Environment Bill

Viscount Colville of Culross Excerpts

2nd reading
Monday 7th June 2021 Lords Chamber

[Viscount Colville of Culross (CB)]

My Lords, I welcome the Bill’s quest to ensure that our companies use resources sustainably and limit packaging. Equally significantly it encourages us, the consumers, to become more responsible in recycling and reusing not just plastic but other resources as well. I intend to limit my comments to Part 3, dealing with waste and resources.

Unless we take action to reduce waste now the problem will subsume us all. It is estimated that the amount of plastic entering the oceans will triple by 2040 to become the equivalent of dumping 7 stone of plastic on every yard of coastline around the world. Surveys show that three-quarters of the British public think not enough is being done to stop plastic pollution. Most of us think we are doing our bit to become stewards of the environment. However, so many of us are still resistant to making personal sacrifices of time and money, even if they will benefit the environment.

All of us need a nudge and, in some cases, a big shove from government to make us become more environmentally responsible. The Bill goes a long way to creating that much-needed shove, but it could go even further. I want us to be the most environmentally responsible citizens in the world. I fear that, without rapidly setting targets on waste, making the schemes in Part 3 more urgent and extensive, this country will not achieve that aim. I welcome the initial clauses of the Bill to set targets on waste and resources efficiency, which will be central to the Government’s waste strategy. I hope that they will take the opportunity to surpass the EU’s proposed targets of halving waste and potential resource consumption by 2030.

I am hopeful that the resource efficiency requirements in the Bill will diminish the use of plastics and generate a more circular economy, but there is too much emphasis on the disposal of plastic rather than reducing its initial use—a move which has been strongly supported in a recent letter signed by businesses ranging from Nestlé to Aldi. It feels ungrateful to say that that will not be enough, but it will not. The World Wildlife Fund warns that our emphasis must be not just on the reduction of plastics but on ensuring that the materials used as substitutes do not go on to create another environmental problem. Environmentalists warn that the substitution of wood and paper for plastic can encourage further deforestation, reduction in biodiversity and chemical waste when it is manufactured. So I will be pushing the Government to extend the single charges scheme for plastics to other environmentally valuable resources. The target must be to drive down our culture of single use across a range of materials.

To support this, emphasis must be put on reuse and refill schemes; after all, most plastic can be recycled a maximum of only six times before it becomes unusable. Across the country, we are seeing exciting refill pilot schemes led by Waitrose, Marks & Spencer and Sainsbury’s. They are all developing stores where an increasing range of products can be bought without packaging. Huge consumer brands that have always used packaging as an important marketing tool are coming round to the idea of reusable packaging. Unilever has just created a deodorant holder that can be refilled with deodorant sticks. This is not only environmentally friendly but, from the company’s point of view, binds the consumer even more tightly to the brand.

Supermarkets are keeping audits on how much plastic packaging they are using, but they are doing so with different metrics. I urge the Government to consider standardising these measurements so that a true comparison of the plastic packaging being used can be created—useful information for consumers, companies and government alike. The deposit return scheme is central to this reuse programme; it will give a strong nudge to encourage us all to recycle and, we hope, reuse containers. However, I am concerned that the Government are being too limited by covering only small drinks containers. Michael Gove, when Environment Secretary, said that a scheme covering all drinks containers would give consumers the greatest possible incentive to recycle. However, I fear that the Government’s new, second consultation on the scope of the DRS has a more limited ambition. There are fears that the Government will introduce a limited scheme, and not until late 2024 at the earliest. Already, the Environmental Audit Committee in the other place has called the delay “unnecessary”. As the noble Lord, Lord Randall, said, this should be an area where the Government introduce uniformity across the country. Scotland is already planning an all-inclusive deposit scheme. The UK must move forward together on this. I urge the Government to be more ambitious and speedy in this area.

