Table of Contents

Table of Contents. 2

List of Tables. 4

List of Figures. 5

Glossary of Terms. 6

Introduction. 7

1........... Procedural issues and consultation of interested parties. 8

1.1........ Consultation and expertise. 8

2........... Problem Definition. 10

2.1........ Problems requiring action. 10

2.1.1..... Plastic carrier bags in the EU: facts and figures. 10

2.1.2..... Impacts. 12

2.2........ Underlying drivers of the problem.. 16

2.3........ Who is affected, in what ways, and to what extent?. 18

2.4........ How would the problem evolve if no action is taken. 18

2.4.1..... Construction of the baseline scenario. 18

2.4.2..... Analysis of the baseline scenario. 19

2.5........ Analysis of subsidiarity and EU added valued. 22

2.6........ Objectives. 23

2.7........ Consistency of these objectives with other EU policies. 23

3........... Description of Policy Options. 24

3.1........ Options discarded at an early stage. 24

3.2........ Options shortlisted for scenario analysis. 26

3.2.1..... Option 1: "Business-as-usual" ("baseline scenario") where no specific EU actions are taken to reduce the use of plastic carrier bags. 26

3.2.2..... Option 2: Voluntary commitment of a significant share of the EU retail sector not to provide single-use plastic carrier bags. 26

3.2.3..... Option 3: Setting an EU level prevention target for single-use plastic carrier bags combined with economic insruments and accompanied by the possibility for Member States to introduce market restrictions by way of derogation of article 18 of the Packaging Directive. 27

3.2.4..... Option 4: Introducing an EU wide ban of single-use plastic carrier bags. 29

4........... Analysis of impacts. 30

4.1........ Underlying assumptions. 30

4.2........ Types of impacts. 32

4.3........ Specific impacts per type of measure. 34

4.3.1..... Option 1: "Business-as-usual" ("baseline scenario") where no specific EU actions are taken to reduce the use of plastic carrier bags. 34

4.3.2..... Option 2: Voluntary commitment of a significant share of the EU retail sector not to provide single-use plastic carrier bags. 35

4.3.3..... Option 3: Setting an EU level prevention target for single-use plastic carrier bags combined with economic instruments and accompanied by the possibility for Member States to introduce market restrictions by way of derogation of article 18 of the Packaging Directive. 36

4.3.4..... Option 4: EU ban on single-use plastic carrier bags. 39

5........... Comparing the policy options. 41

5.1........ Quantitative impacts. 41

5.2........ Other impacts and considerations. 43

5.2.1..... Flexibility of Member States to decide. 43

5.2.2..... Implementation. 43

5.2.3..... Possibility to generate revenues. 43

5.2.4..... Acceptance of the measure. 44

5.2.5..... Raising awareness on sustainable consumption. 44

5.2.6..... Other issues. 44

5.3........ Comparison of the policy options. 45

6........... Preferred option. 46

7........... Monitoring and evaluation. 46

7.1........ Core indicators of progress towards meeting the objectives. 46

7.2........ Broad outline for possible monitoring and evaluation arrangements. 47

ANNEXES. 48

Annex I: Overview national measures to reduce the use of plastic carrier bags. 50

Annex II: Description of types of plastic carrier bags. 64

Annex III: Stakeholder consultation on options to reduce the use of plastic carrier bags and options reinforce of the biodegradability requirements in the Packaging Directive – summary of comments. 66

Annex IV: Plastic carrier bag flows. 68

Annex V: Methodological considerations on setting the level of a prevention target 69

Annex VI: Overview LCA studies on the environmental impacts of different carrier bags. 70

Annex VII: Relative contribution of different environmental impacts of a HDPE bag. 71

Annex VIII: Employment modeling 72

Annex IX: Profits to Manufacturers. 74

List of Tables

Table 1: Weight and number of plastic carrier bags consumed in EU-27 by type, 2010. 10

Table 2: Breakdown of EU plastic carrier bag production by weight 12

Table 3: Summary of EU plastic carrier bag flows by number, 2010 (billions) 13

Table 4: Number of plastic carrier bags used and littered in EU-27, 2010/2020 (billions) 19

Table 5: Tonnage and corresponding percentual values of single-use plastic bags and multiple-use plastic bags, made in the EU and abroad. 30

Table 6: Switches from single-use plastic bags to other types of bags. 31

Table 7: Amount of plastic carrier bags used in the EU, as projected in the Baseline Scenario (Option 1) 34

Table 8: Effects of a 55% reduction in single-use plastic carrier bags used in the EU, 2015. 35

Table 9: Environmental impacts of a 55% reduction in single-use plastic carrier bags used in the EU, 2015. 35

Table 10: Effects of an EU prevention target of 35 single-use plastic carrier bags used per person, 2020. 37

Table 11: Environmental impacts of an EU waste prevention target of 35 single-use plastic carrier bags used per person, 2020. 37

Table 12: Effects of a ban on single-use plastic carrier bags, 2020. 39

Table 13: Environmental impacts of a ban on single-use plastic carrier bags, 2020. 39

Table 14: Quantitative comparison of the main environmental impacts of the options proposed in 2020. 41

Table 15: Quantitative comparison of the main economic impacts of the options proposed, averaged over years 2015-2020, relative to the baseline (business as usual). 42

Table 16: Quantitative comparison of the main social impacts of the options proposed, averaged over years 2015-2020, relative to the baseline (business as usual). 42

Table 17: Qualitative comparison of environmental, economic and social impacts of policy options to reduce use of single-use plastic carrier bags. 45

Table 18: Summary of plastic carrier bag flows in EU, 2010 and 2020 (Mt) 68

Table 19: Main LCAs cited. 70

Table 22: Total number of people employed in the manufacture of single-use plastic carrier bags in the EU (thousands). 73

Table 23: Increase in the number of people employed in the manufacture of multiple-use bags, paper bags and bin liners in the EU (thousands) 73

Table 24: Net change in the number of people employed in the manufacture of all bags in the EU (thousands) 73

Table 26: Single-use plastic bags replacement ratio. 74

Table 25: Unit Costs to Retailers (per 1000 bags) 75

Table 27: Profits to EU Manufacturer from Single-use Plastic Carrier Bags (€ millions) 76

Table 28: Increase in Profits to EU Manufacturers from Multiple-use Bags, Paper Bags and Bin Liners (€ millions) 76

Table 29: Net Change in Profits to EU Bag Manufacturers (€ millions) 76

List of Figures

Figure 1: Single and multiple use plastic carrier bags used per person in EU Member States and EU-27 average, 2010 or latest available data. 11

Figure 2: Bag consumption per Member State, EU-27 average, and 80% reduction target of per capita single-use plastic bag consumption. 28

Figure 3: Relative contribution of different environmental impacts of a HDPE bag. 71

Glossary of Terms

Bags for Life: Multiple-use bags, typically made from LDPE

HDPE (High Density Polyethylene): This is the material from which single-use plastic carrier bags are typically manufactured. Single-use plastic carrier bags may also be referred to as HDPE bags.

LCA: Life Cycle Assessment.

LDPE (Low Density Polyethylene): Plastic carrier bags made of LDPE are designed for multiple-use, have a glossy appearance and are commonly referred to as ‘Bags for Life’.

Multiple-use Bags: This term covers LDPE ‘Bags for Life’, PP bags and other bags made of jute, or cotton intended for multiple-use. Paper bags are not considered to be multiple-use bags.

PE: Polyethylene.

PP: Polypropylene.

Introduction

Plastic carrier bags[1] are a popular and convenient product widely used for transporting shopping items from the store back home. Their ever increasing consumption, and its related impacts, have given rise to strong concerns among the public and policy makers, both within the EU and beyond. Concerns stem in particular from the littering and accumulation of plastic bags in the environment, as well as from inefficient resource use.

Numerous countries and cities around the world have taken measures to reduce the consumption of plastic carrier bags, including bans (e.g. in Switzerland, China, South Africa, Kenya, Rwanda, Congo, Bangladesh, Washington DC and San Francisco in the United States, several states of Australia and India), bans on free provision (Mexico, Hong Kong) and levies (South Korea), as well as voluntary agreements (New Zeeland, Japan, Sao Paolo state in Brazil)[2].

At EU level concerns over the use of plastic carrier bags have led to measures taken in a number of Member States (see Annex I for a full overview). The approaches taken vary both in terms of scope (e.g. measures targeting single-use plastic carrier bags, non-biodegradable plastic carrier bags, bags made of non-renewable materials, promotion of reusable bags) and instruments (e.g. pricing measures, agreements with the retail sector, communication campaigns).

Certain Member States have opted for marketing restrictions. Over the past years, there have been several attempts (e.g. by France and Malta) to ban plastic carrier bags. These measures were withdrawn due, inter alia, to the objections raised by the Commission, inter alia in the light of the provisions in the Packaging and Packaging Waste Directive (Directive 94/62/EC[3]) in its current form. In 2006, Italy adopted a law establishing a ban on the sale of non-biodegradable plastic carrier bags to take effect as of 1st January 2010, later postponed to 1st January 2011. Similarly, in 2011, Spain decided to phase out the placing on the market of single-use non-biodegradable plastic bags leading to a total ban as of 2018.

EU Environment Ministers discussed the issue both at the Environment Council of 14 March and 19 December 2011. On these occasions, a large number of Member States invited the Commission to assess the scope for action at EU level[4].

In the EU, plastic carrier bags are considered as packaging under Directive 94/62/EC). However, there is no EU legislation or policy specifically targeting plastic carrier bags

The measures taken by individual Member States to tackle the unsustainable consumption of plastic bags lack coherence in terms of the objectives pursued (e.g. favouring alternative bags that are not necessarily more environmental friendly from a life-cycle perspective). This and other considerations explain the sense of urgency to address the issue at the European level; this was reflected both in the political discussions at the Environment Council and the massive response to a public consultation conducted by the Commission in the summer of 2011.

1. Procedural issues and consultation of interested parties

This impact assessment (IA) aims at assessing policy options to reduce the use of single-use plastic carrier bags at EU level.

