7 million  compared to business as usual.  
Table 3. Results of the cost-benefit analysis  
Stakeholder  Impact  NPV under 
Baseline (£)  NPV under 
Option 1 (£) Net change 
to NPV (£)  
 
50 Resource Futures on behalf of Defra (2019) A preliminary assessment of the economic impacts of a potential 
ban on expanded polystyrene food and beverage containers . Available at: 
http://sciencesearch.defra.gov.uk/Default.aspx?Menu=Menu&Module=More&Location=None&Completed=220
&ProjectID=20292  
51 Zero Waste Scotl and (2021): “Pricing impacts of single -use plastic bans: Assessing the impact of market -
restrictive bans for single -use plastic products on product pricing”. Not published.  Society  Carbon 
impacts 
(production)  -2,349 ,765 -1,963,643  386,122  
Society  Carbon 
impacts 
(recycling)  5,166 17,800  12,635  
Society  Carbon 
impacts 
(composting)  58,456  77,084  18,628 
Society  Carbon 
impacts 
(incineration)  -506,790  119,682  626,472 
Society  Carbon 
Impacts 
(Landfill)   
-40,026   
-68,611  -28,585  
Local 
Authorities  Recycled 
material  24,533  84,272  59,739  
Local 
Authorities  Composting 
costs   
-193,214   
-257,908  -64,694  
Local 
Authorities  Energy from 
Waste costs  
 
-2,429 ,345  
 
-2,835,118  -405,772  
Local 
Authorities  Landfill costs  
-100,791   
-141,464  -40,673  
Local 
Authorities  Direct 
littering costs -652,888  -767,870  -114,982  
Society   Indirect 
littering costs -31,032,156  -29,485,645  1,546,511  
Society  Visual 
disamenity of 
beach litter *   3,435,600  
Local 
Authorities  Residual 
waste -1,708,246 -2,087,874  -380,778 Scottish 
Government  Enforcement 
costs 0 -1,194,991  -1,194,991  
Scottish 
Government  Communicati
on costs  0 -289,855  -289,855 
Businesses  Manufacturin
g costs 0 -676,471  -676,471  
Society  Change in 
item costs  -272,665,971  -288,666,681  -16,000,709  
Total   -311,591, 496 -327,46 2,427  -13,738,275  
*The disamenity costs of beach litter could not be separated out into NPVs for the Baseline and Option 1 . 
114. The negative  NPV is mainly dri ven by an increase  in item costs  of £16.0 million , 
reflecting the higher costs of some alternative items compared to the single -use 
plastic items. The model does not take into account any potential changes to 
alternative item costs over time . Scheme enforcement costs are also £1.2 million  
above the Baseline .  
115. Another  driver of costs is item weight s. Alternative products are generally 
heavier than single -use plastic items . For instance, a paper cup weighs on 
average around 11g versus around 3g for its single -use plastic equivalent. The 
waste management costs are assessed on the basis of weight, meaning a higher 
cost for alternative products. The model does not take into account any potential 
changes in the weight of alternative products over the period analysed.  
116. On the other hand, Option 1  has net carbon -related benefits of £1.0 million and  
net benefit of £5 million related to reductions in the indirect costs of  littering , 
demonstrating the environmental benefits  of the policy change .  
117. Error! Reference source not found. 4 presents the net cost impacts  as they 
affect each  stakeholder  group . The model estimates that the largest costs will 
fall onto society, which is mainly driven by the higher prices associated with the 
alternative items, while local authorities will face the smallest costs.  
 
Table 4: NPV impacts  by stakeholder  group  
Stakeholder  NPV under 
baseline (£)  NPV under 
Option 1 (£)  Net change to  
NPV (£)  
Local authorities  -5,060,408  -6,007,567  -947,160  
Scottish Government  0 -1,484,846  -1,484,846 
Society  -306,531,088  -319,970,013  -10,003,325  
All  
-311,591,496   
-327,462,427   
-13,738,275  
 118. Table 5 shows how the  economic  impacts  of market restrictions would be likely 
to vary by item.  
Table 5: NPV impacts by individual item  
Category  NPV under 
Baseline  (£) NPV under 
Option 1  (£) Net change 
to NPV (£)  
Cutlery  -111,837,195  -105,551,998  -6,285,198  
Plates  -59,505,718  -57,071,734  -2,433,984  
Stirrers  -1,835,685  -1,738,353  -97,332  
Straws  -41,112,312  -38,883,191  -2,229,121  
Balloon Sticks  -1,259,853  -1,267,894  8,041  
EPS containers  -75,480,494  -96,586,358  -21,105,864  
EPS cups  -20,412,306  -24,348,255  -3,935,949  
Note: The table above excludes costs and benefits which cannot be separated out by individual item, so the columns do not add  up to the 
total  net NPV  change seen in Table 3 . 
119. The model was found to have particularly sensitivity to  the costs of EPS food 
containers  and their alternatives, and as a result these were given additional 
attention.  
120. Engagement with stakeholders (manufacturers, wholesalers and takeaway 
outlets) indicate d that the most likely alternatives  to EPS food containers were 
fibre-based  containers  (such as bagasse) , which have very similar heat 
retention , grease  and liquid  resistant properties . Depending on the business 
model s adopted by individual takeaway outlets , and the type of food sold, 
paper /card -based  containers might also be considered . The choice of alternative 
container type will be largely influenced by price s. Currently, average prices for 
paper /card -based  food containers are higher than  those for fibre-based  
containers.  
121. Under Option 1 , fibre-based containers have been modelled as the most likely 
alternative s to EPS , due to their better functionality and lower price point than 
paper /card -based containers . In order to test what impacts might result if a share 
of businesses opted to use paper /card -based  containers rather than fibre-based , 
a sensitivity analysis was undertaken. The results are presented in Table 6, 
below.  
 
 Table 6. Market share of non -EPS food containers and NPV impacts  
% fibre-based  % paper/card -
based  EPS container 
NPV (£)  Overall net NPV 
(£) 
80 20 -24,343,429  -16,593,973  
90 10 -22,050,217  -14,300, 761 
100 (Option 1 core 
assumption)  0 -21,487,731  -13,738,275   
122. This shows that if 10% of the EPS food container market switche d to the more 
expensive paper /card -based food containers  rather than fibre-based , an 
additional £0. 6 million would  be added to the net NPV under Option 1. If 20% 
switche d, £2.9 million would  be added.  
123. Presenting the results by item also allows identification of where the most 
significant differences lie in carbon impacts . These results are presented in 
Table 7. 
Table 7: Carbon costs of individual items  
Item NPV under 
Baseline (£)  NPV under Option 
1 (£) Net change to  NPV 
(£)  
Cutlery  534,575  197,694  336,881  
Plates  769,961  586,329  183,632  
Stirrers  8,846  7,245  1,602  
Straws  190,326  125,012  65,313  
Balloon  
sticks  8,667  5,028  3,640  
EPS 
containers  966,436  659,503  306,933  
EPS cups  354,149  236,877  117,271  
Total  2,832,960  1,817,688  1,015,272  
 
124. In terms of carbon  emissions , EPS containers  lead to the greatest reduction 
under  Option 1.  Cutlery is the next most significant item when carbon reductions 
are considered .  
125. Changes to the indirect costs of litter ing are a significant environmental benefit 
of the policy, and Table 8 below demonstrates how each  item contributes to this .  
Table 8: Indirect littering costs for individual items  
Item NPV under 
Baseline (£)  NPV under Option 
1 (£) Net change to  NPV 
(£)  
Cutlery  -16,074,123  -15,204,803  869,320  
Plates  -2,608,828  -2,472,676  136,152  
Stirrers  -111,003  -105,126  5,877  
Straws  -17,751,376  -16,781,639  969,737  
Balloon  
sticks  -89,157  -81,252  7,905  
EPS 
containers  - 6,333,858  -3,354,452  2,979,406  
EPS cups  -2,389,747  -1,930,544  459,203  
Total  -45,358,092  
 -39,930,492  
 5,427,600  
 
 126. The greatest economic benefi t from reduced littering impacts  come s from the 
restriction on EPS food containers , at nearly £3 million. A further £1 million 
results from restricting single -use plastic straws, and £0.9m from cutlery. The re 
is a significant benefit in this cost category because non-plastic alternative 
items degrade much faster than the single -use plastics items they are 
replacing.  
127. Many p lastics , including EPS , are resistant to photodegradation and are  
buoy ant, meaning that plastic  litter eventually accumulates along coastlines, 
becoming an increasingly large component of marine debris. It is estimated 
that plastics contribute towards 50 -80% of beach litter,52 and that food 
containers comprise 1% of plastic beach litter in the UK.53 
128. The analysis above demonstrates that while society is likely to face some 
additional costs from restrictions on EPS food containers and cups, these are 
also the items for which restrictions are expected to result in the largest 
environmental benefits.  
129. Looking at the cost -benefit analysis more broadly, i t is worth noting two 
limitations to the methodo logy, which mean that the costs of the policy change 
may be overstated while the benefits are understated.  
130. First, the assumptions regarding the prices of alternative single -use products 
may be too high, particularly in the later part of the time period und er 
consideration. This is because as market demand for alternative single -use 
products rises, their prices are likely to fall owing to economies of scale and 
product innovation.  If the prices were to fall, the net NPV of Option 1 would 
become  less negative . 
131. Second, the indirect  costs of plastic pollution (which are avoided through this 
policy change) are largely uncounted . Robust data and methodologies are 
lacking to enable cost estimates for the avoided damage to Scotland’s terrestrial 
and marine natural capital, which has knock -on benefits for the tourism, 
transport and fisheries industries as well as human health .54  
6.0 Scottish Firms Impact Test  
132. The Scottish Firms Impact Test considers the impact of the market restrictions 
on specific single -use plastic items on key sectors and groups by consulting 
relevant businesses and business associations, representing businesses of 
varying sizes and from dif ferent sectors.  
 
52 ISWA (2017). Prevent marine plastic litter – now!  
53 OSPAR survey on most commonly found identifiable microplastic items in beach litter in the UK .  
54 Beaumont, N. et al. (2019)  Global ecological, social and economic impacts of marine plastic. Marine 
Pollution Bulletin.  Vol. 142, pp. 189 -195; and Hodal, K (4 Apr 2019)  Marine plastic pollutio n costs the world up 
to $2.5tn a year, researchers find.  The Guardian.  133. The table below summarises the businesses interviewed for the Scottish Firms 
Impact Test. The stakeholders were selected to represent the breadth of the 
sectors and activities potentially affected by the restrictions along the supply 
chain . 
 
Table 9: Summary of organisations interviewed for the Scottish Firms 
Impact Test  
Organisation name Description  Sector  
Food and Drink Federation 
Scotland (FDF Scotland)  Membership body for food 
and drink manufacturers  Food and drink  
 Scottish Wholesale 
Association (SWA), and the 
following member s:  
Bidfood  
Braehead Foods  
Dunn ’s Food & Drinks  Trade association for food 
and drink wholesalers in 
Scotland  Wholesalers; Food and drink  
Bio-based and 
Biodegradable Industries 
Associates (BBIA)  Trade association 
representing producers of 
biodegradable polymers and 
end-products  Plastics/materials  
British Plastics Federation 
(BPF)  Trade association 
representing the UK plastics 
industry  Plastics/materials  
Federation of Small 
Businesses (FSB)  Business organisation 
representing small 
businesses across the 
country  N/A 
 
 
 