What brings into sharp focus our inability to use our resources efficiently is the disposal and recycling of our waste. This country exports half its plastic packaging waste, but recycles just a third of that waste. The BBC’s “Panorama” showed the horrific scenes of this waste being exported to Turkey where, far from being recycled, it was burned in backyards in the poorer parts of the country. The Turkish Government have now banned UK recycling exports and the Basel convention limits where the trade can go. I welcome the transfrontier shipping clauses in the Bill, which will further limit the export of our waste but, unless we reduce our use of plastics and other materials, and unless we reduce what we throw away, we will need to either continue exporting our waste or double this country’s infrastructure for dealing with it.

I applaud the Government for the Bill but, as it passes through its various stages in this House, I hope that the Minister will listen to concerns from millions across this country and be open to amending Part 3 and its schedules. Like most other noble Lords, I hope that, when the Bill leaves this House, it will be at the forefront of legislation to protect the environment and make our economies more sustainable. I want us to be a beacon for the world to emulate.

Environment Bill

Viscount Colville of Culross Excerpts

Committee stage
Wednesday 23rd June 2021 Lords Chamber

[Baroness Meacher (CB) [V]]

My Lords, I speak to Amendments 28 and 30, and express my support for all amendments in this group. This is my first contribution on this ground-breaking Bill and I too welcome it. It is wonderful, in many ways, but there is also an opportunity for some tweaks here and there, which could make it a great deal more significant. I speak briefly in the hope that the noble Baroness, Lady Boycott, will indeed be able to speak; she has more knowledge in this area than I ever will, so my comments are limited.

I am sure that all Members of your Lordships’ House agree that plastic pollution in general is one of the greatest threats to our precious planet. I know that, between them, the four signatories will make this case very powerfully in general terms; my purpose is only to support their arguments strongly.

Amendment 28 is modest in the context of the enormity of the plastics problem. To take the example of just one plastic product, it is hard to get my head around the notion that, globally, personal care companies alone produce some 120 billion plastic sachets each year. Others have talked about putting them end to end, back and forth, to the moon 27 times. It is beyond one’s comprehension, but terrifying. These items are totally non-recyclable and, as the organisation A Plastic Planet tells us, there are many reusable and more environmentally friendly alternatives available. Surely the Bill needs to inject a degree of urgency into preventing the continuation of this situation. If there are alternatives, it is difficult for a simple-minded person like me to understand why we are being so careful or modest about this. Why cannot Ministers set a date by which no plastic sachets should be produced, for example? The same sort of eye-watering statistics apply to many other plastic products, including all forms of plastic packaging. They simply need to be replaced.

Yes, the amendment requires Ministers to set a target for the reduction of plastic use by 2030—and this is indeed most welcome—but it says nothing about the level of plastics use at which the target should be set. There could be a target of reducing use by 1%. I really hope that, before Report, we can work with Ministers to achieve an amendment that really would require the end of the use of single-use plastics by a specific date—or, at least, the end of the use of specified single-use plastic products by specific dates. Obviously, this has to be realistic—producers have to make plans—but, unless we make a very clear target for producing complete alternatives, they will not really know where they are. I have a feeling we can do a lot better. In the meantime, I do wholeheartedly support Amendment 28 for putting this crucial issue on Ministers’ agenda. I hope Ministers will, as I have said, be able to come up with something more robust—stronger—in time for Report.

Amendment 30 focuses on single-use plastic packaging. Again, the amendment is hugely important, although, in my view, modest. It requires Ministers, by regulations, to

“set a target for reduction in the production and import of conventional single use plastic packaging”.

But, again, it does not require a specific target to achieve a specified rate of reduction in the use of these products. Again, I wholeheartedly support the amendment for raising the vital issue and cannot see any reason at all why the Government would not accept this amendment—although, as I have said, I hope we can go further.

The Government have made a good start in this field and I want to applaud them—for the ban on plastics straws, stirrers and plastic-stem cotton buds, as well as the ban on microbeads. These are important steps forward, saving literally billions of these items finishing up in the oceans. But, of course, there are many other single-use plastic products. We now have face masks to add to the problem, which we find all over the pavements. What plans are afoot to deal with those?