1.1. Consultation and expertise

Studies

A study on the production and consumption patterns of plastic carrier bags, their related impacts and the impacts incurred by the different policy options to reduce their use was performed in preparation of this impact assessment. This study was conducted by BIO Intelligence Services between 11 May and 11 September 2011[5]. An additional study was commisioned to assess in more detail the socio-economic on the impacts of the different policy options. It was carried out by EUNOMIA between July and October 2012.[6]

Internal consultation

An Interservice Steering Group (ISG) was created in June 2011 to follow the preparation of the IA. This group was chaired by DG ENV, with members from the following Commission services SG, SJ and DGs ENTR, RTD, SANCO, MARE, ENER. The ISG with representatives of DGs ENV, ENTR, SG, SJ and SANCO met first to comment on the outline and policy scenarios of the IA. Furthermore, the services were consulted in writing on the progress of the first study conducted by the consultant. A final consultation in writing was performed on the final version of the IA.

External consultation

The preparation of this report was preceded by a public consultation launched on 17 May 2011 via the EUROPA website. The consultation ran until 9 August 2011 and met the minimum standards for consultation.

15 538 responses were provided showing high public concern about the unsustainable consumption of plastic carrier bags and high expectations for EU action to reduce the environmental impacts of plastic carrier bag use. Opinions were divergent on the instruments, but all options received high support with a slight preference for a prevention target on the use of plastic carrier bags. A summary of the responses are available in Annex III.

Comments from the Impact Assessment Board

A first draft of this Impact Assessment was examined by the Impact Assessment Board and discussed during its meeting of 2 May 2012. The Impact Assessment Board made a number of recommendations and requested the submission of a revised version. A second draft was therefore submitted to the Impact Assessment Board on 1 February 2013. This addressed the Board's comments in the following ways: first, it provided additional information on the relevant policy and legislative framework (section 2.7) and it contained more data on the scale of the problems posed by plastic bag littering, especially on marine ecosystems (section 2.1). Member State specific and regional data are presented where available. Second, with respect to the added value of action at EU level, the revised report underlined that the very high consumption of single-use plastic bags in the EU is not only a transnational, but also a common problem requiring a common policy response (section 2.5). Third, the options considered to take action were analysed in more detail (section 3) including the option of removing plastic bags from the scope of the Packaging Directive (section 3.1). Fourth, sections 4.3 and 5 offered a more in-depth assessment of the likely environmental, economic and social impacts of the shortlisted options, differentiating across the affected sectors, while acknowledging certain data limitations highlighted in the two preparatory studies commissioned for this Impact Assessment. Finally, the monitoring and evaluation arrangements were further clarified in section 7.

The revised draft was given a positive opinion by the Impact Assessment Board on 15 March 2013, with some suggestions and recommendations to refine the text further. These suggestions were addressed as follows: the added value of EU action was further examined in section 2.5; section 2.7 was expanded to better place the proposal in the current policy context; and option 3 was updated by making all former sub-options integral parts of the measure to be implemented (section 3.2.3 and section 6). In addition, additional information was provided on possible burden to consumers (section 4.2) and on costs to public authorities, including in those Member States that have already implemented plastic bag reduction measures (sections 4.2 and 5.2.2). The report also provides some further explanation on the attribution of comparative scores to the different options (section 5.3). Finally, section 7 provides furher monitoring and evaluation details.

Commission interservice consultation

Further consideration of the policy options during the Commission's interservice consultation led to the conclusion that it would be difficult to design and implement an EU-wide reduction target applying to all Member States. Instead of establishing a common EU target, it is therefore preferable to introduce in Directive 94/62/EC the obligation for all Member States to reduce the consumption of single-use plastic carrier bags, while allowing them to set their own national reduction targets and to choose the measures to reach those targets. At a later stage the establishment of an EU-wide reduction target could however be considered.

2. Problem Definition

2.1. Problems requiring action

The unsustainable consumption of plastic carrier bags has resulted in littering, and an inefficient use of resources, which are underscored by transboundary environmental impacts (e.g. air, water, marine and soil pollution, biodiversity loss, depletion of resources), as well as economic (e.g. loss of raw materials in the EU, losses for the recyclers and the tourism sector, costs of cleaning littering) and social consequences (e.g. loss of aesthetic value of landscapes, potential impacts on human health).

As confirmed by the Commission public consultation, plastic carrier bags are perceived as a symbol of a “throw-away” society. Their waste is seen as a very visible nuisance as they are used in high volumes, often supplied free of charge or for a low charge and discarded after having been used only once.

2.1.1. Plastic carrier bags in the EU: facts and figures

In 2010 there were 98.6 billion plastic carrier bags (1.61 Mt) placed on the EU market. It is estimated that the vast majority of these bags (89%) are single-use. This means that every EU citizen used around 198 plastic carrier bags[7] in 2010 – which represents more than one bag per day for each European household.

Table 1: Weight and number of plastic carrier bags consumed in EU-27 by type, 2010

|| Weight (Mt) || Number of bags (billions) || Share (% of total number) || Bags per capita

Single-use non-biodegradable || 0.73 || 85.3 || 87 || 171

Single-use biodegradable || 0.02 || 2.3 || 2 || 5

Multiple-use || 0.87 || 11.0 || 11 || 22

Total plastic carrier bags || 1.61 || 98.6 || 100 || 198

As shown in figure 1, the consumption of plastic carrier bags varies across Europe due to differences in consumption habits, environmental awareness of consumers, as well as the existence, effectiveness, and enforcement of specific policy measures. Per capita consumption of single-use plastic bags ranges from 4 in the best performing countries to 466 in the worst performing Member States.

Figure 1: Single and multiple use plastic carrier bags used per person in EU Member States and EU-27 average, 2010 or latest available data[8]

The common factor across Member States with low consumption levels of plastic bags is the fact that plastic bags are not given away for free. Nonetheless, policy measures in place differ from one country to another – from a levy at the point of sale targeting consumers in Ireland, to a tax on producers in Denmark according to the weight of the carrier bags, to voluntary agreements to promote a reusable eco-bag in Luxembourg or to the phase-out of the distribution of thin-walled plastic bags in France. Some Member States (i.e. Austria, Finland and Germany) have strengthened price signals by running public or private awareness-raising initiatives to reduce their use and to promote reusable alternatives (as well as appropriate collection at the end of life). It is important to note that even in countries with low consumption rates such as Austria, consumers still perceive plastic bags as a problem, as confirmed by an opinion poll in which most Austrians expressed support for a ban on plastic bags[9].

At the other end of the spectrum, most Member States with high consumption levels in 2010 had no (or no effective) measures in place to curb plastic bag consumption. For instance, Romania and Italy have both introduced taxation measures that have proved ineffective in tackling the problem, as is explained in more detail in section 2.4.2.

In most EU countries, the bulk of plastic carrier bags consumed are single-use. Data is scarce as to the exact consumption in every country. For some countries only the number of single-use bags is available (Ireland, Romania) or the vast majority are considered to be single-use (Czech Republic). The available data indicates however that consumption of single-use plastic carrier bags varies across the EU, with some countries still predominantly relying on single-use carrier bags, while in others consumption is dominated by reusable plastic carrier bags.

An estimation of the EU production of plastic carrier bags is illustrated in the table below:

Table 2: Breakdown of EU plastic carrier bag production by weight[10]

|| EU Production (Tonnes)

Single-use non-biodegradable || 239 250

Single-use biodegradable || 10 831

Multiple-use || 873 993

Total plastic bags produced (Tonnes) || 1 124 074

As indicated in Table 5, below, a non-negligible part of these plastic carrier bags is imported from outside the EU. Around 30% of all plastic carrier bags and 70% of single-use plastic carrier bags on the EU market are imported, mainly from Asia; for the lightest single-use bags the share of imports would be even higher. In general, imports from outside the EU tend to be thinner single-use HDPE bags, while EU producers tend to specialise in higher-value, thicker LDPE bags due to specific machinery required. On the other hand, woven PP plastic bags (very thick) may be more competitively produced in Asia due to the low costs of the labour involved.

It is estimated that there are about 250-300 producers of plastic carrier bags in the EU, with 15 000 – 20 000 employees. A significant part of the EU plastic carrier bag producers are family-owned SMEs[11].

2.1.2. Impacts

Inefficient use of resources

The production and use of plastic carrier bags contributes to the depletion of natural resources and the increase of waste. Due to their short life span, they rapidly enter the waste stream in high numbers. The inappropriate disposal and end-of-life treatment of plastic carrier bags exacerbate this. Only a small proportion of plastic bags are actually recycled (6,6%) in the EU. The mix of different resins that need to be pre-sorted is a challenge that thwarts recycling. With limited separate plastic collection, the availability of high quality material for recyclers is limited, making the recycling of plastic bags uneconomical.

The bulk of plastic bags collected through municipal or private waste collection systems is instead either used for energy recovery (39%) or landfilled (49,7% or 710 000 tons a year). Especially in Member States with very high overall landfill rates, plastic bags are predominantly or exclusively landfilled. Even if energy is recovered, part of the energy embedded in the production is lost. If plastic bags end up in landfills then those resources are squandered and at a very fast rate. As an example, given that the total energy (calorific value) used to produce one HDPE bag is about 0.39 MJ, it is estimated that the equivalent of 19 billion MJ (5276 GWh) is landfilled every year in the EU, representing more than the production of an averaged nuclear power plant (3161 GWh) and around 77.42 Mt of greenhouse gas emissions[12].

Plastic packaging waste is also increasingly exported for treatment outside the EU. As an example, Polyethylene (PE), the most common polymer for plastic carrier bags, is the largest fraction of plastic waste exported outside the EU. This results in a loss of raw materials in the EU and a growing dependency on imported non-renewable materials. Moreover, this practice can potentially result in even greater impacts on the environment and human health, especially in countries with less stringent environmental regulations.

Even though the EU recycling market for plastic carrier bags is expected to grow in the coming years, this will not happen at a high enough pace to counter balance the growth in consumption and the accelerated loss of resources.

Littering

The same properties that have made plastic bags commercially successful – low weight and resistance to degradation – have also contributed to their proliferation in the environment. They escape waste management streams and accumulate in natural habitats, especially in the marine environment.

