Ms Tara Buckley:

I thank the committee for the opportunity to present. I represent the owners of 3,500 local, independent and family-owned shops, convenience stores, forecourt stores and supermarkets. RGDATA members are community-based retailers and we share the concerns the Bill seeks to address, namely, the need for waste reduction, increased recycling and reduction in single-use plastic packaging, food and beverage containers and utensils. The independent retailers I represent have played a significant role to date in the dramatic increase in Ireland's packaging recycling rates, from 15% in 1997 to 90% in 2016. Our members pay significant fees to Repak to fulfil their waste management and recycling objectives and to comply with Irish and EU regulations. They also pay for their waste to be taken from the backdoor of the shop as well.

We are active in our communities. We encourage reuse and recycling. Many of our members host recycling centres on their sites and are proactively working in their stores to follow best practice guidelines. They provide staff training on waste management, appoint green champions in their stores and adopt initiatives to reduce the amount of waste going to landfill and be more efficient in their use of natural resources. Many of our members are also trialling initiatives to encourage their customers to use reusable beverage containers.

The shop owners I represent are genuine "green grocers" and take their responsibilities in this area very seriously.

In principle, our members welcome any initiative which helps to reduce waste and contributes to consumers and retailers having more sustainable choices concerning packaging of food products. Accordingly, we are supportive of the general aims and objectives of the Bill. However, we do have concerns about aspects of the Bill which we feel need to be addressed to ensure that any new legislative measures achieve their objectives without unintended consequences. We also believe that any new proposals should be rigorously tested to ensure they will deliver value for money and that they will actually deliver on their objectives.

There are two elements to the Bill: the banning of non-compostable disposable beverage containers and tableware from 2020, and the introduction of deposit and return schemes for sealed beverage containers from July 2019.

On the first provision, banning non-compostable containers and tableware, it is important that consumers and retailers have ready access to affordable substitutes to the products currently being used typically for food to -go in shops and other outlets. There are concerns within the trade at both the cost and availability of substitutable alternatives which will be available in the numbers likely to meet the anticipated demand. Unlike the plastic bag levy, where people could bring their own bags to a shop and customers adapted very quickly to this, there are concerns within the sector that a significant proportion of consumers will be less inclined to bring their own coffee cups, containers or glasses to shops and will be reliant on the food or beverages continuing to be supplied in containers and with utensils from the shop. Consequently it is important that there are cost-effective and substitutable alternatives available to both retailers and consumers before any ban on the existing implements is introduced. Retailers have shown that once alternatives are available, they will fully embrace any initiative designed to reduce unnecessary or unsustainable waste.

On the bring-back scheme proposals in the Bill, we have serious reservations about how this scheme will operate and about the impact the new scheme will have on the existing producer compliance scheme to which retailers contribute. As I have pointed out, our members pay between €1,000 and €3,500 to Repak depending on the size of their store and the amount of packaging they put on the market. They already make a significant contribution to the cost of recycling in Ireland. There is concern that a new deposit-and-return scheme would undermine the rationale and justification for supporting Repak by my members and would amount to a form of double compliance with regulatory obligations with significant extra costs for the smaller retailer.

There are also concerns that such a scheme would be very expensive to set up and that the design of the scheme would need to take account of the place of sale for particular beverage products. For example, if a larger retailer is putting beverage containers out into the market place, then that retailer should have a commensurate responsibility to take back those products in proportion to the volumes put onto the market. It would be an unfair system if smaller retailers found themselves inundated with beverage containers which had been purchased at larger outlets, in circumstances where they would need to install the relevant infrastructure to manage, store and fund a deposit-and-return scheme for products that they did not directly put on the market. Obviously, we would like to see this rigorously tested before being applied because we are concerned about its impact, cost and effectiveness.

In general, we are very supportive of the principle of reducing packaging waste but believe that the design of any legislative measure needs to have due regard to the practical consequences of enactment on both consumers and retailers. There is no point in bringing in new restrictions where easily substitutable alternatives are not available or which serve to undermine existing producer responsibility schemes which are working well. Obviously, we do not place a disproportionate burden on smaller retailers by making them accountable for the sale practices and trading volumes of larger retailers.

In the interest of brevity, I will finish there.