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Submission - Jersey Business Retail - Draft Single-Use Plastics etc. (Restrictions) (Jersey) Law 202

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31 The Parade, St Helier, JE2 3QQ  Telephone: +44 (0)1534 610 300  Email: info@jerseybusiness.je www.jerseybusiness.je

Nikita Hall

Committee and Panel Officer States Greffe

Morier House

Halkett Place

St Helier

Jersey

30th June 2021

Dear Nikita  

Re: Draft Single-use plastics etc (Restrictions) (Jersey) Law 202- [P.61/2021]

In response to the request for views and experiences on the draft Single-use ban p.61/2021, and its consultation process, I have, as requested collated our main points of feedback.

Many retailers, who are time poor, struggle to respond to the the usual method of issuing a lengthy and formal proposition document and so the creation of an information video outlining proposed changes, including imagery of items to be banned and an online survey was very useful. The consultation would have benefited from the addition of an early interactive discussion with a diverse group of retail businesses about the wide variety of bags currently in use and the practicalities of the proposed changes. This would have particularly helped luxury bag users who were left unsure if their bags were be banned or not.

The consultation survey questions were designed to determine a set price for "bags for life" and the lead time to "use up" banned bags. The 2020 survey collected information that led to some welcome changes so, for example, the draft law now includes the specification for a paper "bag for life" as well as four new industry exclusions. These changes have been welcomed by the retail industry.

However, even with these welcome changes, clarity is still need in relation to the specification of a recyclable paper bag for life and specifically the recyclable classification of different components making up the paper bag. For example, if a paper bag has a fully recyclable cotton handle is that bag a recyclable paper bag for life' as illustrated in the draft law?

We have worked collaboratively with Ian Clarkson, the new Head of Retail, Hospitality and Tourism in the Economy Department. Mr Clarkson has been proactive in asking Jersey Business for feedback from the retail industry and we have recently highlighted a specific concern from the industry on the length of time they have to use up non-conforming bags.

This is a particularly difficult issue because the Covid-19 restrictions, which included the forced closure of non-essential retail during 2020 and early 2021, has restricted in-store

shopping and reduced tourist numbers so significantly that footfall has continually been below 45% of a normal year. As a result, retail businesses have an unusually large number of carrier bags in stock which would have to be dumped if the "use up period" remained at six months.

I am very pleased to say that having worked collaboratively with Mr Clarkson to provide industry statistics on the volumes involved, I have been advised an amendment of the "use up period" has now been put forward to increase this timeline to one year.

Continuing this approach, I welcome the desire to communicate the full scope and impact of the changes to businesses through Jersey Business, Chamber of Commerce and the JHA as this will clarify what is required from the retail community well in advance of the regulations coming into force.

If I can give the Scrutiny Panel any additional information, please feel free to contact me.

Lorie Rault Head of Retail Jersey Business

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