Table 3 summarises the littering estimates for the EU. These estimates suggest that over 8 billion plastic carrier bags were littered in the EU in 2010, representing over 8% of the plastic bags consumed in the EU. Single-use plastic bags, account for around 90% of the plastic bags used in the EU, represent the vast majority of littered bags.

Table 3: Summary of EU plastic carrier bag flows by number, 2010 (billions)[13]

|| Used || Littered

Single-use non-biodegradable || 85.3 || 5.73

Single-use biodegradable || 2.3 || 0.004

Multiple-use || 11.0 || 2.3

Total carrier bags || 98.6 || 8.03

Even if the proportion (8.03%) of plastic bags littered may appear low, the absolute numbers and their overall impacts are significant. Once discarded in the environment, plastic carrier bags last for hundreds of years although mostly in fragmented form, which makes them difficult to track. Because they last so long, the cumulative number of plastic bags littered increases over the years. Many of the impacts of plastic littering are of a transboundary and global nature, especially in water courses and the marine environment.

Marine littering is a complex phenomenon and no comprehensive overview covering all EU Member States exist. Nonetheless, there is documented evidence available indicating large debris accumulation in European seas – e.g. along the coasts of the eastern Mediterranean (Greece, Cyprus)[14], [15], [16], the North Sea (200 km west of Denmark), the Celtic Sea and Bay of Biscay (Ireland, UK, France, Spain)[17]. The presence of debris has also been recorded on the deep sea floor in the Eastern Mediterranean[18] and the Sicily Channel (Italy)[19].

Plastics make up most of the marine litter. A study based on samples in 27 oceanographic cruises concluded that plastics – mainly plastic bags and bottles – accounted for more than 70% of total debris in the Baltic Sea, the North Sea, the Celtic Sea, the Bay of Biscay and different areas in the north-western basin of the Mediterranean Sea and the Adriatic Sea[20]. The results of a pilot project on monitoring marine beach litter in Belgium, Denmark, France, Germany, the Netherlands, Portugal, Spain, Sweden, and the United Kingdom confirm these findings. Small plastic/polystyrene pieces (smaller than 50 cm) were found to be the most common type of marine litter items – i.e. found in the highest numbers – on the 100-metre stretches of beach used as reference[21].

While the precise proportion of marine litter attributed to plastic bags is uncertain, research and clean-up projects in different EU regions illustrate the scale of the problem. For example, plastic carrier bags accounted for 73% of the plastic waste collected by trawlers along the Tuscany coast[22]. Similarly, they represented more than 70% of total debris in most stations sampled in the Gulf of Lions and around the cities of Nice and Marseille (France)[23]. Plastic bags were also found on UK beaches, reaching average densities of one bag every 23 metres[24].

The problem of plastic bag waste in water ecosystems does not affect only countries with a marine coastline. Estimates suggest that a considerable amount of the waste from land reaches the sea through rivers. In other words, waste from regions in the interior of the continent can reach the sea along the big European rivers and pollute eco-systems along the way[25].

The impacts of littering

In the marine environment plastic bags can be especially damaging, as documented in many governmental and other reports, as well as in peer-reviewed journals (see references in footnotes 15 to 43). Animals are injured or killed by entanglement or ingestion of plastic bags mistaken for food. At least 267 different species are known to have suffered from entanglement or ingestion of marine litter, including 86% of all sea turtle species, 44% of all seabird species, and 43% of all marine mammal species.[26] Over the past 25 years, 10% of all dead animals found worldwide had been entangled in plastic bags[27]. In the North Sea, the stomachs of 94% of all birds contain plastic, and 55% of all birds exceed the ecological quality objective level of 0.1g of plastic in the stomach[28]. Fragments of plastics were found in the stomachs of 35% of fish in the North Pacific, with an average of two pieces of plastic ingested per fish[29]. Plastic bags have been also found in stomachs of several endangered marine species, such as green turtles[30], [31], loggerhead turtles[32], [33], leatherback turtles[34], black footed albatrosses[35], harbour porpoises[36], etc.

The true rate of entanglement and ingestion of plastic debris is however difficult to assess given that many animals that die of these causes may sink to the sea floor or be consumed by predators. Therefore, these figures represent most likely conservative estimates of the scale of the problem.

Once plastic bags start degrading, they break into small pieces and end up as micro-particles that pollute the soil, water and the sea-bed, threatening the functioning of ecosystems. The accumulation of plastic fragments is of particular concern as they are difficult to remove from the environment and they have the potential to be ingested by a much wider range of organisms, able to affect fish stocks. The accumulation of plastic debris on the seabed can inhibit gas exchange between the sediment layers and the overlying waters, thus depriving organisms of adequate oxygen supply, interfering with normal ecosystem functioning and altering the make-up of life on the sea floor[37]. Furthermore, small organisms can use plastic debris as raft to grow and travel long distances across the ocean/sea and may settle in areas where they are non-native, and become invasive[38].

Plastic bag litter also pollutes the environment by transferring intrinsic chemical substances into ecosystems. Plastic debris acts as a sponge for persistent organic pollutants (POPs), such as hydrocarbons, pesticides (DDT) and polychlorinated biphenyls (PCBs) present in the environment. Living organisms ingest plastic particles and pass on the toxic substances across the food chain where their concentration increases along the way ("bio-magnification"). Small and microscopic plastic fragments resulting from the fragmentation of plastic bags present a likely route for the transfer of these chemicals due to their large "surface to volume" ratio, meaning that they are available to a wide range of organisms. Adverse effects have been observed in laboratory animals and measurable levels of such chemicals have been found in humans, the main channel for ingestion being through the consumption of fish[39].These effects present potential impacts on human health that have yet to be fully documented.

Besides impacts on the marine environment, public health and the fishing industry, littering also has economic and social costs in terms of wider loss of tourism and the need for litter clean-up activities. In Luxembourg, the annual costs for cleaning littering only along the national roads and highways were estimated to around €1 million[40]. In 2004 UK local authorities, industry and coastal communities spent approximately €17.7 million cleaning up marine litter[41]. Costs can rise even higher if other indirect costs are also taken into consideration. To illustrate this, it was estimated that in a worst case scenario the cost to the Shetland community (population 22,000) could be approx. €7.1 million per year, including the costs of cleaning as well as costs for aquaculture, power generation, farming, fishing, harbours and lifeboat launches[42].

2.2. Underlying drivers of the problem

Several factors have led to the current situation of plastic carrier bags in Europe:

Market failure and low public awareness: The use of plastic carrier bags entails negative environmental externalities (littering, greenhouse gas emissions, contamination of air, soil and water, and impacts on ecosystems and human health) that are not reflected in the prices paid by the end users, which normally receive these bags for free. Customers are not encouraged to limit their use of plastic carrier bags precisely because they receive them for free or for a very low charge, while retailers are not encouraged to limit the hand-out of plastic bags because they are inexpensive to provide. Free distribution prevents consumers from being aware of the value of plastic carrier bags and the associated impacts and costs of their use, and creates the perception that they represent an unlimited resource.

Implementation and enforcement failures of the existing legislative framework governing packaging and packaging waste: The Packaging Directive requires national systems to be set up for the collection and recovery of packaging waste. The low level of separate collection for recycling and the prevalence of landfilling and littering problems indicate that infrastructure set up at national level is failing to provide for an effective collection and resource-efficient recovery of plastic carrier bags. Consumption trends such as eating out (away from home) and a greater use of public spaces[43], combined with the lightweight and convenience of plastic bags have added to the difficulties of managing the challenges of plastic bags. The collection infrastructure needs to be adapted to these societal changes. However, this is unlikely to happen quickly enough, especially taken into consideration the uneven development of the waste collection and treatment infrastructure across the EU.

The drivers of the problem are complex and the effective implementation of the existing EU acquis will not be enough to address the growing use and impacts of plastic carrier bags, in particular those of single-use. New measures are needed to increase consumer awareness on the costs and effects of unlimited consumption of single-use plastic carrier bags, and encourage more resource efficient practices.

2.3. Who is affected, in what ways, and to what extent?

EU citizens: all citizens are at least indirectly affected by threats related to inadequate management of plastic carrier bags, in terms of unsustainable resource consumption and pollution of air, water and soil that lead to animal deaths, loss of fish stocks, possible ingestion of contaminated fish and public health impacts. In addition, EU citizens are suffering from the impacts of littering while bearing the costs of collection, treatment and cleaning up of plastic bags waste.

Non-EU citizens: The unsustainable consumption of plastic carrier bags in Europe affects citizens in countries outside the EU due to the cross-border nature of pollution and littering, and especially marine littering. In addition, plastic waste, including plastic bags, is increasingly exported outside the EU for end of life treatment. This creates environmental impacts such as GHG emissions associated with transport and treatment, in certain cases, in sub-standard facilities.

Plastics recyclers: plastic bags in the EU are predominantly veered towards energy recovery and landfilling, and are increasingly exported for recycling outside the EU. Plastic recyclers are affected by the loss of a potential source of raw materials for recycling, and therefore by a loss of revenues.

Public authorities are affected by the increased costs and administrative burden associated with plastic carrier bag consumption, in terms of cleaning littering costs as well as enforcement of prevention measures aimed to reduce this consumption.

Tourism industry and local businesses: Littering incurs an aesthetic cost to society which can affect local businesses, especially the tourism industry.

Fishing industry: The pollution of the sea results in losses in fishing stocks, which translates into a loss of 'raw material' for the fishing industry as well as loss of fishing time and extra costs due to damaged equipment.

2.4. How would the problem evolve if no action is taken

A baseline scenario was constructed in order to assess how the plastic carrier bags consumption and end-of-life is likely to evolve without additional European initiative. The analysis has been limited to the "foreseeable future", i.e. until 2020.

2.4.1. Construction of the baseline scenario

The baseline scenario is based on the annual PRODCOM[44] data on EU production/sales of all plastic bags and sacks (PE[45] and other), which is projected to 2020 by assuming the same average annual change over 2011-2020 as for 2003-2010. The projections for the evolution of plastic carrier bags assumed a constant share of plastic carrier bags in the total EU production of plastic bags and sacks. The same reasoning was applied in projecting the evolution of the production of different types of plastic carrier bags.