134. In addition to engaging with the stakeholders listed in the table above , Zero 
Waste Scotland undertook a telephone survey with a sample of Scottish 
takeaway outlets in late May 2021. A summary of the views expressed is 
presented at the end of this section.  
6.1 Scottish Firms Impact Test results  
135. Below we summarise the responses given by the stakeholders interviewed for 
each of the twelve core questions that were developed for the Scottish Firms 
Impact Test. These interviews were conducted as part of the development of the 
final BRIA.  
136. Question 1  “The Scottish Government is currently consulting on legislation 
aimed at restricting the sale of spec ific single -use plastic items in Scotland. Are you supportive of the introduction of these restrictions? Why (not)? Please give 
your reasons.”  
137. Generally supportive of restrictions  Two respondents (BBIA and FDF 
Scotland) stated that they were generally supp ortive of the proposed market 
restrictions. FDF Scotland cited aligning Scottish policy with the EU Single Use 
Plastics Directive (SUP Directive) as a reason for its views.  
138. Supportive of restrictions with some concerns   
• Concerns over impact on small busine sses  One organisation (FSB) noted 
that while it understood the general objectives of the market  restrictions and 
their importance for advancing the circular economy, at the same time it 
noted some concerns around the potential impacts on smaller businesses  
who may rely more on single -use plastics in their operations than their larger 
counterparts. Further, as the impacts of the COVID -19 pandemic were still 
being felt by businesses, it noted that consideration should be given to 
allowing businesses, and in p articular small businesses, time to recover from 
the effects of the pandemic and crisis, for example through a moratorium on 
new legislation affecting small businesses.  
• Concerns that definitions could limit alternative options  SWA also noted 
that the propo sals included items with plastic or bioplastic lining, as well as 
bio-based and compostable plastic items. The SWA was of the view that if 
these were banned, it would limit availability of alternatives. (Note: the items 
listed here are all considered to be  single -use plastic item s, not alternatives, 
under this proposal as well as the SUP Directive.)  
139. Question 2  “In your opinion how has the use of single -use plastic items covered 
by the market  restrictions changed over recent years (e.g. in the last 5 years)? 
How would you expect the use of these items to change in the next 5 -10 years 
in the absence of the market restrictions being introduced?”  
140. Over recent years there has been a shift away from single -use plastic items  
Four organisations (BBIA, FDF Scotland, FSB and SWA) noted that there had 
been a shift away from single -use plastic items to alternatives. BPF did not have 
a view on market trends.  
141. Larger businesses have seen a greater shift t o alternative products  Two 
organisations (FSB and SWA) reported observing a split between smaller and 
larger organisations in terms of the shift to alternative, non -plastic products 
(including re -usable items), with larger businesses generally seeing a gre ater 
shift.  
142. The decline in the use of single -use plastic items is driven by both 
consumers and businesses   
• FDF Scotland noted that businesses tended to respond to consumer needs, 
whether or not this led to environmentally -friendly outcomes. Pressures such  as branding, ethical considerations and the introduction of similar measures 
in other parts of the UK were identified as factors potentially driving the 
decline in the use of single -use plastics on consumers’ side.  
• The SWA noted that the shift away from s ingle -use plastics was also affected 
by business decisions, for example, to stock and invest in what are viewed 
as more environmentally -friendly products. BBIA stated that consumer and 
retail pressure both played an important role in disincentivising the u se of 
plastics, especially where these were readily substitutable.  
143. The COVID -19 pandemic may impact demand for single -use items  Two 
stakeholders (FSB and BPF) suggested that the current COVID -19 pandemic 
may have altered the downward trend in the use of s ingle -use plastic items, 
though did not provide evidence in support of this assertion. (Note: there is 
insufficient evidence at present to assess trends in single -use items during 
Covid, or to forecast future post -Covid trends.)  
144. Question 3  “In your opinion what will be the biggest potential impacts (both 
costs and benefits) of introducing the market restrictions on your business or on 
those which you represent? Which businesses, in your opinion, will be most 
affected by the restrictions? Please provi de evidence where possible.”  
145. Concerns around the additional costs of manufacturing alternative items 
are limited, as the market has already started to adjust One organisation 
(FDF Scotland) believed that for food and drink businesses, the cost impacts 
asso ciated with changing manufacturing and production processes were likely 
to be the biggest potential impacts. However, in response to Question 4, it further 
stated that some of its larger members had already taken mitigating steps in 
response to the SUP Dir ective , suggesting that further impacts may be limited. 
The BPF noted that the impacts were likely to be limited for its members, 
including EPS manufacturers, as there was not a big manufacturing sector in the 
UK. 
146. Smaller businesses have concerns about add itional costs of alternative 
products  The FSB stated that the most significant impact on its members was 
likely to be costs related to higher prices, as alternative single -use items were 
generally more expensive than single -use plastics. The FSB noted that  these 
additional costs may be passed onto customers. (These concerns are 
addressed in the Competition Assessment  section ).  
147. Businesses dependent on single -use plastic items, including the 
hospitality sector, likely to be most affected  The FSB was of the view that 
businesses producing or relying on single -use plastic items within the scope of 
the restrictions would experience the biggest impacts. The FSB highlighted the 
impact on the hospitality sector, which made use of most of the pro ducts in 
question.  148. Some firms which produce single -use items marketed as alternatives to 
conventional plastic may also be affected  Two organisations (BBIA and 
SWA) noted that due to the proposed list of single -use plastic products to be 
restricted (which a re in line with the SUP Directive) , some firms which produce 
single -use products marketed as environmentally -friendly alternatives to 
conventional single -use plastic  products may also be affected. This included 
businesses whose product range includes some items made fully or partially 
from compostable plastic, which fall within the scope of the market  restrictions, 
though industry has tended to market them as alternatives to plastic.  
149. Customers may face higher costs as a result of the restrictions  One 
respon dent (BPF) suggested that consumers may be most affected by the 
restrictions, as the increased costs to businesses resulting from the higher price 
of alternatives, could be passed onto consumers . These concerns are 
addressed in the Consumer Impact section.  
150. Question 4  “Has your business or have the businesses you represent taken any 
steps to mitigate any anticipated impacts or costs associated with the market 
restrictions? If so, please expand your answer.”  
151. Some larger food and drink businesses have already taken mitigating 
steps  One respondent (FDF Scotland) stated that some of its members had 
already taken mitigating actions in response to the market  restrictions. FDF 
Scotland explained that these actions had —at least in part —been motivated by 
the introduction of the SUP Directive, which had led some larger firms to start 
adapting their production processes elsewhere in Europe. Given the complexity 
around supply chains, these changes would also affect the Scottish market.  
152. No mitigating steps taken , or none known  Four organisations (BBIA, FSB, 
SWA and BPF) stated that the organisations they represent either had not taken 
any mitigating steps or that they were not aware of such actions. The FSB noted 
that mitigation was unlikely to be a top priority f or businesses, since due to 
COVID -19 most small businesses were focused on survival. In addition, it 
suggested that there was probably not much awareness around the market  
restrictions. Nonetheless, it noted that some individual businesses could have 
taken  mitigating steps. Similarly, the SWA was not aware of any mitigating steps 
taken, citing lack of clarity regarding the scope of legislation. However, it noted 
that businesses may have started to bring in more environmentally -friendly 
containers. BPF was n ot aware of significant mitigating steps that had been 
taken among the limited number of EPS manufacturers in the UK.  
153. Question 5  “Does your organisation or association have specific concerns on 
how the restrictions might impact businesses in more remote ar eas of Scotland? 
Please expand on your answer. ” 
154. Small businesses in remote areas may struggle to deal with additional 
costs on top of existing delivery charges FSB stated that  small businesses in more remote areas of Scotland would be in a weaker position to absorb  any 
additional costs associated with the market  restrictions, as they already faced 
higher  delivery charges  than businesses in less remote areas . Any potential 
impacts on more remote areas in Scotland will be address ed in the Island 
Communities Impact Assessment that accompanies  this BRIA.  
155. No concerns  FDF Scotland did not have any specific concerns affecting 
businesses in more remote areas of Scotland, as the alternative items replacing 
single -use plastic item s would go through existing supply chains.  
156. No fixed view  Two respondents (BBIA and BPF) did not express a view on how 
businesses in more remote areas may be affected by the restrictions.  
157. Question 6  “To what extent do you expect the market restrictions to put your 
business, or those which you represent, at a disadvantage, nationally or 
internationally? Please provide evidence where possible.”  
158. No disadvantage nationally or internationally Three organisations (FDF 
Scotland, FSB and BBIA) stated that the introduction o f market  restrictions was 
unlikely to put Scottish firms at a disadvantage either nationally or internationally, 
as similar restrictions were being considered and implemented in other parts of 
the UK (England and Wales) and in the EU. Similarly, the SWA noted that the 
restrictions  would only put wholesalers at a disadvantage if no similar restrictions 
were introduced in the rest of the UK. This was because if restrictions were only 
introduced in Scotland with the rest of the UK unaffected, then manufacturers 
may decide not to produ ce and supply alternative, non -plastic single -use 
products for wholesalers operating in Scotland.  
159. Restrictions could somewhat disadvantage the UK plastics industry  The 
BPF commented that the introduction of market  restrictions should avoid 
penalising plast ic single -use items without a detailed analysis of the potential 
detrimental environmental impacts of the alternatives, to avoid the restrictions 
unfairly disadvantaging the UK plastics industry.  
160. Question 7  “Do you have any concerns about these restrictions affecting 
competition amongst your suppliers, or those of the businesses which you 
represent? If so, could you elaborate?”  
161. Some concerns around smaller producers One organisation (FDF Scotland) 
noted that the restrictions may affect small prod ucers more than larger ones. 
Further, it suggested that smaller manufacturers attaching straws to carton soft 
drink boxes could be particularly affected.  
162. No concerns  Two respondents (BBIA and SWA ) did not state any concerns 
regarding how the restrictions may affect competition amongst suppliers . 
163. No fixed view  Two organisations (FSB and BPF) did not have a particular view 
about how the restrictions may affect competition amongst suppliers. The BPF noted that it did not foresee a big impact on competition within  the UK plastics 
industry.  
164. Question 8  “When the market restrictions come into force, will your business or 
the businesses you represent switch to alternative products, or do you anticipate 
stopping the use, sale or production of the produc ts affected by the restrictions 
altogether? What alternative products will you be producing, using or selling 
instead of single -use plastics? Please expand your answer.”  
165. A significant switch to alternative products  Three organisations (BBIA, FDF 
Scotland a nd BPF) noted that once the restrictions were in force, there would be 
a significant shift to alternatives such as paper. Nonetheless, the BBIA noted 
that these alternatives would also need some form of lining to ensure that they 
provided appropriate greas e and moisture protection.  
166. Switch depends on the alternatives available  The SWA noted that the extent 
of the switch would depend on what the available alternatives were once the 
restrictions came into force . For example, it noted that some businesses may 
use bagasse instead of plastic, but single -use items usually required some form 
of plastic lining.  
167. Extent of the switch will vary by nature of business The FSB was of the view 
that the extent to which businesses would switch to using alternative products 
would vary across different types of business. For example, take -away 
restaurants and businesses serving people on the go would need to provide 
alternative single -use items to customers buying food and drink, while 
businesses involved in home delivery would have the option to ask customers 
whether or not some of these products were needed, reducing their overall use.  
168. Question 9 “If your business or the businesses you r epresent will be substituting 
single -use plastic items covered by the restrictions with alternative products (as 
part of your sales or production), how quickly do you expect this transition to 
take place? Do you anticipate any difficulties prior to or duri ng this transition? 
Please expand your answer.”  
169. Short transition period  One organisation (BBIA) was of the view that the 
industry had the capacity to transition quickly, in a matter of months, once the 
restrictions were introduced.  
170. Grace period needed to allow businesses to sell existing stock  Three 
organisations (FDF Scotland, FSB, and SWA) did not have a fixed view on how 
long the transition from single -use plastic items to alternatives may last. Both 
FDF Scotland and the FSB noted  that businesses affect ed by the restrictions 
would need time  to sell their existing stocks of single -use plastic items. Both 
organisations were in favour of introducing a grace period, in particular for  small 
companies . 171. No specific views on transition period  The BPF had no spec ific views around 
transition times as it did not have many members involved in the manufacturing 
or use of these items.  
172. Question 10  “If you are planning to switch to alternative products, do you expect 
final consumers to notice the change and adjust their  purchasing behaviour as 
a result of the change? For example, would you expect them to buy less (e.g. 
because of reduced convenience) or more (because of increased environmental 
friendliness) of the final product or be willing to pay less or more for it?”  
173. Consumers likely to  notice change ; reaction may depend on performance 
of alternatives  Two respondents (FDF Scotland and BPF) cited anecdotal 
evidence around the alternative straws already on the market as evidence that 
consumers were likely to notice and adjust their purchasing behaviour in 
response to a switch to alternatives. FDF Scotland noted that the carton straws 
introduced by McDonald’s did not receive positive feedback from customers 
initially.  
174. Changes in consumer behaviour would depend on pric e impacts Two 
organisations (FSB and BPF) noted that the extent to which consumers would 
notice the change and adjust their purchasing behaviour may depend on the 
price impacts of the switch to alternatives . 
175. Media campaigns could  help consumers to adjust The FSB considered that 
appropriate media campaigns were needed to ensure that customers 
understood why the change was happening and what the change would mean 
for them (for example, which single -use plastic  items would no longer be 
available). It believed that such campaigns would ease the transition for 
consumers and businesses alike.  
176. No fixed view  One organisation (BBIA) did not have any specific views on how 
consumers may change their behaviour as a result of the restrictions.  
177. Question 1 1 “What unintend ed consequences do you anticipate for your 
business or the businesses you represent as a result of the restrictions?”  
178. Ensuring access to single -use plastic  products by vulnerable customers  
The BBIA noted potential issues around ensuring that vulnerable cus tomers 
reliant on single -use plastic  items, such as straws, for medical reasons would 
continue to be able to access these. For example, the BBIA thought that linking 
medical straws to prescriptions may help to ensure that vulnerable customers 
could continu e to be served. (This issue has been addressed in the Equalities 
Impact Assessment.)  
179. Increased environmental impacts  The BPF noted that one potential 
unintended consequence could be a bigger environmental impact, for example 
if alternatives were less recyclable and had a higher footprint. Further, the BPF 
also commented that consumers may assume that biodegradable mater ials were safer for the environment, and therefore these items may be more likely to 
be littered.  (See the Strategic Environmental Assessment for information on this 
point.)  
180. Finally, the businesses interviewed were also given the chance to add 
anything that was not covered by the questions above.  
181. The following additional considerations emerged:  
182. Need to evaluate the cumulative burden and cost of the policy : FDF 
Scotland noted that when the market restrictions were  introduced, any 
assessment would  need to look at the cumulative burden and cost of this and 
other related policies  which may have impacted similar groups of stakeholders , 
for example the Scottish deposit return scheme.  
 
