I am aware that a report, commissioned by the Irish paper packaging industry which includes producers of single-use cups that will be subject to the levy, was launched last week.
In October 2022, my Department published a Regulatory Impact Assessment (RIA) as part of a public consultation process on draft regulations to introduce an environmental levy on single-use cups. This RIA was produced by EnvEcon Decision Support Ltd, as independent third-party analysis, and was informed by a comprehensive literature review, two major independent nationally representative surveys and two consultations carried out by the Department, the details of which are set out in the RIA.
Life cycle assessment (LCA) is a tool used to assess the environmental impact of a product throughout its life cycle. In a LCA, all raw materials and emissions are considered for each of the processes that make up the life cycle of the product.
There have been many LCAs carried out in this area, assessing whether or not reusable cups represent an environmentally preferred option to single-use cups. The Department adopted a meta-analysis based approach to its LCA of single-use cups and reusable alternatives, to inform the regulations to introduce a levy on single-use cups. In particular, two recent meta studies carried out by the United Nations Environment Programme (UNEP) were considered by the Department; Addressing Single-Use Plastic Products Pollution: Using a Life Cycle and Approach (UNEP 2021) and Single-use beverage cups and their alternatives -Recommendations from Life Cycle Assessments (UNEP 2021)
These studies found, inter alia, that:
• ‘single-use’ is more problematic than ‘plastic’ and that replacing one disposable plastic product with another made of a different material (paper, biodegradable plastic etc) will simply transfer and not necessarily reduce the environmental impact;
• Policies should support, promote and incentivise actions that keep resources in the economy at their highest value for as long as possible, by replacing single-use plastic products with reusable products as part of a circular economy approach;
• reusable cups have a lower overall environmental impact than single-use cups, provided the reusable cup is used enough times and washed efficiently.
My Department’s RIA includes a lifecycle assessment of cups, which considers the methodologies and results from a number of LCA studies in determining the break-even point - the number of cycles a reusable cup must undergo to have comparable or lower environmental impact than a single use cup.
The RIA suggests a break-even point of 10 to 20 uses, which aligns with the broad conclusions of the UNEP study.
I remain satisfied with the assessments made by the published RIA.