These figures were then adjusted to trade to provide an overview of the amounts of plastic carrier bags placed on the market in 2020. EU-27 imports and exports (extra-EU trade) of all plastic sacks and bags for 2003-2009 were taken from PRODCOM and projected by assuming the same average annual change over 2011-2020 as for 2003-2010. Both imports and exports of plastic carrier bags are projected to rise over the scenario period.

Based on the amount of plastic carrier bags placed on the market, the EU population and the average weights of different types plastic bags, the consumption per capita was then projected to 2020. When converting from weight to number of plastic carrier bags used per person, EU-27 population was assumed to grow in line with International Monetary Fund projections, i.e. from 499.2 million in 2010 to 510 million in 2020. Furthermore, average weights were estimated for single-use non-biodegradable (8.5 g), single-use biodegradable (8.9 g) and multiple-use plastic (78.9 g) carrier bags. These weights were assumed to remain constant over the projection period.

The resulting projections were adjusted where appropriate to take into account the effect of national policies already in place. The baseline scenario takes into consideration that certain measures taken between 2003 and 2010 might not deliver the same effects after 2010, as well as the fact that certain recent measures might not yet have fully produced their effects.

2.4.2. Analysis of the baseline scenario

At EU-27 level, the number of plastic carrier bags placed on the market is projected to rise from 99bn in 2010 to 111bn in 2020. Over the same period, EU-27 population is also projected to rise, from 499m to 510m. The number of bags used per capita thus increases by a small proportion, from 198 bags per capita in 2010 to 217 in 2020. The share of single-use plastic carrier bags is expected to remain stable at 89% of the amount of all plastic carrier bags over the projected period and thus slightly increasing in terms of use.

Current EU plastic bag production is shown in Table 5. Although EU overall production of plastic carrier bags is estimated to increase, single-use plastic carrier bags will be mostly imported from third countries. According to PRODCOM data, EU production of overall plastic bags and sacks remains relatively constant in terms of weight, from 3.43 Mt in 2003 to 3.37 Mt in 2010 projected to 3.39 Mt in 2020. Of these, it is assumed that plastic carrier bags only have a constant share of 33% of the total EU production of plastic bags and sacks. EU production of plastic carrier bags increases slightly, from 1.12 Mt in 2010 to 1.13 Mt in 2020. As to the types of plastic carrier bags produced in the EU, the market share of single-use bags and reusable bags will slightly decrease, while the share of biodegradable bags is projected to grow[46]. On the other hand, the share of single-use plastic carrier bags imported from outside EU is estimated to be of 70%. A detailed overview of plastic carrier bags flows in the EU in 2010 and 2020 can be found in Annex IV. In terms of plastic carrier bags treatment at the end of life, the rate of recycling is expected to increase at a rate of half a percentage point per year, from 6.6% in 2010 to 9.3% in 2020. Energy recovery is expected to remain constant at 39% while landfilling and incineration without energy recovery will decline from 49.7% to 46.9%.

Table 4: Number of plastic carrier bags used and littered in EU-27, 2010/2020 (billions)

|| Total bags used (billions) || Bags used per person || Bags littered (billions)

|| 2010 || 2020 || 2010 || 2020 || 2010 || 2020

Single-use plastic bags || 87,6 || 98,7 || 176 || 194 || 5,704 || 6,312

Single-use non-biodegradable || 85,3 || 92,2 || 171 || 181 || 5,7 || 6,3

Single-use biodegradable || 2,3 || 6,5 || 5 || 13 || 0,004 || 0,012

Multiple-use || 11.0 || 11.8 || 22 || 23 || 2.3 || 2.3

Total || 98.6 || 110.5 || 198 || 217 || 8.03 || 8.61

The share of plastic carrier bags that end up as litter is expected to remain stable. However, the absolute numbers of plastic carrier bags littered will grow from just over 8 billion in 2010 to 8.6 billion in 2020. Due to the persistence of plastic, this means that the stock of plastic carrier bag litter in the marine and land environments will add up every year, and will accumulate in the environment. Particles will reduce in size as weathering and disintegration takes place, increasing the surface area and the possibility of chemical transport, and the potential for ingestion by a wider range of biota[47].

Although in the baseline scenario the problem is not expected to increase dramatically, if no action is taken the situation at EU-27 level will definitely not improve either, accumulating the negative effects year on year.

Several Member States have already taken actions to mitigate the environmental impacts of plastic carrier bags with variable results. The approaches vary from country to country as well as their effectiveness; certain measures are quite successful in addressing the problem while others have delivered only limited results.

The most successful policy initiative has been taken in Ireland where a direct levy of €0.15 per disposable bags, applied to consumers at the point of sale, has resulted in a 90% reduction of disposable bags. The success of the levy is partly owed to its progression in relation to the rate of consumption. Following an observed increase in consumption of disposable bags, in 2007 the levy was raised to €0.22 resulting in a further 20% reduction of use of such bags. In 2011, a maximum ceiling for the levy was set to €0.70 to allow flexibility for further increase overtime[48].

In Belgium a combination of tax on disposable plastic bags charged on producers (€3/kg of plastic bags) and a voluntary agreement of the retail sector (aiming to cut disposable plastic carrier bags by 90% by 2013, compared to 2003) has delivered a reduction of 85% in the use of such bags in 2010[49].

Similarly in Luxembourg, a voluntary agreement between the Ministry of Environment, Valorlux (producer responsibility organisation) and CLC (retailers’ organisation) has resulted in a national ‘eco-bag’ campaign promoting the use of an easily identifiable reusable bag. While the eco-bag was provided for free at the beginning, nowadays it can be bought for €0.80 and it is replaced without charge if damaged. As an accompanying measure, in 2007 the major supermarkets in Luxembourg suppressed the provision of free single-use plastic bags. The campaign was a success resulting in a reduction of 50 million single-use plastic carrier bags distributed between 2004 and 2007[50]. The voluntary agreement was prolonged for the period 2008-2012 with the aim to maintain the rate of consumption of at least 51% of reusable bags ('eco-bags')[51].

However, in other Member States similar attempts have had less success for reasons that may relate to the specific design of the instruments. For example, in 1988 Italy introduced a manufacturing tax of 100 ITL (€0.05) for each unit of plastic bags produced and released onto the domestic market[52]. However, the amount of the tax appears to have been too low to provide a real disincentive to the use of plastic bags. Moreover, the tax was abolished after 5 years. In 2010, Italy still appeared among the countries with the highest consumption of plastic bags in the EU. In 2011, Italy opted for a more radical approach introducing a ban on non-biodegradable plastic carrier bags.

Similarly, in 2009 Romania introduced an eco-tax of 0.2 RON (€0.05) per bag on shopping bags made of non-biodegradable materials. In 2010, the eco-tax was cut to 0.1 RON (€0.025) per bag and it was applied to bags made of non-renewable resources. Little data is available to quantify the effectiveness of their approach; however the Romanian Association of Solid Waste Management estimated a limited decrease in their use, of between 6 and 10%[53].

Most of the worst performing Member States have no specific legislation, nor wide-ranging voluntary commitments by retailers, aiming at reducing consumption of single-use plastic carrier bags (i.e. Estonia, Lithuania, Poland, Slovakia and Slovenia)[54]. More worryingly, in certain Member States with high consumption of plastic carrier bags and potentially high risks of marine littering (e.g. Greece, Cyprus), no measures have been taken to address this issue.

Given the experiences illustrated above, it is highly unlikely that individual actions will provide a consistent and overall response to the environmental impacts of plastic bag consumption, which are transboundary by nature and follow a continuous progression.

Annex I describes the various measures taken by Member States in more detail.

2.5. Analysis of subsidiarity and EU added valued

EU competence to take action to reduce the use of single-use plastic carrier bags stems from the articles of the Lisbon Treaty related to the protection of the environment.

Under Article 191 of the Treaty, EU policy on the environment shall contribute, among other things, to protecting and improving the quality of the environment, protecting human health, ensuring prudent and rational utilisation of natural resources, and combating climate change. It shall be based on the precautionary principle and on the principles that preventive action should be taken, that environmental damage should as a priority be rectified at source and that the polluter should pay.

EU action to reduce the use of single-use plastic carrier bags is also fully in line with the objectives of the Packaging Directive 94/62/EC on Packaging and Packaging Waste. It aims, on the one hand, to prevent and reduce the environmental impacts of packaging and packaging waste; and, on the other hand, to ensure the functioning of the internal market.

With respect to the environmental dimension, the EU's right to act stems from the fact that the high consumption rates of plastic bags represent both a common and a transboundary challenge. An example of the former aspect is that efficient resource use is not only a challenge facing individual Member States – it is also an objective for the EU as a whole. Indeed, the discussions at the Environment Council of March and December 2011 reflected that the consumption of plastic carrier bags is a common concern for a large number of Member States – a concern that led to a call on the Commission to analyse possible regulatory measures.

The transboundary dimension of the plastic bags issue is in particular related to littering. Especially single-use plastic carrier bags can travel over large distances with currents and winds. Even in Member States with well performing waste management infrastructure, high concentrations of marine plastic litter can be detected, for instance 200 km west of Denmark, in the southern part of the Celtic Sea and along the south-east coast of France[55]. Nevertheless, littering of single-use plastic bags will exist as long as these items are consumed, and not managed at a similar level of ambition across the continent; as such, littering affects the EU as a whole.

Current experiences in EU Member States point to the fact that without an EU-wide initiative on plastic bags, effective action to tackle the problem is unlikely. As illustrated in the baseline scenario, the actions taken at Member State level have had variable effects. More worryingly, in certain Member States with high consumption of plastic carrier bags and potentially high risks of marine littering (e.g. Greece, Cyprus), no measures have been taken. Thus, the purpose of EU wide action is to ensure that all Member States, including those that have not taken any or sufficient action so far, take measures to address the problem of plastic bag consumption.