183. Scope to find suitable alternative products : The SWA noted that the 
introduction of market  restrictions would need to give enough scope for the 
businesses and sectors affected to find suitable alternatives to single -use 
plastic products. It was keen for  the restrictions to align with the EU SUPD, and 
also suggested considering  the examples of Italy and Portugal, which have 
exempted more  compostable single -use plastic items  when implementing the 
EU SUPD . (Note: the research for this BRIA and the Strategic  Environmental 
Assessment identified suitable alternatives for all the items without including 
compostable single -use plastics.)  
 
6.2 Supplementary business research on EPS food containers  
184. In addition to the busi ness consultation , a telephone survey of Scottish 
takeaway  outlets  was conducted to provide insight into the switch away from 
EPS food containers to most -likely alternatives. This supplementary research 
was conducted owing to the importan ce of EPS food container prices , and the 
prices of their alternatives, to the  overall cost impact of the proposed policy 
change.  
185. In total, 47 takeaway  outlets  were contacted  in various locations across 
Scotland. There was a relatively low response rate but 7 agreed to share 
information on their use of food containers. The respondents were a mix of 
takeaway owners, managers, and staff. Therefore, the applicability of certain 
questions varied from outlet to outlet.  
186. Question  1. “Were you aware of the ban on EPS food containers due to come 
into force in 2022 ?” 
187. In response, 4 out of the 7 takeaways  were aware  of the ban and had 
considered some of the implications for their business . 
188. Question 2 . “What materials do you use for your takeaway food containers?”   189. The 2 takeaways that were using EPS for all their products had never used 
non-plastic  alternatives. 5 takeaways  were  using non-plastic alternative 
products of a range of materials  including cardboard, bagasse, and other 
biodegradable materials.  
190. Of the 5 takeaways which were using alternative materials:  
• 1 takeaway said they use d biodegradable boxes for fish and chicken meals 
but clear plastic tubs for curr ies and other liquids.  
• 1 takeaway said they had been using EPS previously but switched to  
alternatives in the past 6 -8 weeks.  
• 1 takeaway said it used biodegradable boxes from  a leading supplier of 
bagasse containers  and ha d never used EPS. Every single -use  item sold 
was (as far as possible) biodegradable material including cutlery and ice 
cream tubs.  
• 1 takeaway said it used recycled  cardboard boxes for food containers and 
had never used EPS.  
• 1 takeaway said it used biodegradable boxes only.  
 
191. Question 3 . “Have you looked at what alternative food containers might be 
suitable for your business?”  
192. One of the 2 takeaways who were currently using EPS was able to provide 
information on what alternative products might be available for their business. 
They stated  that “ bio-boxes” were the most suitable alternative s for EPS, as 
other s, made from basic cardboard for example, were not a suitable 
replacement for EPS in terms of functionality.  
193. Question 4 . “What do you typically pay for your EPS food containers  and how 
does this c ompare with the price for non -EPS alternative s?” 
194. The takeaways contacted were reluctant to reveal specific data on the prices 
paid due to the commercially  sensitive nature of this information , but 3 out of 7 
respondents said  that non -EPS containers were more expensive . One 
respondent , who used to use EPS and has recently switched to biodegradable 
containers,  indicat ed that for his business , paper/card -based food containers 
were around twice the price of equivalent EPS containers.  
195. In addition to specific information  on container prices , 3 takeaways commented  
on the extent to which any additional costs could be passed onto consumers if 
there was a switch in container type.  One respondent  said that it would pass 
on the price of an increase in container  costs by 5 -10p per meal . One 
takeaway said it would not pass on any price increase to consumers, as it saw 
meal prices  as being exclusive of packaging  prices and would therefore absorb 
the cost . One takeaway said that they would expect the cost of meals to rise somewhat from a change from EPS to alternative  containers  but were not 
concerned about the impact on their levels of business of profitability.  
196. Three  takeaways cited environmental concerns in relation to EPS containers. 
One takeaway (which use d only EPS containers ) was supportive of the policy 
as they want ed to help the environment and dislike d the litter impact of EPS 
containers in the area surrounding their business. One takeaway (which 
formerly used EPS  containers ) stated that it had switched to alternative 
products due to customer complaints about the env ironmental impact of EPS 
containers. One takeaway (which formerly used EPS  containers ) said they had  
made the switch to alternative products as the business owner wanted to help 
the environment by doing so.  
197. Two respondents  expressed an  opinion on the proposed policy. One said that 
it didn’t have any issues with the policy itself but hope d that the Scottish 
Government would provide financial support to small businesses such as their  
own to alleviate any potential negative impacts on business. One said it was 
not concerned about any potential negative impacts of the policy.  
 
 
7.0  Competition Assessment  
198. This assessment follows the BRIA toolkit for the Competition Assessment, which 
is based on the Competition Checklist component of the Competition and 
Markets Authority’s (CMA’s) Competition Impact Assessment guidelines.55 
These guidelines recommend considering four key questions in order to assess 
whether a proposed policy would have an impact on competition. These are:  
• Will the measure directly or indirectly limit the number or range of 
suppliers?  
• Will the measure limit t he ability of suppliers to compete?  
• Will the measure limit suppliers’ incentives to compete vigorously?  
• Will the measure limit the choices and information available to 
consumers?  
199. The questions are answered with reference to a set of sub -questions defined b y 
the CMA that are considered relevant for each level of the supply chain 
(upstream, distribution and downstream).  
7.1 Identifying relevant markets  
200. The markets and stakeholders that may be affected by the restrictions can be 
divided into three levels of the supply chain:  
 
55 Competition and Markets Authority  (2015) Competition impact assessment: guidelines for policymakers .  
Table 10. Identification of relevant markets  
Supply 
chain level  Definition  Example of stakeholder 
types  
Upstream  Firms that support the manufacture and 
import of single -use plastic  products to be 
restricted and alternative items, as well as 
suppliers of raw materials, equipment,  and 
plastics additives.  Manufacturers, importers.  
Distribution  Firms involved in distributing single -use 
items to those that need them. This 
includes packaging wholesalers as well as 
high street retailers.  Catering wholesalers, 
supermarkets, convenience 
stores.  
Downstream  Firms that use single -use items in their 
provision of goods and services. There may 
also be a small number of innovative firms 
that convert plastic products for other uses 
that may be affected.  Hospitality sale of food and 
drinks, chain restaurants, 
cafes, mobile food services, 
and catering businesses.   
 
7.2 Overview of markets affected by single -use plastic  restrictions  
201. This section looks at the value chain of the Scottish market for the relevant  
single -use plastic  products, and for their most -likely alternatives. It presents 
data, to the extent that it is available, on whether Scottish businesses are active 
stakeholders at each stage of the value chain, enabling the identification of the 
stakehol ders which are most likely to be impacted by the policy change.   
202. Upstream : The manufacturing of single -use plastic  products in Scotland takes 
place within the wider manufacture of plastic and rubber products sector. This 
sector is tracked by the Scottish Government and has aggregate data published 
in the annual “Businesses in Scotland” publication (2020). More granula r data 
on the production of specific single -use plastic  product types are not available.  
 
203. A summary of the available data showing trends in the Scottish plastic and 
rubber products sector is provided in  
204.  
205.  
206. Figure 1, below.  The number of Scottish firms in this sector declined sharply 
between 2010 and 2012 before levelling off and beginning a slower decline to 
2020. The size of the workforce has decreased somewhat in step with the 
reduction in firms.   
 
 
Figure 1: Scottish plastic and rubber sector summary (all plastic products, 
including single -use plastic s) 
 Number of firms in Scotland  Employment  
 
 
 
 
 
 
 
 
 
                    
Annual sector turnover, £m                                                                 
 
 
 
 
 
 
Source: Europe Economics analysis, based on Scottish Government (2020) “Businesses in Scotland”56 
 
 
207. The following analysis looks at three main segments: producers of polymers 
which could be used as inputs for the relevant single -use plastic  items; 
producers of the single -use plastic  items excluding EPS products; and producers 
of EPS products.  
208. Producers o f polymers for single -use plastic s: In 2017, Scotland was 
responsible for approximately 30 per cent of relevant polymers made in the UK,57 
though it accounted for just 5 per cent of plastics and rubber firms in the UK.58  
This raises a question around whether Scottish polymer producers could be 
impacted by the restrictions. According to the British Plastics Federation (BPF), 
 
56 Scottish Government (2020) Businesses in Scotland: 2020 . 
57 Law, P. (2017) Scotland’s plastics industry: Crucial to the overall sector , Interplas Insights . 
58 British Plastics Foundation (2021) Members Directory 2020 -21. 220230240250260270280290300
 1,000 1,100 1,200 1,300 1,400 1,500 1,600 1,700
 100,000 150,000 200,000 250,000 300,000
Productivity: Plastics
Productivity: Manufacturing 8,000 8,200 8,400 8,600 8,800 9,000 9,200 9,400just two firms i n Scotland may be driving this polymer production: Ineos Olefins 
and Polymers (capacity: 615,000 tonnes p.a.) and PET Processors (UK) LLC 
(capacity: 20,000 tonnes p.a.). Both produce a range of products in addition to 
potential inputs to the single -use pla stic items in question.59  
209. It was not possible to find data on the extent to which polymers produced 
domestically are used for the production of the relevant single -use plastic  items 
in Scotland, nor the extent to which end products produced from them are 
consumed domestically. However, the evidence suggests that local producers 
of relevant items only represent a small share of demand for locally -produced 
polymer.  
210. First, there is only a small single -use plastic manufacturing presence in Scotland 
(see below : ‘Producers of single -use plastic  items excluding EPS’). Second, 
research conducted for Defra indicates that a majority of the relevant single -use 
plastic  products consumed in the UK are imported.60 Finally, the volumes 
involved are considered. According to the Strategic Environmental Assessment 
for this policy change, the total weight of relevant single -use plastic  items used 
in Scotland in 2020 was 1,848 tonnes,61 equivalent to just 0.3% of the total 
weight of polymers produced each year by the two domes tic producers noted 
above. It is concluded that Scottish polymer producers are unlikely to experience 
significant impacts from the policy change.  
211. Producers of single -use plastic  items excluding EPS Recent research 
conducted for Defra indicated that imports  of single -use plastic  products into the 
UK as a whole accounted for:62   
• 90% of cutlery, plates, balloon sticks.  
• 95% of straws, cotton buds and stirrers.  
 
212. Desk research identified a number of manufacturers of relevant single -use 
plastic  items, as well as some firms that manufacture alternatives. Both types of 
firm are shown in the following table. This information was retrieved via online 
 
59 British  Plastics Foundation (n.d.) About the British Plastic Industry.  The two polymer manufacturers are Ineos 
Olefins & Polymers (Grangemouth; polymers include Polyethylene High Density/Linear Low Densi ty [HD / 
LLDPE swing], Polypropylene) and PET Processors (UK) LLC (Dumfries; polymers include Polyethylene 
Terephthalate [PET]).  
60 Resource Future s on behalf of Defra (2018a): A preliminary assessment of the economic impacts of a 
potential ban on plastic cutlery, plastic plates and plastic balloon sticks , A preliminary assessment of the 
economic, environmental and social impacts of a potential ban on pla stic straws, plastic stem cotton buds and 
plastics drinks stirrers , and Resource Futures on behalf of Defra (2019) A preliminar y assessment of the 
economic impacts of a potential ban on expanded polystyrene food and beverage containers .  
61 Scottish Government (2020) Introducing ma rket restrictions on problematic single -use plastic items in 
Scotland: Strategic Environmental Assessment (SEA).  
62 Resource Future s on behalf of Defra (2018a): A preliminary assessment of the economic impacts of a 
potential ban on plastic cutlery, plastic plates and plastic balloon sticks , A preliminary assessment of the 
economic, environmental and social impacts of a potential ban on plastic straws, plastic stem cotton buds and 
plastics drinks stirrers , and Resource Futures on be half of Defra (2019) A preliminary assessment of the 
economic impacts of a potential ban on expanded polystyrene food and bever age containers . searches for manufa cturers in Scotland, manually reviewing the items they 
produce. In all cases, the products listed in column three appear to account for 
a small proportion of the offering of each firm, though it is not possible to identify 
the precise relative importance o f sales of the single -use plastic  items.  
Table 11. Manufacturers of single -use plastic and alternative products 
identified in Scotland  
Company  Materials  Products  Area  
Tri-Star Polypropylene , 
cardboard , wood Cups, food boxes, 
and cutlery  Glasgow  
Kimberly Watson 
Packaging   Plastic  Trays for baked 
goods  Livingston , West 
Lothian  
Streetfood 
Packaging  Plastic , alternative  
materials  
(cardboard, palm 
leaf) Food and beverage 
cups , trays and 
boxes  Aberdeen  
Vegware  Wood, paper, 
bagasse, products 
coated in plastics  Straws, plates, 
cutlery, food 
containers, and cups  Edinburgh  
Cullen  Moulded pulp , 
corrugate  Food and beverage 
containers  Glasgow  
Eco Pack Scotland  Bagasse, recycled 
plastics  Food and beverage 
containers  Edinburgh  
Verona Eco  Paper, board  Food and beverage 
containers, trays, 
and pots  East Kilbride  
 
213. Given that 90 -95% of single -use plastic  cutlery, plates, balloon sticks. straws 
and stirrers are imported into the UK (and we found no evidence that this differs 
materially for Scotland), it is concluded that manufacturing of the relevant 
products does not form a significant part of the Scottis h value chain for single -
use plastic  products. One firm which was identified through stakeholder 
engagement as being affected was Vegware, which produces some lines of 
cutlery and straws that fall in scope of the regulations but a significant proportion 
of its business is pr oduction of non -EPS food and beverage containers which 
will benefit from the market restrictions . 
214. Producers of EPS items : The Defra research cited above found that imports 
into the UK accounted for just 5% of EPS food and beverage contai ners.63 This 
 