Amendment 30 takes a more ambitious line indeed on plastic packaging than the Government’s planned tax on items that do not meet a minimum threshold of at least 30% recycled content from April 2022. Surely we should not accept 70% non-recyclable content in the future. Surely, again, we have to be more ambitious. I look forward to hearing the Minister’s response to these modest proposals. I was impressed by the Minister in our recent briefing meeting; it seems that he has a clear commitment to move forward on these agendas. I would like to think that he will want to work with noble Lords in developing stronger amendments before Report.

[Viscount Colville of Culross (CB)]

My Lords, this is my first amendment, too, in the Environment Bill, and I also welcome it.

I was glad to hear the Minister state on the first day of Committee:

“The Government will periodically review targets and can set more, especially if that is what is required to deliver significant improvement to the natural environment in England.”—[Official Report, 21/6/21; cols. 93-94.]


I would ask the Minister to examine Amendment 28, to which I put my name, because it seeks a target for plastics pollution which would do just what he says: namely,

“deliver significant improvement to the natural environment”.

I echo the concerns of the noble Earl, Lord Caithness, about litter. I am especially concerned about microplastic pollution. It is a blight found in the highest mountains and the deepest oceans; it is choking our wildlife, creating gut obstructions in seabirds that cause them poor health and even death, and it is present in the food we eat and the air we breathe, posing a potential danger to human health from ingesting microplastics. There are fears that microplastics might inhibit the ability of our lungs to repair damage caused by Covid-19. I also support Amendment 30 from the noble Baroness, Lady Bakewell.

The Bill, as it stands, focuses very well on the end-of-life solutions to plastics pollution. These are, of course, very welcome, but this amendment adds to the Bill’s provision by targeting the problem of plastics pollution holistically. The Clause 1 target for resource efficiency and waste reduction is also welcome, but it will make only a partial contribution to reducing plastic pollution.

The problem is that products can be efficiently designed but and still create plastic pollution. Lightweight polystyrene packaging, polythene packaging and lightweight plastic bottles do achieve a reduction in resource but, when they are discarded, they create microplastic pollution. Litter from plastic bottles is estimated to contribute 33% of plastic pollution entering our oceans. Likewise, fishing nets are seen as resource efficient when made of plastic, as they last longer and use fewer materials. However, when they break and are discarded, they become floating traps for marine wildlife. Microbeads in plastics make the product work better but constitute 8.8% of Europe’s microplastic pollution. The Government have described this country’s microbead ban as world beating, but it covers only rinse-off products such as shampoo and toothpaste, and it still allows microbeads in the majority of cosmetics.

A plastic pollution reduction target on the face of the Bill will ensure the enforcement of measures such as a ban on maritime waste. Subsection (1) introduces a target to reduce plastic pollution that will ensure that major types of plastic pollution are not overlooked. The inclusion of the wording about reducing

“the volume of all non-essential single-use products”

avoids incentivising substitutions of plastics for other single-use materials, which the noble Baroness, Lady McIntosh, talked about. It works in tandem with my Amendment 139 to Schedule 9.

I hope that the Minister will see this amendment as a response to the Defra Minister’s reply to a similar amendment in the other place, in which she said that

“we actually want to see a more ambitious resources and waste target … which applies holistically to all materials, not just plastic.”—[Official Report, Commons, 21/1/21; col. 261.]

This amendment will realise this ambition by mitigating against the resource efficiency target when it does not deal adequately with the scale of the present plastics crisis. Proposed new subsection (2) sets outs a specific date for the new target—by 31 December—to align with the Government’s own target in Amendment 22. However, the Government have pushed back twice on long-term targets during this Bill’s stages in the other place. So this date seems like a compromise leaving room for further negotiations during the target-setting process. Proposed new subsection (4) reinforces the objective that a reduction in single-use plastics should not incentivise substitutions with other single-use materials that would create an adverse impact on the environment.