The added value of EU action would lie in providing a framework establishing a shared objective, concepts and definitions, as well as a timeframe and monitoring and reporting arrangements, while leaving Member States free to decide about precise implementation methods, in line with the subsidiarity principle. Common EU action would also facilitate the sharing of positive experiences and best practices from those Member States that have already successfully introduced measures reducing the use of single-use plastic bags.

2.6. Objectives

The general objective of an EU policy initiative on plastic carrier bags is to limit negative impacts on the environment, encourage waste prevention and a more efficient use of resources, while limiting negative socio-economic impacts.

More specifically, the objectives of the initiative are to:

· limit the environmental damage caused by an increasing consumption of plastic bags, in particular in terms of littering and unsustainable resource use, by significantly reducing the amount of single-use plastic carrier bags consumed per capita by 2015;

· tackle a common and transboundary problem in a coordinated and coherent way across the EU.

This Impact Assessment aims at assessing the main environmental, social and economic impacts of different policy options to achieve a reduction of the use of single-use plastic carrier bags. Various levels of ambition will be assessed and compared to a "baseline scenario" (without additional action at EU level) in order to identify the most appropriate instruments minimizing costs while maximizing benefits.

2.7. Consistency of these objectives with other EU policies

The initiative is fully consistent with the overall objectives of EU waste policy as reflected in article 1 of the EU's Waste Framework Directive 2008/98/EC, i.e. to protect the environment and human health by preventing or reducing the adverse impacts of the generation and management of waste and by reducing overall impacts of resource use and improving the efficiency of such use. It is also fully in line with the EU waste hierarchy according to which waste prevention should be given the highest priority – before any other waste management options such as recycling, incineration and disposal. More specifically, the initiative serves the objectives of EU's Packaging and Packaging Waste Directive – environmental protection and preservation of the internal market – upon which it will build.

Given its focus on more efficient resource use, the initiative should also be seen in the context of the "EU2020 Flagship" on resource-efficiency[56] and the Roadmap to a Resource Efficient Europe[57].

By reducing the use of plastic carrier bags the initiative will also contribute to reducing the pressure on biodiversity, especially on the marine environment, in line with the EU Biodiversity Strategy[58] which aims to halt the loss of biodiversity and ecosystem services in the EU by 2020. The initiative also complements the actions against littering and, more specifically, marine litter, undertaken under the Marine Strategy Framework Directive[59]. As such, it is referred to in the recent Commission Staff Working Paper on Marine Litter[60].

While the issue of plastic bag waste can be linked to the broader debate on the planned review of EU waste policy[61], specific solutions for plastic bags have already been identified and tested in practice, both at Member State level and internationally. Moreover, Member States have repeatedly requested the Commission to explore the scope for action at EU level, particularly in response to action taken by some Member States. Also, extensive public consultation on the issue has already been conducted by the Commission and the response has been analysed. For these various reasons, plastic bags will be addressed through a self-standing policy initiative.

3. Description of Policy Options

In light of the environmental impacts of single-use plastic carrier bags referred to in the problem definition and the LCA evidence reviewed, the options put forward will focus on prevention measures targeting single-use plastic carrier bags (both non-biodegradable and biodegradable).

3.1. Options discarded at an early stage

The options below were analysed but were not shortlisted for a detailed assessment:

Full implementation of the Packaging Directive. Full implementation of the Packaging Directive is not expected to bring a significant improvement. The Directive only includes targets for recycling and recovery. Already in 2009, most of the countries had achieved or surpassed those targets. Even in full implementation cases, packaging continues to be transferred to landfills, where single-use plastic carrier bags can escape and end up as litter. Experience shows that even in countries surpassing the obligations of the Packaging Directive littering has not been completely eradicated. As the Directive does not contain concrete provisions on prevention, it is unlikely that full implementation will reduce the growing consumption of single-use plastic carrier bags.

Remove plastic bags from the scope of the Packaging Directive. Plastic carrier bags are undeniably covered by the general definition of 'packaging' and the related criteria set out in article 3.1 of the Packaging Directive. Article 3.1 of the Directive defines packaging as "all products made of any materials of any nature to be used for the containment, protection, handling, delivery and presentation of goods, from raw materials to processed goods, from the producer to the user or the consumer." This definition is accompanied by a number of criteria, also contained in article 3.1, which, among other things, stipulate that "items designed and intended to be filled at the point of sale and 'disposable' items sold, filled or designed and intended to be filled at the point of sale shall be considered to be packaging provided they fulfil a packaging function". In line with this, plastic carrier bags are one of the illustrative examples listed in Annex I of the Directive. Although the list of examples in Annex I is not exhaustive, Member States have an obligation to consider items listed therein as packaging. It is worth recalling that this item was added in Annex I of the Directive after the Court ruled that plastic carrier bags handed to customers in shops constitute packaging within the meaning of the directive[62]. Moreover, this option also risks undermining the environmental objectives of common EU provisions, as this type of bags would not be regulated with regards to other provisions in the Packaging Directive. For instance, single-use plastic bags would no longer need to comply with the restrictions imposed on heavy metals, nor would they be covered by the Directive's recycling targets. Altogether, this option would miss the objective of tackling a common problem in a coordinated and coherent way across the EU.

Require Member States to organise awareness raising campaigns on the impacts of the use of single-use plastic carrier bags. Although this option provides flexibility, it is estimated that awareness-raising campaigns alone are not sufficient to drive a major change in consumer habits. Nevertheless, they can be an important and necessary instrument accompanying other measures such as voluntary agreements, pricing measures, etc.

Set a pricing measure on single-use plastic carrier bags at EU level. This option would require a unanimous endorsement of the Council of Ministers, which is highly unlikely in the current political climate. Further challenges relate to the level of the tax and the administrative arrangements related to its enforcement.

Voluntary agreement of the whole retail sector to phase out single-use plastic carrier bags to customers. Such an option is unlikely to meet with consensus in the short term, as retailers have taken different approaches on the issue of plastic carrier bags. While certain sub-sectors (e.g. food retail sector) have already achieved good progress, others are just starting; therefore different implementation dates might be required. It is expected that small retailers will have more difficulties in implementing the commitment, therefore entailing a high administrative burden in relation to the results.

3.2. Options shortlisted for scenario analysis

3.2.1. Option 1: "Business-as-usual" ("baseline scenario") where no specific EU actions are taken to reduce the use of plastic carrier bags

In this "do-nothing" option, the current situation would continue. There would be no additional policies and measures at EU or national level aiming to limit the consumption of single-use plastic carrier bags. This scenario is described in detail in section 2.4.2.

3.2.2. Option 2: Voluntary commitment of a significant share of the EU retail sector not to provide single-use plastic carrier bags

This option entails a voluntary agreement by a significant share of the EU retail sector to stop providing single-use plastic carrier bags. As is already the case in some Member States, multiple-use plastic bags would be charged, at least at cost recovery prices.

Such an agreement could take the form of a commitment by the retail sector encompassing the largest retailers in the EU. For the purpose of such an agreement it is assumed that 46.9 billion single-use plastic carrier bags are sold or given away by these retailers, which would translate into a 55% reduction of single use plastic carrier bags. Progress towards the achievement of the objective would be reported yearly. A review of the overall achievements would be conducted at the end of 2015 and depending on the results further voluntary or regulatory measures might be envisaged[63].

A targeted voluntary commitment encompassing the players that place the largest share of single-use plastic carrier bags on the market will ensure cost-effectiveness, with respect to public authorities' implementation of the measure. Of course, the resulting reduction would be less significant than in the case of a commitment covering the whole retail sector in the EU. On the other hand, a commitment by the largest retailers would entail less administrative and enforcement burden. The already established reporting and third-party independent monitoring structure would facilitate an effective monitoring towards the objective. It would also save time and costs in creating such a structure.

Hence in 2011 the Commission initiated discussions with retailers within the framework of the EU Retail Forum on a voluntary commitment for the reduction/phase out of single-use plastic bags. After almost one year of intensive and lengthy negotiations, these discussions concluded without a positive outcome. While the Retail Forum's members in principle acknowledged the existence of the problem, and despite the support for a drastic reduction of single-use plastic bags by a substantive number of retailers in the Forum, another significant group of large retailers did oppose such measures. The main arguments put forward by some against the proposed EU voluntary agreement were based on subsidiarity grounds (i.e. it should be left to Member States to take measures), on proportionality (the measure in their view was too cumbersome in terms of monitoring, and controlling "compliance" would not be proportionate to the size of the problem) and on effectiveness. Some retailers argued, for example, that after some time of implementing a charge between €0.10 and €0.20 per bag, they had still observed an increase in the consumption of single-use plastic bags.

Given this situation, both European organisations representing retailers, Eurocommerce and ERRT did not further pursue the idea of a voluntary commitment. Similarly, a proposal for a voluntary commitment initiated by the plastic converter industry to reduce of the use of single-use plastic bags was not taken up by retailers.

The feasibility and success of this option depends on the willingness of the players involved to work on a commonly agreed framework and on any accompanying instruments set up to support a change in consumption patterns[64].

3.2.3. Option 3: Setting an EU level prevention target for single-use plastic carrier bags combined with economic instruments and accompanied by the possibility for Member States to introduce market restrictions by way of derogation of article 18 of the Packaging Directive

Under this option, a minimum prevention (reduction) target for single-use plastic carrier bags would be set at EU level, expressed in number of bags consumed per capita per year. Member States would be free to choose the measures to reach the target although it would be worth making an explicit recommendation to ensure that plastic carrier bags are not provided to consumers for free. This option has three mutually supportive elements: a prevention target; the recommended use of economic instruments (pricing measures); and a possibility for Member States to introduce market restrictions by way of derogation of article 18 of the Packaging Directive. These elements are explained in more detail below.

· A prevention target

A prevention target provides for a clear objective, while leaving flexibility to Member States on the means to be applied to attain it. This is in line with the Treaty provisions on internal market and takes into consideration progress already achieved in some of the Member States. Article 4 (on prevention) of the Packaging Directive could be used to introduce such target in EU legislation.