63 Resource Future s on behalf of Defra (2018a): A preliminary assessment of the economic impacts of a 
potential ban on plastic cutlery, plastic plates and plastic balloon sticks , A preliminary assessment of the 
 suggests that a large share of the relevant EPS items is produced within the UK. 
A 2019 Defra impact assessment found that there were just four EPS plants 
involved in the manufacture of relevant single -use plastic  items in the UK as a 
whole.64 We sou ght to identify whether any Scottish EPS manufacturers would 
be affected. This involved two main streams of research.  
215. First, via desk research we explored whether we could identify relevant EPS 
manufacturers operating in Scotland. We did find a number of f irms operating in 
Scotland that produce EPS products, but their product offerings covered larger 
items, such as EPS products for large -scale insulation, that did not fall within the 
scope of the restrictions.65 It is possible that some of these firms have side-lines 
in producing smaller EPS items, but this could not be verified.  
216. Second, we asked stakeholders to identify any manufacturers of relevant EPS 
products operating within Scotland. The British Plastics Federation was not 
aware of any producers of sin gle-use items in Scotland and suggested that if 
there were any such producers, their share of total plastics production in 
Scotland would be very small.   
217. Third , Zero Waste Scotland discussions with representatives from the Scottish 
EPS manufacturing sector66 revealed that virtually all manufacturing of the target 
EPS containers  had ceased in Scotland due to the low economic returns 
available for producing these items domestically and a growing acceptance that 
market restrictions on prob lematic single -use plastic items would be 
implemented.  
218. It is concluded that the majority of in -scope EPS items are imported into Scotland 
from elsewhere in the UK.  
219. Distribution : Further down the value chain are distributors and retailers of 
single -use plastic  items and their alternatives to consumers, both in the 
hospitality trade and in private households. The table below shows a selection 
of distributors and retailers known to b e operating in Scotland based on online 
research. The market includes three smaller, family -run businesses (Morrison’s 
 
economic, environmental and social impacts of a potential ban on plastic straws, plastic stem cotton buds and 
plastics drinks stirrers ; and Resource Futures on behalf of Defra (2019) A preliminary assessment of the 
economic impacts of a potential ban on expanded polystyrene food and beverage containers . 
64 Resource Futures on behalf of Defra (2019) A preliminary assessment of the economic impacts of a potential 
ban on expanded polystyrene food and beverage containers .  
65 The BPF Expanded Polystyrene Group (n.d.) Find a supplier . Producers identified are: Engineered Foam 
Products (Livingston), Moulde d Foams (Cumbernauld, Stornoway, Peterhead), Sundolitt (Corpach, Montrose , 
Stirling), Thulecraft ( Lerwick ). Email correspondence with the firms confirmed that Sundolitt does not produce 
any of the items in scope (the others were contacted but did not respo nd to our request).  
66 Sundollit. 19/04/2021  Food Services, Scottish Disposable Supplies and RBR Supplies) competing 
alongside large multinational firms.  
 
220. The single -use plastic  items in the scope of the restrictions, the majority of which 
are provided to customers alongside food products, tend to comprise only a 
small part of the catalogues of catering distributors. Many of these firms also 
currently sell alternatives to single -use plastic  items. It is concluded that a 
handful of actors of different sizes at this level of the value chain in Scotland will 
be affected by the restrictions, though it will only affect a small part of their overall 
business.  
 
Table 12: Examples of wholesalers and distributors operating in Scotland  
Company  Description  Examples of items sold  
James Kidd  One of Scotland’s largest independent  
distributors of catering supplies and 
equipment.  Packaging made of plastic, 
polystyrene, and alternatives 
includ ing bagasse, paper/card 
and moulded fibre.  
Morrison’s 
Food 
Services  A family -run business originally 
established to supply food items to the 
food service sector, since expanding to 
provide a variety of food containers.  Polystyrene and cardboard food 
trays as well as bagasse items.  
Scottish 
Disposable 
Supplies  An independ ent supplier of catering 
disposables.  Plastic and polystyrene food 
containers, paper plates.  
RBR 
Supplies  A family -run distributor of catering 
cleaning supplies based in the West of 
Scotland that has begun to supply 
disposable cutlery and crockery.  Plastic cutlery and stirrers, 
plastic cups, Vegware 
compostables.  
Nisbets  With three locations in Scotland, the 
largest supplier of catering equipment 
in the UK sells various catering and 
kitchenware to all end -consumers.  Wide range of plates, 
containers and cutlery, both 
plastic and non -plastic, as well 
as compostable products .  
Bidfood 
Scotland  A subsidiary of the international Bidfood 
UK company, Bidfood Scotland sources 
items from large multinationals and 
small ‘artisan’ producers.  Expanded polystyrene food 
containers, newspaper boxes, 
bagasse items, plastic and 
wooden cutl ery. 
 221. Downstream: Other Scotland -based firms impacted by the introduction of 
market  restrictions are those in the food and beverage service sector. These 
firms provide food or drinks fit for immediate consumption in traditional, self -
service or take -away restaurants and cafés, whether as permanent or temporary 
set-ups and with or without  seating.67 Many of these provide take -away food and 
beverages that are likely to be served in the single -use plastic  products within 
the scope of the restrictions: there were 3,50 5 take-away businesses in Scotland 
as of 2018.68 The Scottish Government’s Businesses in Scotland  publication 
indicates that small and micro businesses account for 97.7 per cent of the firms 
in the food and beverage sector, the majority of these employing fewer than ten 
employees (see  
Figure  2). 
222. Table 14 shows that take -aways account for 33% of the total number businesses 
supplying food and beverages  in Scotland . Licensed restaurants and cafes 
account for 25% and unlicensed restaurants and cafes for 23%.  
 
Figure 2: Number of firms in the food and beverage service sector in 
Scotland, by size category  
 
Source: Europe Economics analysis of Scottish Government (2020) “Businesses in Scotland” . Food and Beverage Service Activities. 69 
223.  
Figure  2 also shows the steady growth of the number of firms in the food service 
sector. Prior to the Covid -19 pandemic, the takeaway food market had enjoyed 
significant growth in Scotland in recent ye ars. Between 2010 and 2018, the 
number of takeaway firms in Scotland increased by 28 per cent, and in 2018 the 
average household spent £244 on takeaways consumed at home.70 In the three 
years to 2019, the UK takeaway sector doubled in size.71 It is concluded that 
there is a sizeable market in Scotland at this level of the value chain,  some of 
which  will be impacted by the proposed restrictions.  
Table 13. Scot tish food outlets  and s ervices (2018)   - 2,500 5,000 7,500 10,000 12,500
2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020
Micro (0-9) Small (10-49) Medium (50-249) Large (>250)SIC Sector  Number  
56.10/3 Takeaways & food stands  3,505  
56.10/1 Licensed restaurants & cafes 2,725  
56.10/2 Unlicensed restaurants & cafes 2,440  
56.2 Events & outdoor catering  1,220  
56.21 Other food services  850 
Total  10,740  
Source: ONS, Nomis Database . 
 
7.3 Detailed Competition Assessment  
Will the measure directly or indirectly limit the number or range of suppliers?  
224. This question aims to identify, and where possible quantify, potential impacts 
of the policy change on limiting the number and range of suppliers in Scotland, 
with a view to assessing potential impacts on the prices and available choices 
of the relevant single-use plastic  items and their most -likely alternatives to 
consumers in Scotland.   
225. The following paragraphs aim to answer this question in line with the CMA 
guidance. It considers the possibility of direct and indirect impacts separately, 
for which a set  of relevant sub -questions are answered (based on the issues 
suggested by the CMA). The sub -questions are as follows:  
226. Direct impacts  
• Does the measure award exclusive rights to supply?  
• Does the measure require procurement from a single supplier or a 
restric ted group of suppliers?  
• Does the measure create a licensing scheme that limits the number of 
suppliers?  
• Does the measure create a licensing scheme for quality standards?  
227. Indirect impacts  
• Does the measure significantly raise the costs of incumbent firms, c ausing 
them to exit the market?  
 
67 ONS (2009) UK Standard Industrial Classification of Economic Acti vities 2007 (SIC 2007), Main volume.  
68 SPICe ( Scottish Parliament Information Centre ) Spotlight (2019) Fast food booming – a cause for concern?  
69 Scottish Govern ment (2020) Businesses in Scotland: 2020 .  
70 SPICe ( Scottish Parliament Information Centre ) Spotlight (2019) Fast food booming – a cause for concern?  
71 British Takeaway Campaign (2019) Cooking up growth, Serving up talent . • Does the measure significantly raise the costs of new suppliers (including 
small businesses) relative to existing suppliers?  
• Does the measure significantly raise the costs of some existing suppliers 
relative to other existin g suppliers?  
UPSTREAM  
Direct impacts  
228. The Scottish Government is restricting manufacture of all the relevant single -
use plastic items except for straws and balloon sticks.  However, neither the 
proposed restrictions on supply, nor any potential restrictions on manufacture, 
explicitly aim to restrict the number or range of manufacturers of any specific 
item through:  
• Awarding exclusive rights of supply;  
• Requiring procurement from a single supplier or a restricted group of 
suppliers;  
• Introducing a licensing scheme for suppliers or quality standards.  
• It is therefore concluded that there are no direct competition impacts  
Indirect impacts  
Does the measure significantly raise the costs of incumbent firms, causing 
them to exit the market?  
229. The market restrictions are unlikely to significantly raise the costs of 
incumbent firms, causing them to exit the market. There may be some costs 
for adapting production to  alternatives, but the small number of single -use 
plastic -producing firms in Scotland suggests that this would not affect many 
firms. These points are explained in what follows.  
230. The high import share in the single -use plastic  market in the UK, and the 
market overview in Section 6.2, suggests there are not many manufacturers 
of single -use plastic  products in Scotland that would be affected. We can 
estimate the extent to which this is the case by combining the aforementioned 
import proportions with estimates  of annual consumption quantities of the 
various single -use plastic  products. We find that 19.8 per cent of domestically 
consumed single -use plastic  products may be produced domestically, the 
majority of which are EPS containers (see table below). However, the EPS 
containers account for less than 15 per cent of the single -use plastic s 
consumed in Scotland, and – given the research finding of there bei ng zero 
manufacturers of EPS single -use plastic s in Scotland – excluding them 
reduces the estimated proportion of consumed single -use plastic s to 6.2 per 
cent. Moreover, these domestically produced single -use plastic  products 
represent just 0.29 per cent o f the turnover of the plastics and rubber 
manufacturing sector in Scotland in 2020 (when EPS are excluded, this drops to only 0.1 per cent).72 Therefore, it is reasonable to suggest that knock -on 
effects of a drop in demand for single -use plastic  products would affect only a 
small number of Scottish manufacturers. These firms could choose to  exit the 
market or adapt processes to alternative products.  
Table 14. Estimated quantities of single -use plastic  products produced 
domestically  
Single -use 
plastic  products  Estimated 
consumption in 
Scotland 
(million, per 
year)  Share of single -
use plastics  
consumed in 
Scotland  (%) Estimated 
number 
produced 
domestically 
(million, per 
year)  Estimated 
number 
produced 
domestically 
(million, per 
year) assuming 
zero EPS/XPS 
manufacturers  
Balloon sticks  1.7 0.2 0.17 0.17 
Straws  300 38.6 15 15 
Cutlery  276 35.5 27.6 27.6 
Stirrers  9.9 1.3 0.495  0.495  
Plates (incl. 
trays and 
bowls)  50 6.4 5 5 
EPS food 
containers  66 8.5 62.7 0 
EPS drinks 
containers  45 5.8 42.75  0 
Produced 
domestically 
(% of 
consumed 
single -use 
plastic s) - - 19.8 6.2 
 
 
231. The restrictions are likely to indirectly accelerate the market for alternative 
products by encouraging existing manufacturers of single -use plastic  items 
 
72 Based on sector turnover data from Scottish Government (2020) Businesses in Scotland: 2020 ; and unit 
price data from Welsh Government (2020) Preliminary research to assess the impacts of a ban or restrictions 
in sale in Wales of items in the EU's Single Use Plastics Directive .  and alternatives to maintain their position in the production of these types of 
products by adjusting  production towards alternatives more exclusively. Some 
existing manufacturers of single -use plastic s may be able to adapt production 
to satisfy the demand for alternative products – at a cost. Two stakeholders 
who responded for the Scottish Firms Impact T est suggested that the cost 
impacts associated with changing manufacturing and production processes 
are likely to be the biggest potential impacts of the restrictions. Three studies 
for Defra on the impact of similar restrictions in the UK have estimated t he 
total costs to business of implementing them over a ten -year period, during 
which manufacturers of single -use plastic s experience a gradual reduction in 
sales. These are reported in Table 15 below.  
232. The business implementation costs include the annual cost of implementing 
the restrictions over the period, as well as one -off capital costs for all but the 
EPS products (for which costs are reported separately in the table as 
significant capital investments). The annual costs of implementing the 
restrictions would be expected to involve the following for manufacturers:73 
233. Transition costs: costs involved in refocusing production towards alternative 
single -use items, which may be low and involve relatively short timescales for 
existing suppliers of alte rnatives . 
234. Overproduction costs: The costs of manufacturers sitting on redundant 
warehoused single -use plastic s upon the implementation of restrictions, which 
could be minimised if clear timescales are provided in advance.  
235. Scale costs: the costs involved in scaling -up production of non -EPS single -
use items (these costs were not reported in the Defra study of EPS products, 
so we assume that they are not applicable to EPS producers; moreover, the 
lack of EPS single -use plastic s producers in Scotland suggests that they are 
not relevant). Research for Defra suggests that economies of scale would be 
possible in the event of the single -use plastic  ban being considered in 
England.74 Consulted stakeholders did not indicate the nature  of additional 
costs (e.g. labour, materials)  
236. It has been previously highlighted  that EPS single -use plastic s are produced 
domestically in the UK (but not in Scotland), whereas the other single -use 
plastic  items in scope are largely imported. The modelling  for the UK assumed 
that a one -off capital investment would be needed to convert existing EPS 
packaging manufacturing capacity or establish new packaging production 
capacity for EPS -free products. Stakeholders suggested that capital costs 
 
73 Resource Fut ures on behalf of Defra (2018a): A preliminary assessment of the economic impacts of a 
potential ban on plastic cutlery, plastic plate s and plastic balloon sticks , A preliminary assessment of the 
economic, environmental and socia l impacts of a potential ban on plastic straws, plastic stem cotton buds and 
plastics drinks stirrers ; and Resource Futures on behalf of Defra (2019) A preliminary assessment of the 
economic impacts of a potential ban on expanded polystyrene food and beverage containers . 
74 Resource Futures on behalf of Defra (2019) A preliminary assessment of the economic impacts of a potential 
ban on expanded polystyrene food and beverage containers . could amount to £ 30m per plant.75 The capital costs are displayed separately 
for the EPS product categories in the following table.  
 
