The group said the levy will not lead to a reduction in packaging waste, but will instead damage competitiveness and further harm the vulnerable retail sector. Ambitious targets for Ireland under the EU packaging directive are already being met by industry.
Retail Ireland’s submission said the proposed levy:
- will impose double taxation on the retail sector over and above the already onerous compliance costs of Repak membership
- does not take into account the fact that Ireland has met its 2011 targets under the packaging directive or the move to more environmentally-friendly packaging in recent years
- will result in unintended consequences such as higher food wastage caused by less packaging.
Retail Ireland Director Torlach Denihan said, "While we support the objective of reducing packaging waste, there is no evidence to show that a packaging levy will achieve this. Irish retailers already pay millions of euros to Repak, the industry-funded packaging waste recycling scheme. International precedent shows that countries with such schemes do not have packaging levies.
"A levy on top of Repak fees is double taxation. The 2009 International Review of Waste Management Policy concluded that levies on disposable materials should not be imposed unless packaging reduction targets were not met. Ireland exceeded those targets in 2001 and 2005. We hit the 2011 target of 60 per cent recovery rate two years early in 2009. This levy is simply not necessary.
"Government should carry out a regulatory impact assessment that includes a cost-benefit model of the proposed levy and a justification of its necessity, effectiveness, proportionality and consistency with national and EU policy."
The Department of the Environment held an initial public consultation on a proposed levy on packaging, following a commitment in the Programme for Government . The Minister is now considering responses received.