In terms of the measures to achieve such target, Annex IV of the Waste Framework Directive[65] provides a list of examples of waste prevention measures available to Member States, including prevention programmes, awareness raising campaigns, voluntary agreements, etc. Such measures could also be applied to single-use plastic carrier bags[66].

Stakeholders responding to the public consultation expressed large support for waste prevention targets set at EU level (74,1%), although they did not generally make suggestions on how the targets should be set.

A prevention target should be ambitious enough to address the unsustainable rate of plastic bag consumption in the EU, while taking account of what has proved achievable in those Member States that have already taken action.

Figure 2: Bag consumption per Member State, EU-27 average, and 80% reduction target of per capita single-use plastic bag consumption[67]

A per capita target is deemed the most effective way to reduce the consumption of plastic bags. The target would be set at 35 bags per person per year, based on the average current (2010) consumption of the best 25% performing Member States (i.e. Finland, Denmark, Luxemburg, Ireland, Austria, Germany, the Netherlands, and France), which together have an average of 32 single-use plastic bags consumed per capita. 35 bags used per capita per year in the EU would result in a reduction of approximately 80% of single-use plastic bag consumption, which for the purpose of this impact assessment will be as the preferred reduction target (as reflected in figure 2 above). All Member States are deemed able to reach this target as it only relates to a category of plastic carrier bags (single-use ones) for which consumption can be reduced without significant impacts on consumers, as re-usable alternatives are already available.

The methodological considerations related to setting the level of a prevention target are described in more detail in Annex V of this report.

· The use of economic instruments (pricing measures)

As outlined in section 2.4.2 above, experiences of Member States show that the common denominator of policies that have successfully reduced plastic bag consumption is the introduction of economic instruments. Member States that have introduced effective pricing measures have achieved reductions in the consumption of single-use plastic bags of or greater than 80%.

The prevention target described above should therefore be accompanied by an explicit recommendation to introduce a pricing instrument, building on article 15 of the Packaging Directive, which encourages the use of economic instruments. Such pricing instruments – the exact design of which would again be left to Member States – could take the form of a consumer or a manufacturers/importers levy[68] (revenues would be re-directed to the public budget), or could be implemented through an agreement with the retail sector not to provide plastic carrier bags for free (revenues would go to retailers).

The effectiveness of pricing instruments depends on a number of factors that should be considered in their design phase:

- the instrument should ideally be part of an overall framework of measures aiming to increase resource efficiency (alternatives to plastic carrier bags should not be provided for free either)

- secure early acceptance of the public and ensure visibility of the measure and adequate alternatives (e.g. awareness campaigns)

- secure agreement of stakeholders on implementation

- design systems with minimal administrative burdens for producers and retailers (e.g. by integrating the measure into existing structures)

- effective enforcement (e.g. strong penalties, regular inspections, etc.).

· A possibility for Member States to introduce market restrictions by way of derogation of article 18 of the Packaging Directive

Marketing bans by individual Member States are likely to conflict with article 18 of the Packaging Directive in its current form and may not be justifiable under the exception of TFEU art 114 (5). These legal problems can be addressed by introducing a specific derogation to article 18 of the Directive allowing Member States to introduce marketing bans on single-use plastic bags.

3.2.4. Option 4: Introducing an EU wide ban of single-use plastic carrier bags

Under this option, the provision of single-use plastic carrier bags in retail service would be prohibited. Member States would have to design and implement the appropriate tools to enforce the ban, e.g. by setting dissuasive penalties for non-compliance, organising spot checks and following up on complaints, ensuring appropriate action in case of breach, etc. Multiple-use plastic bags would be charged, at least at cost-recovery prices.

Industry stakeholders responding to the Commission's questionnaire were particularly wary towards the option of a ban, and stressed the need to consider the "unintended consequences", such as a market switch to other materials which may not deliver the desired environmental outcomes.

4. Analysis of impacts

This section analyses the impacts of the different policy options proposed in section 3.2, taking account of the experiences of regions and Member States that have already introduced single-use carrier plastic bags' reduction measures.

The analysis is based on a qualitative and – to the extent possible – quantitative assessment (including modelling) of the environmental and socio-economic impacts of the proposed policy options. The data presented here is based on the two studies commissioned by the Commission services: the first one by Bio Intelligence Service in 2011, the second one by Eunomia in 2012.

4.1. Underlying assumptions

The impacts of the prevention targets and measures presented here depend on their exact design, as to be decided by each Member State, and the evolution of consumer behaviour following their introduction. The models used are based on a number of key assumptions:

a) An entry into force of the measures in 2015. This was done for ease of comparison between the cases.

b) For the resource use and CO2 impacts, it was assumed that:

* The production 1 kg of PE[69] plastic requires about 2 kg of oil (including raw material and energy)[70].

* One single-use non-biodegradable plastic carrier bag weighing 7.5-12.6 g entails the emission of 1.58 kg of CO2, assuming a rate of 40% of reuse[71].

c) Production of plastic bags within the EU vs. external production (imports). This is a key assumption in analysing the socio-economic impacts of the four policy options; 68% of all single-use plastic carrier bags consumed in the EU are imported, as shown in Table 5 below. Rounding up this figure, it is assumed that 70% of all non-biodegradable single use plastic bags are made outside the EU.

Table 5: Tonnage and corresponding percentual values of single-use plastic bags and multiple-use plastic bags, made in the EU and abroad[72]

|| EU Bag Production (Tonnes) || Imported bags (Tonnes) || EU Bag Production (%) || Imported bags (%)

Single-use plastic bags[73] || 250081 || 522500 || 32 || 68

Multiple-use plastic bags || 873993 || 238081 || 79 || 21

d) Switches from single-use plastic bags to other types of bags. Table 6 below shows the 'switching behaviour', based on experiences made in EU Members States where single-use plastic bag consumption has already been curbed: for every 1000 single-use plastic bags avoided, people use on average 29 multiple-use plastic bags; 4 other multiple-use bags; 127 paper bags; and 273 plastic bin-liners. This means that a switch to alternative bags results in an overall reduction of bags used.

Table 6: Switches from single-use plastic bags to other types of bags[74]

Other bags used || for every 1000 Single-Use Plastic Bags avoided

Multiple-use plastic bags || 29

Other multiple use bags || 4

Paper bags || 127

Plastic bin liners || 273

Total || 433

Although situations may vary from country to country, depending on regional production and consumption trends, we assume this table to represent the general patterns for the whole of the EU. For each policy option, the above switching rates are assumed[75].

e) Retailers would charge for multiple-use plastic bags, at least at cost-recovery prices; and would provide paper bags free of charge.

4.2. Types of impacts

All options to reduce the use of single-use plastic carrier bags share the same types of impacts; the magnitude of these impacts will differ from one option to another depending on the degree of ambition and effectiveness of each measure.

The analysis that follows is focused on nine main issues. It looks at three environmental impacts (benefits): resource use, littering rates, and impacts on public spending on waste management and litter collection.

The analysis of economic and social costs and benefits will cover six main issues: administrative burden; impacts on EU producers; impacts on EU retailers; impacts on consumers; impact on employment levels; and public awareness.

Environmental impacts

The main environmental benefits of the proposed measures are linked to the reduced use of resources embedded in the production of single-use plastic carrier bags, and corresponding greenhouse gas emissions; as well as a decline in the amount of waste arising and the number of bags littered. This, in turn, will lower litter clean-up expenses, and expenses incurred in formal waste management (collection, recycling and disposal)[76], which are expected to be reduced considerably, as consumption of single-use plastic bags diminishes. In Member States with high consumption rates, it is expected that there will be higher cost reductions in public spending.

Economic and social impacts

Measures to reduce the consumption of single-use plastic carrier bags, especially regulatory measures, are likely to entail some administrative burden, falling both on the public and the private sector, to ensure implementation and enforcement. The extent of the administrative burden will depend on the choice and the exact design of the measures to be implemented[77].

The impacts on producers are expected to be mixed. The reduction or elimination of single-use plastic carrier bags will entail a decrease in the activity of their manufacturers. On the other hand, producers of multiple-use plastic bags will benefit from the changes. In the EU context, given that 70% of single-use carrier bags are imported from outside EU, we expect limited negative impacts on European producers. Reduced availability of single-use plastic carrier bags would in part be offset by a switch to reusable (LDPE) plastic carrier bags, that are mainly produced in the EU.[78]

Retailers may initially face costs to implement any of the proposed measures (e.g. awareness raising, administrative costs, possible longer transaction times in supermarkets, and an increase in costs of providing free alternatives such as paper bags) but it is likely that these costs can be offset by the increased sale of reusable alternatives and the overall reduction of consumption of single-use carrier bags which retailers currently often provide free of charge[79]. As is the case in Denmark, some retailers may even profit economically from measures to reduce single-use plastic bag consumption (in such cases care should be taken to avoid the public perception that a specific sector is profiting significantly from such practices[80]).

Impacts on employment levels are likely to be slightly negative; although proportionally the impacts are not major, employment in the plastic bags producing sectors is expected to be negatively affected in all the proposed policy options[81].

Consumers may face an initial increase of costs under all options, as the recommended use of economic instruments would imply that they are asked to pay for plastic carrier bags. However, these costs will decrease as consumers switch to reusable alternatives, which save costs in the longer run.

All options will increase awareness of the environmental impacts of single-use plastic bags and resource efficiency aspects at large, and could help promote more sustainable consumption patterns. If designed and implemented in an optimal way, measures have the potential to influence consumer behaviour more broadly (e.g. limit use of disposable items, promote re-use), as well as guide manufacturers' and retailers' business models (e.g. promoting reusable, resource efficient alternatives, provide sizes that better suit consumer needs).

4.3. Specific impacts per type of measure

4.3.1. Option 1: "Business-as-usual" ("baseline scenario") where no specific EU actions are taken to reduce the use of plastic carrier bags

The business-as-usual scenario shows a trend with a slight increase in the amount of plastic bags consumed over the 2010-2020 period, as shown in Table 7. All other policy options are compared to this baseline scenario.