 
Table 15. Business implementation costs of a ban over the period 2019 -
2028 in the UK  
Item Business implementation 
cost for all types of 
businesses NPV 2019 -28 
(£m)  One-off capital 
investment for 
manufactures (£m)  
Cutlery  3.1a  
Plates  0.8a  
Straws  2.3b  
Drink stirrers  1b  
Balloon sticks  0.2a  
EPS food containers  2.4c 47.7c 
EPS beverage containers  1.7c 68.1c 
 
237. Based on the figures presented in Error! Reference source not found. 15, 
the cost to the few manufacturers of single -use plastics  in Scotland of 
transitioning to alternative products is likely to be relatively low. This is 
because the business implementation costs are generally low (considering 
that the figures are spread across all businesses in the UK ) and no EPS 
manufacturers hav e been identified in Scotland (so the one -off capital 
investment costs do not apply).  
238. Furthermore, that plastic polymer production in Scotland does not appear to 
contribute to the Scottish manufacture of single -use plastic s suggests that 
firms involved in  polymer production would not face costs due to the market 
restrictions . 
Does the measure significantly raise the costs of new suppliers (including 
small businesses) relative to existing suppliers?  
239. The market restrictions are unlikely to significantly raise the costs of new 
suppliers relative to existing suppliers.  
 
75 Resou rce Futures on behalf of Defra (2019) A preliminary assessment of the economic impacts of a potential 
ban on expanded polystyre ne food and beverage containers . The £30m figure is based on the sum of the 
capital costs for the two EPS product categories (47.7 + 68.1 = 115.8) distributed evenly between the four 
known EPS manufacturing facilities in the UK: £28.95m.  240. Recognising the potential profit to be made in the market for these types of 
products upon the market restriction of the single -use plastic  variants, there 
may be market entry o f new manufactures of alternatives. This may also offset 
any potential indirect reduction in the number of manufacturers caused by the 
restrictions. Scotland does not currently have a particularly large wood and 
paper products industry (it is the smallest manufacturing subdivision in terms 
of 2018 gross value added)76 – a sector that could be expected to satisfy the 
demand for alternative packaging products when the restrictions begin. The 
sector is however nearly twice as productive per manufacturing secto r worker 
as the same sector in England,77 potentially giving it a competitiveness 
advantage over English manufacturers in satisfying the demand. And the 
current existence of successful eco -friendly packaging firms in Scotland, such 
as Cullen and Eco Pack S cotland, suggests that opportunities for new market 
entries could arise.  
DISTRIBUTION  
Does the measure significantly raise the costs of incumbent firms, causing 
them to exit the market?  
241. There would be a degree of familiarisation costs associated with the 
restrictions. The introduction of the legislative restrictions would cause a 
period of adjustment to the new regime for all firms involved in the sale of 
single -use plastic  products domes tically. This is unlikely to threaten the 
number of distributors in the market.  
242. The number of wholesalers and distributors of single -use plastic  products is 
unlikely to be significantly impacted by costs unless (directly or indirectly) any 
of these deal pr edominantly in the restricted single -use plastic  products and 
face issues in sourcing alternatives or significant cost increases that they 
cannot pass on to customers. This assessment has identified a number of 
Scotland -based manufacturers of alternative p roducts for food service 
activities, so difficulties in sourcing alternatives may stem from alternative 
manufacturers’ capacity constraints rather than from difficulties in locating 
manufacturers. Balloon sticks may be harder to source, as the market 
overv iew did not identify any domestic manufacturers of them (plastic or 
otherwise), but the small number consumed annually suggests that this may 
not threaten the revenues of distributors to a great extent.  
243. The single -use plastic  items in the scope of the res trictions, the majority of 
which are provided to customers alongside food products, tend to comprise 
only a small part of the catalogues of catering distributors. Many of these firms 
 
76 Scottish Governm ent (2020) Scottish Annual Business Statistics 2018 .  
77 Manufacture of paper and wood products except furniture  in England and Scotland (2018) of £6,317m and 
£959m,  respectively, over manufacturing workforce jobs (Dec 2019) of 2.25m and 183,000, respectively. ONS 
(2019) Regional GVA (bala nced) by industry: all NUTS level regions ; and ONS (2020) JOBS05: Workforce jobs 
by region and industry .   also currently sell alternatives to single -use plastic  items. It is unlik ely that 
such firms would be significantly affected by the restrictions.  
DOWNSTREAM  
Does the measure significantly raise the costs of some existing suppliers 
relative to other existing suppliers?  
244. Downstream firms, unable to produce the single -use products themselves, 
would be indirectly affected by any price and availability issues that emerge 
further up the supply chain. It is possible that the costs of some firms will rise 
relative to other existing suppliers.  
245. In the study for Wales78 it was repo rted that smaller downstream hospitality 
outlets and charities who are less able to absorb any cost increases caused 
by a move towards alternatives may be disproportionately affected.  But that 
the overall impact (to these disproportionately affected groups  and to larger 
companies alike)  will be negligible because the price differential between the 
plastic product and the alternative is relatively small or non-existent in some  
cases.  
246. Research79 by Zero Waste Scotland on the price impact of market restrictions 
on single -use items looked at how additional costs are shared or passed along 
the supply chain  with evidence from stakeholders suggest ing that the first 
differentiation occurs when considering the relationship bet ween the 
individual or entity purchasing the item and the individual using it.  
247. Where the individual buying the item is also the person who will be making 
use of it, the additional cost is normally passed directly to the consumer. For 
example, when an indiv idual purchases a box of paper straws for their 
personal use, they are directly impacted by the increased cost of the paper -
based product. Stakeholder communication with one mid -range supermarket 
as well as an interview with a representative previously inv olved in another 
supermarket’s sustainability strategy confirmed this finding. The latter added 
that when the sale was business -to-consumer, product price was heavily 
dictated by profit margin and there was therefore little scope for absorption 
of any addi tional costs.  
248. The exception, however, was presented by a low -cost supermarket with a 
business built on ensuring that its product lines remain cheaper than those 
of its competitors. Its aim was to prevent customers from noticing any 
increases in price as a result of changes in the supply chain. As such, the 
representative of this supermarket stated that it absorbed any additional 
costs associated with transitioning to a new alternative product. This 
suggests that people shopping in low -cost supermarkets may be less likely 
 
78 Welsh Government (2020) Preliminary research to assess the impacts of  a ban or restrictions in sale in 
Wales of items in the EU's Single Use Plastics Directive . 
79 Zero Waste Scotland (2021): “Pricing impacts of single -use plastic bans: Assessing the impact of market -
restrictive bans for single -use plastic products on produc t pricing”. Not published.  to experience price increases as a result of the policy change than people 
shopping in mid -range or premium retailers.  
249. In contrast, when an item is provided as an aspect of a service, for example a 
stirrer in a tea at a coffee shop or a stra w in a drink from a takeaway  outlet, 
the distribution of the additional costs becomes more varied and complex. In 
these scenarios, the product is passed through a greater number of nodes in 
the value chain, and there is therefore more opportunity for variation in 
approach.  
250. The relati vely large number of takeaway outlets in Scotland (3,505) suggests 
that the market is very competitive. Whereas cost shocks for individual firms 
or groups of firms could be disruptive to competition, a cost rise experienced 
by all firms – which could be ex pected among the smaller firms given the 
restrictions and a move towards some more costly alternative products – may 
be simply passed on to the final consumer in the price they pay for takeaway 
food products. On the other hand, more high -end and larger out lets might be 
more willing /able  to absorb additional costs.  Without detailed information on 
the distribution of cost margins across Scottish food outlets it is not possible 
to fully assess the extent to which any potential additional costs to businesses 
will be absorbed or passed on.  
251. Table 16 below sets out the average prices  for single -use plastic items and 
the most likely non -plastic alternatives.  Plastic c utlery, stirrers and straws are , 
on average , the same price as non-plastic alterna tives. Non-plastic plates and 
cups are 1 -2 pence more expensive than equivalent plastic items . Non-plastic 
balloon sticks are 3 pence more expensive than plastic balloon sticks but the 
number of these in circulation is relatively small , accounting for 0.0 1 per cent 
of all items in scope . Compostable/bagasse food containers are on average 
3.7 pence more expensive than EPS containers . 
Table 16. Average catering industry prices for single -use plastic items 
and non-plastic alternatives80 
Product  Material  Item Price £ Material  Item Price £    
Cutlery  Plastic  0.04 Wood  0.04   
Plates  Plastic  0.06 Paper  0.07   
Beverage stirrers  Plastic  0.01 Wood  0.01   
Straws  Plastic  0.01 Paper  0.01   
Balloon sticks  Plastic  0.07 Paper/card  0.10   
EPS Food containers  Plastic  0.08 Bagasse  0.12   
 
80 Same methodology applied as Resource Futures research for Welsh Government. Obtained by taking an average of 
prices found from different wholesaler websites, primarily: Catering24; Cater4you; Nisbets.  EPS Beverage cups  Plastic  0.03 Paper/card  0.04  
 
252. Research by Spice81 found th at the average Scottish household spends £244  
annually on takeaway food  resulting in a  total market82 for takeaway  outlets of 
£579 million.  
253. It has not been possible to present data on typical turnover or gross profit 
margins in the food takeaway sector but Table 17 below indicates the scale 
of additional costs that may arise as a result of switching all single -use plastic 
items to non -plastic. The relevant non-plastic items identified as currently 
being more expensive th an their single -use plastic counterparts are plates, 
food containers and cups.  
Table 17. Additional costs associated with switching from single -use 
plastic items to non -plastic alternatives  
 Plates  Food Containers  Cups  
Number  (million)  50 66 45 
Price Difference  (£) 0.01  0.04  0.01 
Cost (£ million ) 0.5 2.64 0.45 
 
254. Under this approach, total additional cost s to the takeaway sector are 
estimated to be around £3.6 million  which represents  0.6 percent  of the total 
£579 million  Scottish takeaway food market.  It should be noted that the prices 
of alternative single -use products may be too high, particularly in the later part 
of the time period under consideration. This is because as market demand for 
alternative single -use products rises, their prices are likely to fall owing to 
econo mies of scale and product innovations for non -plastic alternatives.  
Does the measure significantly raise the costs of incumbent firms, causing 
them to exit the market?  
255. Incumbent firms may experience a small but insignificant cost rise through a 
degree of f amiliarisation costs associated with the restrictions. Smaller 
hospitality outlets without the resources to maintain close observation of 
legislative developments may be disproportionately affected ,83 but this alone 
is unlikely to threaten their number. Moreover, a programme of public 
 
