The Convenience Stores & Newsagents Association, CSNA, welcomes the opportunity to participate in the committee's detailed scrutiny of the general scheme of the waste reduction Bill. The Bill, not having been subject to a regulatory impact assessment or cost-benefit analysis, is lacking in what we would require for detailed scrutiny. We are also concerned that the Bill may be in contravention of European rules on the freedom of movement of goods and Article 18 of the packaging directive. We are concerned that the Bill provides, by way of regulation, for ministerial action without any further stakeholder involvement. CSNA does not consider that Bills discussed in a pre-legislative format should have amendments suggested that may materially alter their substance without a requirement for re-engagement with stakeholders.
We would like to discuss three elements pertaining to this Bill: the banning of non-compostable tableware, the deposit-return scheme, and the possibility, in lieu of a cup-banning section, of the introduction of an environmental levy on hot beverage containers, the so-called "latte levy".
The CSNA questions whether the proposed ban would materially affect the levels of littering and, if so, how the committee could ensure there would be adequate bin facilities for compostables placed throughout the country. We are aware that EU targets for recycling would not be improved for many involved in home composting and we query how success would be measured. The very considerable changes in every workplace to accommodate separate bins for compostable beverage containers need to be evaluated properly and costed. In many cases, we are aware that the contents of bins within local authority collection areas are mixed with ordinary waste, thereby defeating the effort of the consumer. It is a rarity to find any separate bins for recycling waste in our cities or towns.
The cost to industry of providing compostable tableware is currently six times higher than that of ordinary tableware. There are no guarantees that these costs would reduce solely on the basis of increased demand, leaving the retailer or the consumer, or both, with additional costs.
The Department has indicated that its preferred option, instead of a ban on tableware, would be the introduction of an environmental levy. We would like to make a number of observations on this. Initial reports have suggested that such a levy would be based on a percentage of the retail value of the product. The CSNA, while not advocating a levy, suggests, in the interest of equity, that a unit price be charged rather than a percentage. There need to be very clear rules on the levy's application and exceptions. We are concerned that the levy may give rise to difficulties for retailers with regard to product contamination and their HACCP obligations.
We are concerned that the introduction of the proposed levy, unlike the very successful plastic bag levy, could lead to significant additional costs to retailers. Machines might need to be recalibrated, tills and back-office systems would have to have additional product lines applied to accommodate a two-tier system, and there would be significant additional training costs. If such a scheme is being considered, and assuming the Revenue Commissioners are involved in devising rules for its implementation, detailed consultation is required as a matter of urgency to ensure retailers are not affected negatively in their businesses.
One of the areas the CSNA would be most concerned about would be the lack of an even playing field if a certain style of beverage reseller could avoid charging the levy.
With regard to a deposit return scheme, the CSNA does not believe such a scheme is necessary, given the comprehensive existing shared responsibility scheme, Repak, in place across the country. However, we ask the committee to consider how such a deposit return scheme could be put in place which would not act as a barrier to small manufacturers and distributors getting into the marketplace.
There are many styles of deposit return scheme. The type that would be put in place in Ireland might be for plastic bottles, plastic cartons, aluminium cans and glass bottles. If that is the case, it will be important to ensure it is not limited to retailers but also captures hotels, bars and restaurants. We make reference to this because there is always a possibility that partial systems can lead to returns being made of products on which no deposit has been charged. Similarly, the CSNA is most concerned that products purchased outside the State may be subject to the reclaim of unpaid deposits. If a deposit return scheme was in place, it would need to be sufficiently robust to ensure any retailer would not pay out more than the deposit taken in by him or her. If a retail store was the nearest store to a sports gathering or a music festival, the prospect of enterprising groups returning thousands of bottles to a store in which very few deposits had been taken demonstrates the importance of having adequate responsible controls in place. If the module is being designed to be revenue neutral at a macro level, sufficient consideration must be given to ensure that, on a micro level, individual retailers will be rewarded, not penalised, for their involvement in the scheme.
The majority of our members meet their existing packaging obligations through membership of Repak. We do not believe we should be subject to what might be considered to be double taxation were we to be obligated to maintain our Repak membership and incur additional packaging costs for the same products. It is our concern that if implementation of a deposit return scheme were to lead to a reduced income stream for commercial operators, such a reduction could lead to an increase in Repak fees for members.