Table 7: Amount of plastic carrier bags used in the EU, as projected in the Baseline Scenario (Option 1)

Impact category || 2010 || 2020

Plastic carrier bags (Mt) || 1.613 || 1.772

Single-use plastic carrier bags (Mt) || 0.73 || 0.842

Plastic carrier bags (billions) || 98.6 || 110.5

Single-use plastic carrier bags (billions) || 85.3 || 98.8

Environmental impacts

In the projected period, the amount of plastic bags consumed rises, with single-use plastic bags experiencing a similar trend. If no action is taken, consumption would keep rising beyond 2020. At EU level, the rate of recycling of plastic bags might experience a slight increase, coupled with a corresponding decrease in disposal rates. However, an increased recycling rate is unlikely to offset the use of natural resources due to increased consumption, and the effects of plastic persisting in the environment. The amount of bags used will increase littering rates. Assessing related impacts in quantitative terms – e.g. in terms of numbers of marine species affected – is however difficult.

Public expenses to deal with plastic bag waste (formal collection and end-of-life treatment) and litter (clean-up costs) are also expected to increase.

Economic and social impacts

In a business-as-usual scenario, no major change is expected in terms of impacts on administrative burden, EU producers, retailers, employment, consumers, and public awareness: these remain almost constant. It is worth mentioning that the projected increase in single-use plastic bag consumption will further increase the costs faced by EU retailers to provide such bags free of charge.

Moreover, the increase and persistence of plastic bags litter will increasingly affect communities dependent on fishing and tourism, in Europe and elsewhere.

4.3.2. Option 2: Voluntary commitment of a significant share of the EU retail sector not to provide single-use plastic carrier bags

Under this option, as of 2015, the members of the EU Retail Forum would stop distributing single-use plastic carrier bags. On the basis of the share of the market of the Forum, such a commitment would result in a 55% reduction of the total amount of single-use plastic carrier bags used in the EU by 2015 compared to the base year 2010 (see Table 8 below). Based on existing experiences, switches to alternative bags are assumed to be as reflected in Table 6 in section 4.1 above.

Table 8: Effects of a 55% reduction in single-use plastic carrier bags used in the EU, 2015

Impact category || Baseline || Retailers' voluntary agreement || Reduction

Plastic carrier bags (Mt) || 1.772 || 1.540 || 0.232

Single-use plastic carrier bags (Mt) || 0.842 || 0.379 || 0.463

Plastic carrier bags (billions) || 110.5 || 59.1 || 51.4

Single-use plastic carrier bags (billions) || 98.8 || 44.4 || 54.3

Environmental impacts

In terms of resource use a 55% reduction in the number of single-use plastic carrier bags translates into a 13% reduction (0.2 Mt) of plastic used to make plastic bags in 2020[82]. The overall number of plastic carrier bags used decreases by 46% (taking into account the partial switch to multiple-use plastic carrier bags), leading to oil savings of 434 kt and avoidance of 81,2 Mt of life-cycle greenhouse-gas emissions. Environmental impacts are summarised in Table 9:

Table 9: Environmental impacts of a 55% reduction in single-use plastic carrier bags used in the EU, 2015

Impact category || Reduction

Oil (kt) || 463 ||

Emissions (MtCO2eq) || 81.2 ||

Bags littered (billions/2015) || 4.1 ||

Compared to the baseline, in 2015 there would be a net decrease in the numbers of bags littered, of 4.1 billion[83]. In addition, the yearly reduction in littered bags would translate into savings to public authorities in terms of budget spent on littered bags collection and disposal (€ 39 million in 2015); and in the formal collection, recycling and disposal of all types of bags (€ 28.9 million in 2015).

Economic and social impacts[84]

The administrative burden on public authorities and their expenditure to implement and enforce this option would be minimal. Retailers would be able to define implementation modalities adapted to their market circumstances.

As expected, EU producers of multiple-use plastic bags, paper bags and bin liners would see their annual profits go up (€ 86 million in 2015). Single-use plastic bag manufacturers, however, would see reduced profits (- € 77 million in 2015).

Retailers would experience a reduction in the costs incurred in providing carrier bags to their costumers, translated into net savings nearing € 500 million per year between 2015 and 2020. Costs for providing plastic carrier bags would be drastically reduced, as retailers would forego the costs of providing single-use plastic bags free of charge, while charging for multiple-use plastic bags. The fraction of the retail sector switching to free paper bags would incur higher costs, but these costs do not exceed the cost reduction from providing 55% fewer plastic bags.

Overall, the combined savings and profits by public authorities, manufacturers and retailers amount to € 478 million per year, on average, between 2015 and 2020.

EU plastic bag producers would experience a reduction in employment of 860 Full Time Equivalents.

As mentioned in the general section on impacts, consumers may face an initial increase of costs, although these would decrease as consumers switch to reusable alternatives.

A voluntary initiative of retailers could contribute to raising public awareness of the environmental impacts of the use of carrier bags, especially if accompanied by awareness-raising campaigns. However, the fact that the commitment does not cover the entire retail sector might result in creating uncertainty for consumers, limit their awareness and stand in the way of a potentially more profound change in consumption patterns.

4.3.3. Option 3: Setting an EU level prevention target for single-use plastic carrier bags combined with economic instruments and accompanied by the possibility for Member States to introduce market restrictions by way of derogation of article 18 of the Packaging Directive

Under this option, each Member State would be required to set a limit of 35 single-use plastic carrier bags per person, with implementation of the measure starting in 2015. This target is estimated to deliver a reduction of 80% in the number of single-use plastic carrier bags used in the EU; corresponding absolute reductions are shown in Table 10:

Table 10: Effects of an EU prevention target of 35 single-use plastic carrier bags used per person, 2020

Impact category || Baseline || Prevention target || Reduction

Plastic carrier bags (Mt) || 1.772 || 1.425 || 0.346

Single-use plastic carrier bags (Mt) || 0.842 || 0.149 || 0.693

Plastic carrier bags (billions) || 110.5 || 33.7 || 76.8

Single-use plastic carrier bags (billions) || 98.8 || 17.5 || 81.2

Member States would be free to determine the instruments to meet this target; differences in the choice of instruments to reach the target will also lead to differences in economic and social impacts. This also applies to impacts arising from market restrictions, where it is impossible to forecast which Member States would set them so as to derogate article 18 of the packaging directive. Consequently, it is difficult to determine the exact quantitative impacts for individual Member States and the other stakeholder groups. Impacts will thus be assessed in terms of EU averages.

Environmental impacts

An 80% reduction in the number of single-use plastic carrier bags in 2015 translates into a 70% reduction in the total number of plastic carrier bags (the difference being due to switching from single-use to multiple-use plastic bags). This amounts to a 20% decrease in tonnes of plastic used in making plastic bags[85], translating into resource use savings in terms of oil used equal to 693 kt and a reduction of 121.4 million tonnes of CO2 equivalents. The overall environmental impacts of this option can thus be summarised as follows:

Table 11: Environmental impacts of an EU waste prevention target of 35 single-use plastic carrier bags used per person, 2020

Impact category || Reduction

Oil (kt) || 693

Emissions (MtCO2eq) || 121.4

Bags littered (billions/2015) || 5.3

Moreover, this option will result in a reduction of 5.3 billion littered bags[86]. The reduction in bags littered would translate into considerable annual savings to public administrations in terms of budget spent on collecting and disposing of littered bags (savings of € 54.4 million in 2015); and in the formal collection, recycling and disposal of all types of bags (savings of € 45.6 million in 2015).

Economic and social impacts

The administrative burden and economic costs would depend on the choice and design of the measures to be adopted at the national level, which could include voluntary agreements, regulatory measures, pricing instruments, awareness-raising campaigns, etc. They would entail administrative costs linked to monitoring (collection and reporting of data) and enforcement. If a pricing instrument is indeed taken up by Member States, costs may, for instance, depend on how well a levy is integrated in existing tax instruments such as VAT. Moreover, and depending on its design, such instrument could bring additional revenues to national budgets or to retailers. The administrative burden facing Member States need to be put in perspective, as they already have an obligation to report on packaging and packaging waste.

At EU level, additional administrative burden would result from ensuring that targets are achieved and from dealing with Member States that do not comply. However, this additional burden is expected to be limited compared to the already existing flow of products and waste statistics reported by the Member States to EUROSTAT.

Finally, it is worth bearing in mind that pricing measures on plastic carrier bags could generate significant revenues for government (e.g. Ireland).

EU producers of multiple use plastic bags, paper bags and bin liners would experience a considerable rise in profits (€ 127 million in 2015). On the other hand, single-use plastic bag manufacturers would again see their profits reduced (- € 120 million in 2015). However, as the 80% target would still allow for some production of single-use plastic bags, in the meantime EU companies could increase their investments in the production of multiple-use plastic or other carrier bags.

Retailers would experience a reduction in the costs incurred in providing bags to their costumers, translated into net savings nearing € 800 million per year between 2015 and 2020. As in the previous scenario, the savings made by all retailers by foregoing the free provision of single-use plastic bags exceed the costs that some would incur if they chose to provide free paper bags. Moreover, these net savings would offset the predicted small costs of adjustment and additional administrative burden[87]. However, small shops might be more affected than larger ones because placing a price on plastic carrier bags might discourage impulse buying by “walk-up” customers. For larger retailers, which represent the main channel for plastic bags distribution to consumers, 'impulse shopping' is likely to account for a smaller share of sales.

Overall, the combined savings and profits by public authorities, manufacturers and retailers amount to € 650 million per year, on average, between 2015 and 2020.

EU plastic bag producers would experience a reduction in employment of 1340 Full Time Equivalents, throughout the initial stages of the implementation of the policy. After this one-off effect employment levels would stabilise.

Consumers may face an initial increase of costs, as the recommended use of economic instruments would imply that they are asked to pay for plastic carrier bags. However, these costs will decrease as consumers switch to reusable alternatives, which save costs in the longer run.

An ambitious and clear reduction target – underpinned by a pricing mechanisms and other measures – would contribute to raising awareness about the problem of high levels of single-use plastic bags consumption and sustainability and resource use issues in general. Nevertheless, specific awareness campaigns would appear necessary to ensure that the objectives of such measures are well understood by consumers.