81 SPICe ( Scottish Parliame nt Information Centre ) Spotlight (2019) Fast food booming – a cause for concern?  
82 Scotland’s Census (2021) Housing . 
83 We note that t here will be a programme of public engagement alongside the policy, which will mitigate this 
impact . Furthermore, the lead -in period allowing time  for firms to adjust  will give an opportunity for smaller firms 
to discover changes to the rules that they might otherwise have been unaware of . engagement, as well as the transition period for the introduction of market  
restrictions, is likely to mitigate the extent of familiarisation costs.  
Will the measure li mit the ability of suppliers to compete?  
256. This question investigates whether the market restrictions could affect the 
ability of firms to influence the characteristics that make their products stand -
out relative to their competitors. Such characteristics may include : the price, 
quality, level of innovation, marketing strategy and sales channel. Inhibiting 
the ability of firms to establish their own combination of these characteristics 
can in turn hinder competition between them.  
257. For this q uestion, the CMA guidance suggests that the following sub -
questions should be addressed, where relevant:  
• Does the measure control or substantially influence the price a supplier 
may charge and/or the characteristics of the products supplied?  
• Does the meas ure limit the sales channels a supplier can use, or the 
geographic area a supplier may supply in?  
• Does the measure substantially restrict the ability of suppliers to advertise 
their products?  
• Does the measure limit the suppliers' freedom to organise their own 
production processes or their choice of organisational form?  
258. Discussions of the first and third sub -question for are considered relevant for 
the market restrictions on single -use plastic s. 
UPSTREAM  
259. Does the measure limit the sales channels a supplier can use, or the 
geographic area a supplier may supply in?  
260. Rest-of-UK m anufacturers of single -use plastic  items will no longer be 
competing for the sale of single -use plastic  items in Scotland .  Manufacturers 
that currently focus predominantly on e xports to markets beyond the 
jurisdiction of the EU  SUPD  may thus be in a better position to compete than 
other manufacturers since they would be partly shielded from the restrictions. 
The high proportion of imported single -use plastic s, however, suggest t hat the 
UK’s share of the export market is not large and that this line of argument is 
unlikely to apply to many firms in Scotland. Therefore, there may not be any 
significant competition impacts on geographical areas of supply for 
manufacturers.  
261. Does the measure controls or substantially influence the characteristics of the 
products supplied?  
262. The characteristics of single -use items could  be influenced by the restrictions. 
If alternative products are intrinsically different such that they require certain 
equipment to produce and significantly higher capital expenditure, this could pose a barrier to entry to smaller firms wishing to transition to non -single -use 
plastic  production. It has not been possible to determine  whether capital 
expenditure cos ts are significantly different between single -use plastics  and 
non-plastic alternatives.  
DISTRIBUTION  
263. Does the measure control or substantially influence the characteristics of the 
products supplied?  
264. The market overview exercise noted three smaller distributors of single -use 
items in Scotland. Observing their catalogues of products currently on offer 
suggests that single -use plastic s comprise a material proportion of their 
historic sales of single -use items for the food takeaway trade. These smaller 
firms may therefore experience greater frictions of transitioning to non -plastic 
alternatives than the larger multinational distributors that are more likely to be 
able to procure them, both domestically and  from overseas. That larger firms 
can source inputs at lower prices than smaller ones is routinely noted in the 
literature (for example, larger firms can benefit from greater buyer power and 
can have teams of employees devoted to negotiating with suppliers ).84 
However, this exercise also shows that the smaller distributors have managed 
to stock alternatives, suggesting that the competition impact would be 
minimal.  
DOWNSTREAM  
265. Does the measure control or substantially influence the characteristics of the 
products supplied?  
266. The restrictions would directly control the characteristics of the single -use 
items that downstream firms can provide with their food services. However, 
research conducted for Defra concluded that despite stakeholder c oncerns, 
alternatives with equivalent functionality for consumers exist for single -use 
plastic cutlery and plates, and for EPS food containers and cups.85,86 Wooden 
alternatives to single -use plastic beverage stirrers are already widely in use 
and do not affect fun ctionality.   
267. Card -based alternatives to single -use plastic balloon sticks are available. 
While these may be less durable than their single -use plastic equivalents, 
there will not be a significant impact on consumers given the short, in -use life 
 
84 See, for example, Bernard et al. (2019) The origins of firm heterogeneity: A production network approach, 
NBER working paper No. 25441 . 
85 Resource Future s on behalf of Defra (2018a): A preliminary assessment of the economic impacts of a 
potential ban on plastic cutlery, plastic plates and plastic balloon sticks , A preliminary assessment of the 
economic, environmental and social impacts of a potential ban on plastic straws, plastic stem cotton buds and 
plastics drinks stirrers ; and Resource Futures on behal f of Defra (2019) A Preliminary Assessment of the 
Economic Impacts of a Potential Ban on Expanded Polystyrene Food and Beverage  Containers . 
86 Resource Futures on behalf of Defra (2019) A preliminary assessment of the economic impacts of a potential 
ban o n expanded polystyrene food and beverage containers . of the items. An exemption exists for plastic balloon sticks used and collected 
for re -use by businesses and professionals.  
It is acknowledged that no alternative to single -use plastic straws has exactly 
equivalent functionality —though innovation in this area is ongoing. A study for 
the Welsh Government identified a lack of readily -available alternatives to 
single -use straws capable of piercing through the film on drinks 
cartons/pouches.87 However, at least two multinational manufacturers in 
Europe are introducing paper alternatives that are capable of piercing through 
drinks cartons.88 
Will the measure limit suppliers’ incentives to compete vigorously?  
268. The purpose of this question is to ascertain the extent to which firms may be 
incentivised to mutually agree to stop or reduce the extent of competition 
between them (e.g. in terms of the price and/or quality of a product, or the 
type of customers). In other words, firms may or may not be i ncentivised to 
coordinate their behaviour.   
269. The CMA guidance suggests the following sub -questions may be answered 
in response to this question:  
• Does the measure incentivise suppliers to coordinate their behaviour?  
• Does the measure exempt suppliers from co mpetition law?  
• Does the measure introduce or amend and intellectual property regime?  
270. The restrictions are unlikely to facilitate or encourage the coordination or 
collusion of firms in the manufacturing, distribution or downstream market 
segments. The marke t restrictions do  not exempt suppliers from competition 
law nor introduce or amend an intellectual property regime.  
271. The remaining sub -question is whether the measures would incentivise 
suppliers to coordinate their behaviour. The market restrictions would  serve 
to create a new, but level, playing field for all participants in the supply chain, 
which does not present clear incentives for participants to coordinate. The 
downstream food service sector is especially competitive and extremely 
unlikely to experi ence any coordination of firm activity as a result of the 
restrictions.  
 
Will the measure limit the choices and information available to consumers?  
 
87 Welsh Government (2020) Preliminary research to assess the impacts of a ban or restrictions in sale in 
Wales of items in the EU's Single Use Plastics Directive . 
88 Suntory Beverage and Food GB&I, owner of Ribena, began trialling paper straws on its cartons in retailers in 
the UK in September 2020. Tetra Pak began consumer trials of its paper straws in 2019. Sources: Suntory 
(2020) The final straw: Ribena becomes first major UK juice drinks brand to trial paper straws on cartons ; and 
Tetra Pak (2019) Tetra Pak becomes first carton packaging company to launch paper straws in Europe . 272. The choice of product consumers make is key to driving competition between 
firms. A consumer making a decision informed with the relevant information 
of a firm’s product will either reward the firm (by purchasing its product) or 
send a signal to the firm that its product does not meet the consumer’s 
preferences. This question investigates whether consumer s may become 
limited in their ability to make these choices.  
273. The following sub -questions may be considered based on the CMA guidance:  
• Does the measure limit the ability of consumers to decide from whom they 
purchase?  
• Does the measure change the information  available to consumers but 
does not improve their ability to make informed decisions?  
• Does the measure reduce the mobility of consumers by increasing the cost 
of changing suppliers?  
274. Of these sub -questions, the first is considered to be potentially relevan t for the 
upstream, distribution and downstream levels of the supply chain.  
UPSTREAM  
275. Does the measure limit the ability of consumers to decide from whom they 
purchase?  
276. Consumer choice would be limited by (a) the unavailability of restricted single -
use pla stic items and (b) if the choice of manufactured most -likely alternatives 
was more restrictive. Possibility (a) is largely unavoidable given the 
restrictions. Possibility (b) would only emerge if, for example, manufacturers 
were limited in their capacity t o produce the quantity of alternatives  required , 
but as we have discussed above, it seems likely that the range of alternatives 
available would expand. As discussed previously, there are a number of 
alternative products already being produced and distribut ed in Scotland, and 
it is likely that market incentives would encourage manufacturers to produce 
a greater variety of alternatives in the longer -term. The end -consumption of 
existing single -use plastic  products is generally not for its own benefit since 
these products are provided to consumers as complementary goods with 
other products, such as takeaway food and beverages. Their consumption 
choices are unlikely to be affected by the single use plastic material type. 
Therefore, if it were restricted at all, consumer choice would only be limited by 
alternative manufacturing capacity in the short -term, and this is unlikely to 
disadvantage consumers.   
DISTRIBUTION  
277. Does the measure limit the ability of consumers to decide from whom they 
purchase?  
278. Factors that might lead to consumers in certain areas being limited in choice 
including questioning whether distributors of alternatives have the geographic 
distribution capacity to reach all downstream firms across Scotland. A question asked of stakeholders was w hether consumers of takeaway food in 
the islands may be limited in their choice of food products if the food outlets 
are limited in what containers they have been able to procure.  
279. Stakeholder  responses  indicated  that alternative items could be sourced 
through existing supply chains, including the  more remote areas of Scotland.  
DOWNSTREAM  
280. Does the measure limit the ability of consumers to decide from whom they 
purchase?  
281. To the extent that downstream firms increase prices to match the increase in 
the costs of single -use plastic  alternatives, this could limit the affordability and 
choice of certain end products for consumers. Assuming single -use plastic  
alternatives do incr ease the cost of end -products (with, for example smaller 
food outlets with tight margins), and if enough consumers turn away from 
them, downstream firms could, theoretically, experience a reduction in 
demand.  
282. We can investigate whether consumers may turn away from the end -products 
with which single -use plastic s are provided using price elasticities. Price 
elasticities measure the extent to which a change in price is associated with 
changes in demand for a product. In the case of “own -price elasticities” 
(changes in the product’s own price), values of less than -1 indicate elastic 
demand; between 0 and -1 indicate inelastic demand.  
283. Research conducted for Defra in 2012 on the elasticities of different food 
products suggests that takeaway food is generally in elastic – that is, demand 
is relatively unresponsive to price. For example, a 10 per cent increase in the 
price of takeaway poultry would be expected to decrease demand by a 
proportionately -smaller 8 per cent.89 The same increase applied to other 
takeaway meat would result in just 2 per cent lower demand. (Please refer to 
the Appendix for further detail of these elasticities.)  
284. The elasticity estimates reported above relate to only takeaway meat items, 
and so the picture may be different for other popular ta keaway foods. The 
booming takeaway market in the UK, and its expected steady growth in future 
years,90 suggests that overall demand is unlikely to fall, and so any small price 
increments caused by the cost of single -use alternative items may be offset 
by overall revenue growth.  
 
89  Tiffin, R. et al (2012) for Defra. Estimating Food and Drink Elasticities . 
90  British Takeaway Campaign (2019) Cooking up growth, Serving up talent . 285. Zero Waste Scotland  research on transfer of change in item costs  found that  
some food outlets and retailers (higher -end ones) may instead absorb any 
cost increases,91 thus leaving consumer prices unchanged.  
286. Overall, the evidence from the elasticity estimates available suggests that if 
the additional costs of sourcing suitable alt ernatives to takeaway food 
packaging items are passed on to consumers in full, then downstream 
takeaway firms may not experience dramatically reduced demand given 
consumers’ relative insensitivity to takeaway price changes.  
287. In the case of balloon sticks, consumers could face a slightly  more limited 
choice if a range of non-plastic alternatives are not forthcoming.  However, 
exemptions exist for those used for industrial/professional uses.  
 
 
8.0 Consumer Assessment  
288. This section considers the extent to which the market restrictions may benefit or 
disadvantage consumers in Scotland. A consumer is defined following the 
Scottish Government’s definition as “anyone who buys goods or digital content, 
or uses goods or servic es either in the private or public sector, now or in the 
future”.92 In this context, this includes end -consumers who use the single -use 
plastic  items  in question , either buying  them from a retail er, or having them 
provided by food and drink outlets  or retail ers in conjunction with the purchase 
of food and beverages. Consumers may also include individuals and 
organisations that purchase and/or use the relevant single -use plastic  items as 
part of their business model.  
289. The BRIA toolkit sets out the fol lowing questions to consider in a consumer 
assessment:  
• Does the policy affect the quality, availability or price of any goods or services 
in a market?  
• Does the policy affect the essential services market, such as energy or 
water?  
• Does the policy involve storage or increased use of consumer data?  
• Does the policy increase opportunities for unscrupulous suppliers to target 
consumers?  
• Does the policy impact the information available to consumers on either 
goods or services, or their rights in relation  to these?  
 
91 Zero Waste Scotland (2021): “Pricing impacts of single -use plastic bans: Assessing the impact of market -
restrictive bans for single -use plastic products on product pricing”. Not published.  
92 Scottish Government (2018) Business and Regulatory Impact Assessments (BRIA) toolkit.   • Does the policy affect routes for consumers to seek advice or raise 
complaints on consumer issues?     
 
Does the policy affect the quality, availability or price of any goods or 
services in a market?  
290. Availability of the relevant single -use plastic  items and their most -likely 
alternatives : 
291. The policy will almost entirely restrict the availability of the relevant single -use 
plastic  items.  
292. However, the impact on consumers will be mitigated by the following points.  
293. Single -use items made of alternative materials  are readily available  for 
these products.  Alternative item s (typically made of paper or wood) are 
available in Scotland from l arger bricks -and-mortar retailer s as well as  online 
retailers . There are a number of existing manufacturers of alternative single -
use items in Scotland, such as Cullen, Vegware and Eco Pack Scotland, 
which could  respond to higher demand for non -plastic single -use items . In 
addition, the fact that similar regulations have already been introduce d in 
neighbouring countries means that market demand for —and therefore supply 
of—alternative items is expected to remain strong.  
294. Consumer demand is gradually switching away from all single -use 
items , and is switching away from single -use plastic  items  to alternative 
single -use items . As noted in the Options section,  previous research for 
Defra suggests that demand for single -use items (plastic and alternative)  is 
gradually declining over time.  This is driven by rising awareness of the 
population around the negative effects of single -use items, the desire of 
businesses to avoid the higher costs of non -plastic single -use alternative 
products, and a gradual shift towards reusable products.  Levels of concern in 
Scotl and about single -use items are already high. A recent survey 
commissioned by Zero Waste Scotland found that an overwhelming majority 
of people in Scotland (77 per cent) were  very or fairly concerned about the 
quantity of items designed to be used only once . Still more people (79 per 
cent) would support the introduction of regulations to reduce the use of single -
use items and packaging.93 
295. In addition, research conducted for Defra suggests that the market share of 
single -use plastic  items compared to alternative single -use items  is falling at 
around 10 percentage points per year  in most cases . (The exception is EPS 
 
93 Zero Waste Scotland (2020) Majority of Scots concerned over single -use items and packaging.  Available at: 
https://www.zerowastescotland.org.uk/press -release/majority -scots -concerned -over-single -use-items -and-
packaging  food containers and EPS cup s, the share  of which is falling by just 1 
percentage point annually  compared to their most -likely alternatives.)  
296. The policy include s exemptions for products where these are provided 
for medical use and to support independent living . The EU SUPD 
provides explicit exemptions for straw s used for medical purposes.94 The 
Scottish Government has recognised that certain single -use plastic  items are 
required for medical purposes or to support independent living.95 Therefore, 
the availability of single -use plastic  items required for these purposes , 
specifically  single -use plastic  straws,  will be maintained.  Exemptions will also 
apply for bal loon sticks where they are used for professional purposes.  
297. Quality and functionality of alternatives : 
298. The impact on consumers in terms of quality and functionality will be minimal.  
299. The majority of single -use plastic s in scope have alternatives that can be 
substitu ted for them without compromising functionality.   
300. Research conducted for Defra concluded  that despite some stakeholder 
concerns,  alternatives with equivalent functionality for consumers exist  for 
single -use plastic  cutlery and plates,  and for EPS food containers  and 
cups .96,97 Wooden  alternatives to single -use plastic  beverage stirrers  are 
already widely in use  and do not affect functionality .  
301. Card -based alternatives to single -use plastic  balloon sticks are available.  
While the se may be less durable than their single -use plastic  equivalents, 
there will not be a significant  impact on consumers given the short , in-use life 
of the items. An exemption exists  for plastic balloon sticks used and collected 
for re -use by businesses and professionals.  
302. It is acknowledged that no alternative to single -use plastic  straws has exactly 
equivalent functionality —though innovation in this area is ongoing . A study for 
the Welsh Government identified  a lack of readily -available  alternative s to 
single -use straws capable of piercing through the film on drinks 
cartons/pouches.98 However, at least two multinational manufacturers in 
Europe are introducing paper al ternatives that are capable of piercing through 
 
94 European Union (2019) Directive (EU) 2019/904 of the  European Parliament and of the Council of 5 June 
2019 on the reduction of the impact of certain plastic products on the environment, Article 3(3).   
95 The Scottish Government (2020) Introducing Market Restrictions on Problematic Single -Use Plastic Items in 
Scotland: Strategic Environmental Assessment - Environmental Report .  
96 Resource Future s on behalf of Defra (2018a): A preliminary assessment of the economic impacts of a 
potential ban on plastic cutlery, plastic plates and plastic balloon sticks , A preliminary assessment of the 
economic, environmental and social impacts of a potential ban on pla stic straws, plastic stem cotton buds and 
plastics drinks stirrers ; and Resource Futures on behalf of Defra (2019) A Preliminar y Assessment of the 
Economic Impacts of a Potential Ban on Expanded Polystyrene Food and Beverage Containers . 
97 Resource Futures on behalf of Defra (2019) A preliminary assessment of the economic impacts of a potential 
ban on expanded polystyrene food and beverage containers . 
98 Welsh Government (2020) Preliminary research to assess the impacts of a ban or restrictions in sale in 
Wales of items in the EU's Single Use Plastics Directive . drinks cartons.99 Negative impacts on consumers  related to supply of single -
use plastic  straws for drinks cartons/pouches  are likely to be short -lived, as 
the market can respond  by creating and adopting better alternatives as noted 
above, or by changing to another type of container.   
303. The Equalities Impact Assessment for this policy change noted several 
qualities specific to single -use plastic  straws which are important to people 
who require them for medical purposes or to support independent living . 
However, exemp tions are in place to ensure that people with these 
requirements will continue to have access to single -use plastic  straws, so no 
significant consumer impact is expected in this regard.  The Scottish 
Government is working with stakeholders , including representatives of 
equalities groups  and users of single -use plastic straws , to ensure that the 
exemption is implemented in a way that respects equality interests  and the 
dignity of those needing to access single -use plastic straws.  
304. Price of alternatives : 
305. Consumers may experience a slight increase in the prices they pay for goods 
and services associated with some of the products in scope. However, the 
overall price  impacts on consumers  at an individual level will be very limited, 
often not noticeable,  and sometimes avoidable.  
306. At present , three  out of seven of the  most -likely alternatives are more 
expensive than the  restricted single -use plastic  products, as can be seen in 
Figure  3, below. This show s average  per-unit market prices of the restricted 
single -use plastic  items and their most -likely single -use alternatives , collected 
for the impact assessments of introducing market restrictions on the same 
single -use plastic  items in Wales . 
 
Figure 3: Prices of single -use plastic  products and their alternatives  
 
99 Suntory Beverage  and Food GB&I, owner of Ribena, began trialling paper straws on its cartons in retailers in 
the UK in September 2020. Tetra Pak began consumer trials of its paper straws in 2019. Sources: Suntory 
(2020) The final straw: Ribena becomes first major UK juice drinks brand to trial paper straws on cartons ; and 
Tetra Pak (2019) Tetra Pak becomes first carton packaging company to launch paper straws in Europe .   
Source: Welsh Government (2020) “Preliminary research to assess the impacts of a ban or restrictions on sale in Wales of items in the 
EU's Single Use Plastics Directive” Based on online UK wholesalers 100 
307. The per -item cos t increases range from £0 to £0. 04, so the impact on the 
typical individual consumer in any given purchase will either be nil or limited.  
The per -item cost increases range from £0 to £0.04 so the impact on the 
typical  individual consumer  in any given purchase will either be ni l or limited . 
308. The extent to which additional costs will be experienced by consumers will 
depend on the willingness and ability of individual businesses in the supply 
chain to absorb them. This depends on factors such as profit margins and 
market positioning  and will vary . For instance, s takeholder interviews  
conducted for Zero Waste Scotland found that  some  large retailers  with a 
business model based on low prices  would be willing to abso rb the differ ence 
in price between single -use plastic  and alternative items . However, smaller 
food and drink outlets with tight profit margins m ay be more likely to pass on 
costs to consumers .101 This suggests that in many cases, consumers will be 
able to avoid additional costs by choosing to shop  at retailers or outlets which 
have absorbed  them.  
309. Consumers willingness to pay for non -plastic  items may be increased by 
environmental concern s around the damage caused by single -use plastic 
items. I t was found during telephone interviews  with takeaway outlets  that one 
business , in particular , received complaints from customers over the 
environmental damage caused through their use of EPS food containers. This 
was a key factor in them switching to alternative items. This factor will vary 
between different consumers and businesses, but it will be a factor in 
decision -making around item prices.  
310. How noticeable the price  increase s are to an individual will also depend on 
the context of the purchase. Where a small number of items are provided 
along with a food or drink purchase, the additional costs to consumers are £0.00£0.02£0.04£0.06£0.08£0.10£0.12£0.14
Cutlery Plates Beverage
stirrersStraws Balloon
sticksFood
containersBeverage
cups
Plastic product Alternative product‘hidden’ and limited. A £2 drink served with a straw would not necessarily see 
any price increase. A hot drink served in the alternative to a single -use EPS 
cup would only be around £0.01  more expensive, which is not a noticeable 
increase. Turning to the  item with the biggest absolute per -unit price increase, 
EPS food container s: a meal for one person requiring up to two containers 
may increase in price by up to £0.08 when using alternative items , depending 
how much of the pric e increase  the business is willing to absorb.  
311. Cost increases to consumers buying items in bulk from retailers  would vary 
by outlet type . For example, a pack of 20 single -use plates may not change in 
price if purchased from a budget retailer which prioritises price points  for its 
products .102 Higher -end retail outlets may be less concerned about price 
points and, for example , if 100 per  cent of the cost  increase was passed 
through , the price for 20 single -use plates would rise from £1.20  to £1.40 for 
single -use alternatives.  
312. The higher cost of some alternative items is likely to incentivise both 
businesses and consumers to reduce their consumption of these single -use 
items in general . According to s takeholder interview s conducted for Zero 
Waste Scotland , some businesses in England found ways to significantly 
reduce the use of alternative single -use items following the introduction of 
similar restrictions there  (e.g. handing out straws only when asked for them) , 
thereby a voiding the need to pass on additional costs to consumers.  
313. Prices are never static, and given rising demand for the alternative single -use 
items after the restrictions —not just in Scotland, but in countries across 
Europe which have implemented restrictions  based on the EU SUPD —it is 
reasonable to expect that their prices could fall in coming years, or that other, 
cheaper alternatives could come onto the market. This would further limit price 
impacts on consumers.  
 
 
Does the policy affect the essential services market, such as energy or 
water?  
No. 
Does the policy involve storage or increased use of consumer data?  
 
100 Welsh Government (2020) Preliminary research to assess the impacts of a ban or restrictions in sale in 
Wales of items in the EU's Single Use Plastics Directive . Available at: 
https://gov.wales/sites/default/files/statistics -and-research/2020 -05/impacts -of-a-ban-or-restrictions -in-sale-of-
items -in-the-eus-single -use-plastics -directive.pdf  
101 Pricing impacts of single -use plastics bans. Eunomia. January 2021. Unpublished  
102 Pricing impacts of single -use plastics bans. Eunomia. January 2021. Unpublished.  No. 
Does the policy increase opportunities for unscrupulous suppliers to target 
consumers?  
No. 
 
Does the policy impact the information available to consumers on either 
goods or services, or their rights in relation to these?  
No 
Does the policy affect routes for consumers to seek advice or raise 
complaints on consumer issues?  
No  
 
9.0 Test run of business forms  
The introduction of these regulations will not result in the creation of new forms for 
businesses or result in amendments of existing forms.  
10.0 Digital Impact Test  
Changes to policy, regulation or legislation can often have unintended consequences, 
should g overnment fail to consider advances in technology and the impact this may 
have on future delivery. This digital impact test is a consideration of whether the 
changes being made can still be applied effectively should business/government 
processes change – such as services moving online. The below details the evaluation 
of the market restrictions  on current and future digital developments. Overall, it is 
viewed that the legislation will not have an adverse impact on digital technology 
developments.  
 
Table  18. Digital Impact Test Questionnaire  
Question 1. Does the measure take account of changing digital 
technologies and markets?  
Potential c hang es in  digital technologies and markets are being account ed 
for during the development of th is legislation.   
Question 2. Will the measure be applicable in a digital/online context?  
Any restrictions would apply equally to both online and offline suppliers.   Question 3. Is there a possibility the measures could be circumvented 
by digital/online transactions?  
As the affected single -use plastic products  are sold by both traditional and 
online suppliers , the legislation would also need to apply to online 
transactions in order to be effective and meet  the stated object ives. 
Question 4. Alternatively, will the measure only be applicable in a 
digital context and therefore may have an adverse impact on 
traditional or offline businesses?  
The legislation  would be applicable equally to both digital and traditional 
businesses and would therefore not result in an adverse impact on 
traditional or offline businesses.  
Question 5. If the measure can be applied in an offline and online 
environment will this in itself have any adverse impact on incumbent 
operat ors?  
No. 
 