4.3.4. Option 4: EU ban on single-use plastic carrier bags

As is shown in table 12, a total ban entails a 100% reduction in the number of single-use plastic carrier bags and an 85% reduction in the total number of plastic carrier bags (taking into account a partial switch to multiple-use plastic carrier bags).

Table 12: Effects of a ban on single-use plastic carrier bags, 2020

Impact category || Baseline || Ban || Reduction

Plastic carrier bags (Mt) || 1.772 || 1.351 || 0.421

Single-use plastic carrier bags (Mt) || 0.842 || 0 || 0.842

Plastic carrier bags (billions) || 110.5 || 17.1 || 93.4

Single-use plastic carrier bags (billions) || 98.8 || 0 || 88.9

Environmental impacts

Table 13 below shows the environmental impacts of a complete prohibition of the distribution of single-use plastic carrier bags in the EU in terms of resources use – it would result in a reduction in oil use of 842 kt and save the release of 148 million tonnes of CO2 equivalents. A complete ban would also entail a reduction of 6.4 billion littered bags compared to the baseline scenario. The total lack of bags littered would translate into annual savings to public authorities in littered bags collection and disposal (€ 64 million in 2015); and in the formal collection, recycling and disposal of all types of bags (€ 57.3 million in 2015).

Table 13: Environmental impacts of a ban on single-use plastic carrier bags, 2020

Impact category || Reduction

Oil (kt) || 842

Emissions (MtCO2eq) || 147.6

Bags littered (billions/2015) || 6.4

Economic and social impacts

The ban would incur a significant administrative burden in terms of enforcement and compliance checks. On the other hand, there would be no reporting burden for retailers.

As expected, EU producers of multiple use plastic bags, paper bags and bin liners would experience a considerable rise in their profits (€ 156 million in 2015). Single-use plastic bag manufacturers, however, would see their profits decline considerably (-€ 146 million in 2015)[88]. A ban will affect all single-use carrier bags producers simultaneously, with possibly drastic consequences on production and employment, especially for SMEs. Such concerns have been expressed by a large number of the industry stakeholders who responded to the Commission's public consultation in June 2011. Nevertheless, as EU producers have a competitive advantage in producing higher-value, thicker LDPE bags, there is scope for a shift in production; this would however require timely investments in equipment and the training of staff. EU manufacturers producing alternative carrier bags will benefit from the ban, but they are also likely to face immediate demand pressure for production of alternatives, which will require additional investments. In the medium term, EU producers of multiple-use carrier bags could nevertheless obtain net benefits and quickly offset initial investments.

Retailers would no longer incur any costs in providing bags to their costumers, while charging for multiple use plastic bags, at least at cost-recovery prices. This would translate into net savings nearing € 890 million per year between 2015 and 2020. The fraction of the retail sector switching to free paper bags would incur higher costs, but these costs do not exceed the cost reduction from providing no plastic bags.

Overall, the combined savings and profits by public authorities, manufacturers and retailers amount to € 792 million per year, on average, between 2015 and 2020.

EU plastic bag producers would experience a reduction in employment with a (one-off) loss of 1640 Full Time Equivalents in 2015. On the other hand, employment in the tourism and fishing industries may benefit from a near total reduction of littered bags.

As with the other options, consumers may face an initial increase of costs to replace single-use plastic bags with reusable alternatives. However, these costs will decrease as consumers adapt their behaviour. Nevertheless, if not accompanied by important information campaigns, consumer perceptions of a ban may be negative in terms of a curtailing freedom of choice. In practice, however, the availability of alternatives to single-use plastic carrier bags would not lead to important changes in consumption patterns.

Even though the ban could have positive impacts on consumer habits, a simple disappearance of single-use plastic carrier bags may not per se increase awareness and incentivise consumers to reduce the use of carrier bags or switch to more sustainable alternatives.

5. Comparing the policy options

5.1. Quantitative impacts

This Section compares the different policy options based on a quantitative analysis. Tables 14, 15 and 16 below summarise the quantitative impacts modelled for several environmental, economic and social impact indicators, for each of the four policy scenarios described in the previous sections 3 and 4.

In terms of quantitative impacts the following tables show that a ban on single-use plastic bags would score best against environmental and economic indicators, followed by a prevention target (80% reduction) and a voluntary agreement of the Retail sector (55% reduction), with the business-as-usual scenario having the poorest score. The ban would lead to the largest negative effects on employment (followed by a prevention target and a voluntary agreement, with the business-as-usual scenario not leading to net changes in employment levels); nevertheless, under options 2 to 4 profits made by bag producers are expected to increase. This is due to the differences in profits made from producing single-use and multiple-use plastic bags (for further details on modelling results, data used, assumptions and calculations on the modelling of employment and manufacturer's profits see Annex VIII and Annex IX) .

Table 14: Quantitative comparison of the main environmental impacts of the options proposed in 2020

Environmental Impact Indicators || Baseline (Business as Usual) || Retailers' voluntary agreement || Prevention target || Ban

Tonnes of total plastic carrier bags (% reduction) || 0 || 13 || 20 || 24

Tonnes of single-use plastic carrier bags (% reduction) || 0 || 55 || 82 || 100

Number of total plastic carrier bags (% reduction) || 0 || 47 || 70 || 85

Number of single-use plastic carrier bags (% reduction) || 0 || 55 || 80 || 100

Oil (kt saved) || 0 || 463 || 693 || 842

Emissions (MtCO2eq avoided) || 0 || 81,2 || 121,4 || 147,6

Littered bags' (billions/2015) reduction || 0 || 4,1 || 5,3 || 6,4

Table 15: Quantitative comparison of the main economic impacts of the options proposed, averaged over years 2015-2020, relative to the baseline (business as usual).

Economic Impact Indicators || Baseline (Business as Usual) || Retailers' voluntary agreement || Prevention target || Ban

Costs Reduction to Retailers (€m/year) || 0 || 412,5 || 649,8 || 791,7

Profits to EU Bag Manufacturers (€m/year) || 0 || 5,7 || 3,8 || 4,2

Cost reduction for Litter Collection (€ m/year) || 0 || 34,0 || 46,3 || 54,2

Cost reduction for waste management (€m/year) || 0 || 25,8 || 39,8 || 49,5

Total savings and benefits (€m/year)[89] || 0 || 478,0 || 739,8 || 899,5

Table 16: Quantitative comparison of the main social impacts of the options proposed, averaged over years 2015-2020, relative to the baseline (business as usual).

Social Impact Indicators || Baseline (Business as Usual) || Retailers' voluntary agreement || Prevention target || Ban

Net Change in Employment in EU Bag Manufacture in 2015 (Full Time Equivalents) || 0 || -860 || -1340 || -1641

5.2. Other impacts and considerations

Bearing in mind the objective of a policy initiative on single-use plastic carrier bags – to limit negative impacts on the environment and human health, and to reduce resource and energy use – it is important to complement the above quantitative assessment with a – more qualitative – analysis of impacts that are much more difficult to quantify.

5.2.1. Flexibility of Member States to decide

Even though a prevention target would prescribe an objective, it takes account of the progress already achieved in certain Member States. Moreover, it would grant all Member States the flexibility to decide which measures work best in their national contexts. These conditions would neither be met in the case of an EU-wide voluntary agreement with the retail sector, nor in the case of a ban. Furthermore, the introduction of a minimum target would grant Member States the freedom to reach higher levels of ambition.

5.2.2. Implementation

Changes in institutional arrangements needed to implement a new measure may entail administrative and human resources' costs.

A voluntary agreement with part of the EU retail sector would entail lower implementation costs for public authorities than a prevention target or a ban. Moreover, retailers would be able to define conditions for implementation that are adapted to their market circumstances. On the other hand, a voluntary agreement also comes with risks related to possible free-riding and the difficulty of imposing sanctions in case of non-compliance[90].

The administrative costs related to a prevention target will depend on the exact measures to be adopted by individual Member States. Public authorities are likely to face additional costs related to monitoring (in particular to ensure compliance by retailers with reporting obligations), but this would be a small part of the costs already borne by Member States in the context of reporting on existing targets for packaging and packaging waste. In the case of a prevention target monitoring and enforcement costs are likely to be lower than in the case of a ban.

Member States that have already implemented measures to reduce the use of plastic bags and have already reached the average per capita target will not face further impacts.

5.2.3. Possibility to generate revenues

The recommended pricing instrument for plastic bags accompanying a prevention target for single-use plastic bags would generate revenues, which depending on the precise design of the instrument, could be directed towards public authorities or retailers. If revenues flow to public authorities, they could be used to offset (part of) the necessary administrative costs related to implementation and enforcement. Revenues could also be used to finance environmental projects. In a business-as-usual scenario public authorities (and/or retailers) would not be able to generate additional revenues; a voluntary agreement and a ban would only allow for potential additional revenues from the sale of multiple-use plastic bags, if these were sold at higher than cost-recovery prices.

5.2.4. Acceptance of the measure

As the retailers in the EU Retail Forum only cover 55% of the total EU consumption of single-use plastic bags, if such a voluntary agreement were to happen, many smaller retail shops would not take part. This not only risks confusing consumers as single-use plastic bags would be available in some shops but not others, but also raises questions in terms of a level playing field between all retailers in the EU. Moreover, as mentioned above, there is a risk that individual retailers covered by the Retail Forum do not accept the agreement.

On the other hand, both retailers and consumers could perceive a ban as excessive and disproportional, especially in light of the positive experiences in Member States having taken less stringent measures.

5.2.5. Raising awareness on sustainable consumption

Making single-use plastic bags more scarce and introducing a mandatory pricing measure – as would happen in the case of a prevention target – may help raise consumer awareness of (un)sustainable consumption patterns more broadly, i.e. beyond the consumption of plastic bags only. This effect is likely to be much smaller in the case of a voluntary agreement with only part of the EU retail sector, as this would confront consumers with contradictory messages about the sustainability of plastic carrier bags (which would be available in some places but not in others).

5.2.6. Other issues

A ban and a prevention target may affect small shops more than larger ones because it might discourage impulse buying by “walk-up” customers. For larger retailers, which represent the main channel for plastic bags distribution to consumers, 'impulse shopping' i