11.0 Legal Aid Impact Test  
The market  restrictions will not have an  impact on Legal Aid.    
12.0 Enforcement, sanctions and monitoring  
In order to achieve the objectives of market  restrictions  on several single use plastic 
products , enforcement, sanctions and monitoring systems will be put in place.  
13.0 Implementation and delivery plan  
The Scottish Government will set out a timetable for implementation and will work 
closely with businesses invol ved in the manufacture, import, trade and sale of the 
single -use plastic products  under consideration . This includes exploring opportunities 
for diversification and the manufacture of affected products  using alternative materials  
which will help support more circular business opportunities such as providing 
reusable alternatives.  
14.0 Declaration and publicatio n 
I have read the Business and Regulatory Impact Assessment and I am satisfied that, 
given the available evidence, it represents a reasonable view of the likely costs, 
benefits and impact of the leading options. I am satisfied that business impact has 
been assessed with the support of businesses in Scotland.  
 Signed:  
 
Date:  
  
Minister’s name     Michael Matheson  
 
Minister’s title        Cabinet Secretary for Net Zero, Energy and Transport  
 
Scottish Government Contact point:  Shaun Taylor – shaun.taylor2@gov.scot   
 
 
15.0 Annex A: Indicative questions for Scottish Firms Impact Test interviews  
Europe Economics, on behalf of Zero Waste Scotland, is supporting the development 
of a Business and Regulatory Impact Assessment (BRIA) for the introduction of market 
restrictions on certain single -use plastic items in Scotland.  
A BRIA is used to analyse the cost and benefits to businesses and the third sector of 
any proposed legislation or regulation, with the goal of using evidence to identify the 
proposal that best achieves policy objectives while minimising costs and burdens.  
Engagement with Scottish firms forms a central part of the BRIA process. For this, 
interviews are performed with a group of key stakeholders which may be impacted by 
the change in legislation. The findings of this engagement will be fed into the 
development of the proposed legisla tion.  
The views expressed during this engagement process will be published as part of the 
BRIA process. However, your personal information will remain confidential; only the 
name of your organisation will be used. Additional information can be found at: 
http://www.zerowastescotland.org.uk/content/data -protection -policy.  
Please note that the interview may not cover all of the questions below. These provide 
an indication as to  the areas we are interested in exploring. If you feel only able to 
engage with us on certain questions please indicate that to us and we will focus the 
interview on the areas where you are most able to provide useful input.  
1. The Scottish Government is curr ently consulting on legislation aimed at 
restricting the sale of specific single -use plastic items in Scotland. Are you 
supportive of the introduction of these restrictions? Why/ why not? Please give 
your reasons.  
2. In your opinion how has the use of single -use plastic items covered by the 
restrictions changed over recent years (e.g. in the last 5 years)? How would you expect the use of these items to change in the next 5 -10 years in the absence 
of the market restrictions being introduced?  
3. In your opinion wh at will be the biggest potential impacts (both costs and 
benefits) of introducing the market restrictions on your business or on those 
which you represent? Which businesses, in your opinion, will be most affected 
by the restrictions? Please provide evidenc e where possible.  
4. Has your business or have the businesses you represent taken any steps to 
mitigate any anticipated impacts or costs associated with the market 
restrictions? If so, please expand your answer.  
5. Does your organisation or association have spec ific concerns on how the 
restrictions might impact businesses in more remote areas of Scotland? Please 
expand on your answer.  
6. To what extent do you expect the market restrictions to put your business, or 
those which you represent, at a disadvantage, nation ally or internationally? 
Please provide evidence where possible.  
7. Do you have any concerns about these restrictions affecting competition 
amongst your suppliers, or those of the businesses which you represent? If so, 
could you elaborate?  
8. When the market restrictions come into force, will your business or the 
businesses you represent switch to alternative products, or do you anticipate 
stopping the use, sale or production of the products affected by the restrictions 
altogether? What alternative prod ucts will you be producing, using or selling 
instead of single -use plastics? Please expand your answer.  
9. If your business or the businesses you represent will be substituting single -use 
plastic items covered by the restrictions with alternative products (as  part of your 
sales or production), how quickly do you expect this transition to take place? Do 
you anticipate any difficulties prior to or during this transition? Please expand 
your answer.  
10. If you are planning to switch to alternative products, do you exp ect final 
consumers to notice the change and adjust their purchasing behaviour as a 
result of the change? For example, would you expect them to buy less (e.g. 
because of reduced convenience) or more (because of increased environmental 
friendliness) of the final product or be willing to pay less or more for it?  
11. What unintended consequences do you anticipate for your business or the 
businesses you represent as a result of the restrictions?  
 
12. Is there anything else you wish to add not covered by the above quest ions?  
 
16.0 Annex B:  Demand elasticities of food products  
Research conducted for Defra on the elasticities of different food products suggests 
that takeaway food is generally inelastic – that is, demand is relatively unresponsive to 
price. This can be seen below, where the compensated elasticities for the available 
takeaway products clearly show inelastic demand. Compensated elasticities mean that 
the figures do not consider the income effect: the possibility that a lower price leaves consumers with more inc ome at each quantity of consumption that they may then spend 
on the product. The authors note that at this high level of product disaggregation, the 
compensated elasticities are more informative because the substitution effect 
(switching consumption to/awa y from the product whose price changes) is stronger as 
households tend to be more sensitive to changes in the prices of individual products 
than they would be to changes in the prices of broad product categories.103 
Figure 4: Estimated own -price elasticitie s for takeaway products  
 
Source: Tiffin, R. et al (2012) for Defra “Estimating Food and Drink Elasticities” . Figures for 2009. Level 3 elasticities reported.  
 
17.0 Annex C: Full NPV tables by individual item  
1. Cutlery   
Stakeholder  Impact  NPV under 
Baseline (£)  NPV under 
Option 1 (£)  Net 
change to  
NPV (£)  
Society  Carbon impacts 
(production)  -445,384  -231,052  214,331  
Society  Carbon impacts 
(recycling)  0 0 0 
Society  Carbon impacts 
(composting)  16,607  20,701  4,095  
Society  Carbon impacts 
(incineration)  -98,768  27,385  -126,153  
Society  Carbon Impacts 
(Landfill)  -7,030  -14,728  -7,698  
Local 
Authorities  Recycled 
material  0 0 0 
Local 
Authorities  Composting 
costs  -77,652  -98,412  -20,759  
 
103 See discussion on page 24. Tiffin, R. et al on behalf of Defra (2012)  Estimating food and drink elasticities.  
Available at: https://www.gov.uk/government/publications/food -and-drink -elasticities  -1.2-1-0.8-0.6-0.4-0.20Uncompensated Compensated Uncompensated CompensatedPoultry (Cooked & Takeaway) Other meat (Processed & Takeaway)Local 
Authorities  Energy from 
Waste costs -490,166  -457,416  32,750  
Local 
Authorities  Landfill costs -21,072  -18,246  2,826  
Local 
Authorities  Direct littering 
costs -220,941  -216,690  4,250  
Society   Indirect littering 
costs -12,111,272  -11,435,373  675,899  
Local 
Authorities  Residual waste -368,507  -362,225  6,282  
Society  Change in item 
costs  -98,013,011  -92,765,941  5,247,069  
 
Total   -111,837,195  -105,551,998  6,285,198  
2. Plates  
Stakeholder  Impact  NPV under 
Baseline (£)  NPV under 
Option 1 (£)  Net 
change to  
NPV (£)  
Society  Carbon impacts 
(production)  -765,250  -654,055  111,195  
Society  Carbon impacts 
(recycling)  0 0 0 
Society  Carbon impacts 
(composting)  36,844  38,618  -1,774  
Society  Carbon impacts 
(incineration)  -16,787  57,184  -73,971  
Society  Carbon Impacts 
(Landfill)  -24,768  -28,076  -3,308  
Local 
Authorities  Recycled 
material  0 0 0 
Local 
Authorities  Composting 
costs  -100,249  -105,216  -4,966  
Local 
Authorities  Energy from 
Waste costs -1,040,984  -1,022,876  -18,108  
Local 
Authorities  Landfill costs 
-45,153  -46,522  -1,369  
Local 
Authorities  Direct littering 
costs -220,859  -220,311  548 
Society   Indirect littering 
costs -1,965,927  -1,860,489  105,438  
Local 
Authorities  Residual waste 
-747,324  -745,515  1,809  
Society  Change in item 
costs  -54,615,261  -52,484,477  2,130,784  
Total   -59,505,718  -57,071,734  2,433,984  3. Stirrers  
Stakeholder  Impact  NPV under 
Baseline (£)  NPV under 
Option 1 (£)  Net 
change to  
NPV (£)  
Society  Carbon impacts 
(production)  -9,935  -8,801  1,134  
Society  Carbon impacts 
(recycling)  0 0 0 
Society  Carbon impacts 
(composting)  0 0 0 
Society  Carbon impacts 
(incineration)  1,856  2,427  571 
Society  Carbon Impacts 
(Landfill)  -767 -870 -104 
Local 
Authorities  Recycled 
material  0 0 0 
Local 
Authorities  Composting 
costs  0 0 0 
Local 
Authorities  Energy from 
Waste costs -25,217  -24,945  272 
Local 
Authorities  Landfill costs 
-749 -802 -53 
Local 
Authorities  Direct littering 
costs -928 -928 0 
Society   Indirect littering 
costs -83,774  -79,233  4,541  
Local 
Authorities  Residual waste 
-15,684  -15,684  0 
Society  Change in item 
costs  -1,700,486  -1,609,517  90,970  
Total   -1,835,685  -1,738,353  97,332  
4. Straws  
Stakeholder  Impact  NPV under 
Baseline (£)  NPV under 
Option 1 (£)  Net 
change to  
NPV (£)  
Society  Carbon impacts 
(production)  -166,332  -130,183  36,149  
Society  Carbon impacts 
(recycling)  0 0 0 
Society  Carbon impacts 
(composting)  0 0 0 
Society  Carbon impacts 
(incineration)  -22,319  9,137  31,456  
Society  Carbon Impacts 
(Landfill)  -1,675  -3,966  -2,291  Local 
Authorities  Recycled 
material  0 0 0 
Local 
Authorities  Composting 
costs  0 0 0 
Local 
Authorities  Energy from 
Waste costs -201,149  -218,022  -16,872  
Local 
Authorities  Landfill costs 
-5,308  -6,794  -1,486  
Local 
Authorities  Direct littering 
costs -73,769  -81,529  -7,760  
Society   Indirect littering 
costs -13,397,519  -12,645,234  752,285  
Local 
Authorities  Residual waste 
-123,249  -136,478  -13,229  
Society  Change in item 
costs  -27,120,992  -25,670,121  1,450,870  
Total   -41,112,312  -38,883,191  2,229,121  
5. Balloon sticks  
Stakeholder  Impact  NPV under 
Baseline (£)  NPV under 
Option 1 (£)  Net 
change to  
NPV (£)  
Society  Carbon impacts 
(production)  -7,562  -5,510  2,052  
Society  Carbon impacts 
(recycling)  237 305 69 
Society  Carbon impacts 
(composting)  0 0 0 
Society  Carbon impacts 
(incineration)  -1,282  338 1,619  
Society  Carbon Impacts 
(Landfill)  -60 -160 -100 
Local 
Authorities  Recycled 
material  1,025  1,502  477 
Local 
Authorities  Composting 
costs  0 0 0 
Local 
Authorities  Energy from 
Waste costs -7,829  -8,327  -499 
Local 
Authorities  Landfill costs 
-264 -298 -34 
Local 
Authorities  Direct littering 
costs -3,175  -3,499  -324 
Society   Indirect littering 
costs -67,177  -61,033  6,144  
Local 
Authorities  Residual waste 
-5,299  -5,851  -552 Society  Change in item 
costs  -1,168,467  -1,185,360  -16,893  
Total   -1,259,853  -1,267,894  -8,041  
6. EPS containers  
Stakeholder  Impact  NPV under 
Baseline (£)  NPV under 
Option 1 (£)  Net change 
to NPV (£)  
Society  Carbon impacts 
(production)  -686,977  -642,755  44,222  
Society  Carbon impacts 
(recycling)  0 0 0 
Society  Carbon impacts 
(composting)  76 270 194 
Society  Carbon impacts 
(incineration)  -275,2 71 -1,519 273,753 
Society  Carbon Impacts 
(Landfill)  -4,264  -15,499  -11,235  
Local 
Authorities  Recycled 
material  0 0 0 
Local 
Authorities  Composting 
costs  -2,188  -7,754 -5,567  
Local 
Authorities  Energy from 
Waste costs -494,641  -835,718  -341,078  
Local 
Authorities  Landfill costs -23,627  -60,445  -36,818 
Local 
Authorities  Direct littering 
costs -90,232  -153,884  -63,652  
Society   Indirect littering 
costs -2,025,479  -2,024,168  1,311  
Local 
Authorities  Residual waste -304,085  -518,176  -214,091 
Society  Change in item 
costs  -71,763,128  -92,997,356  -21,234,228  
 
Total   -71,763,128  -92,997,356  -21,234,228  
7. EPS cups  
Stakeholder  Impact  NPV under 
Baseline (£)  NPV under 
Option 1 (£)  Net 
change to  
NPV (£)  
Society  Carbon impacts 
(production)  -268,325  -291,286  -22,960  
Society  Carbon impacts 
(recycling)  4,929  17,495  12,566  
Society  Carbon impacts 
(composting)  4,929  17,495  12,566  Society  Carbon impacts 
(incineration)  -94,219  24,729  118,949  
Society  Carbon Impacts 
(Landfill)  -1,462  -5,311  -3,849  
Local 
Authorities  Recycled 
material  23,509  82,770  59,262  
Local 
Authorities  Composting 
costs  -13,125  -46,526  -33,401  
Local 
Authorities  Energy from 
Waste costs -210,749  -408,662  -197,913  
Local 
Authorities  Landfill costs 
-4,618  -8,358  -3,739  
Local 
Authorities  Direct littering 
costs -42,984  -91,029  -48,045  
Society   Indirect littering 
costs -1,381,008  -1,380,115  894 
Local 
Authorities  Residual waste 
-144,555  -305,551  -160,996  
Society  Change in item 
costs  -18,284,626  -21,953,908  -3,669,281  
Total   -20,412,306  -24,348,255  -3,935, 949