I understand that Ministers are concerned that it would be difficult to measure and monitor plastic pollution. Surely the OEP will be able to work with experts to devise the best way to measure, monitor and enforce a target. After all, such targets have been generated for such complex issues as carbon emissions. The Government are also concerned about the international nature of plastics pollution. Rebecca Pow has said that plastic pollution is a “highly transboundary issue” which needs to be tackled at an international level as part of a UN global plastics treaty. This is, of course, right. However, if this Bill is to be world beating, I hope the Minister will agree that this country must show the way by setting up its own domestic targets for plastic pollution. I hope the Minister will look favourably on this amendment.

[The Earl of Lytton (CB) [V]]

My Lords, as this is my first intervention at this stage in the Bill, I draw attention to my vice-presidency of the LGA and my professional interests, particularly in the construction sector, as well as my membership of the Country Land & Business Association. I warmly welcome all the amendments in this group, for the reasons that have already been given. I could not help a bit of a smile when I heard the noble Baroness, Lady Scott of Needham Market, refer to a well-known roadside fast food operator because, following the lockdown, I knew within about 24 hours that it had reopened by the nature of what was in the roadside verges near my home.

We can all recognise the utility of plastics, as referred to by the noble Earl, Lord Caithness. For many automotive, construction and household products, they perform a valuable, life-extending and efficiency function in many things that we use on a daily basis. But I wish to add my voice to those who have a fundamental concern about single-use plastics in general, their clear pathways into discards as litter and microplastics, and the fact that many are not recyclable at all or not generally recyclable in this country.

Environment Bill

Viscount Colville of Culross Excerpts

Committee stage
Wednesday 30th June 2021 Lords Chamber

Transparency from the supermarkets about their own footprint and a ban on the scourge of sachets could be two major contributors alongside the other amendments in this group. I therefore beg to move.

[Viscount Colville of Culross (CB)]

My Lords, I applaud the Government’s determination to drive down the single use of plastics. Clause 54 and its associated Schedule 9 will do a useful job in reducing plastic pollution by introducing a charge on the use of single-use plastics, but Amendment 139 aims to push the Government to be braver and go further with the Bill. I also support the wish to make the use of plastics more transparent in Amendments 130A and 130B.

The lockdown and its subsequent easing have shown us all the dangers of allowing the single-use culture to flourish. I, like many other noble Lords, was appalled when we ordered online delivery shopping during lockdown to find so many of our purchases wrapped in sheaths and sheaths of paper inside a huge cardboard box—all of which had to be thrown away. Many noble Lords have expressed their horror at the litter left behind in our parks and streets as lockdown eased. That litter is not just plastic. It is also wooden cutlery, aluminium cans and paper bags, all of which are used just once and then discarded and all of which despoils our countryside and urban spaces.

On day two of Committee, the Minister said:

“For the long-term legally binding target on waste reduction and resource efficiency, we want to take a more holistic approach to reduce consumption, not just of plastic, but of all materials. This would increase resource productivity and reduce the volume of waste we generate overall”.—[Official Report, 23/6/21; col. 255.]


Does the Minister stand by that statement? If so, will he support the holistic approach demanded by this amendment? That holistic approach means that, although the campaign to reduce plastics must be supported, it cannot be carried out at the expense of driving manufacturers and consumers into substituting them with other single-use materials, as the noble Baroness, Lady Jones, just warned us.

As it stands, Schedule 9 risks creating a situation where single-use plastic will be replaced by other environmentally damaging materials. I have already mentioned that paper is being used extensively for packaging, bags and cups, and wood is being used for cutlery. It is not always possible to determine the provenance of all paper and wood. Not all our pulp for imported paper comes from the EU and the USA. Annually, more than 750,000 hectares of timber—equivalent to nearly half the size of Wales—is imported into the UK from China, Russia and Brazil, where there is a high risk of deforestation and a threat to biodiversity. The paper manufacturing process increases the use of chemical waste, creating water pollution and pouring carbon into the atmosphere. A recent study by the Danish environment agency found that a paper bag must be reused 43 times if it is to have a lower environmental impact than the average plastic bag.

Increasingly, coffee shops and cafés are stocking disposable paper cups that do not contain plastic. As the Bill stands, they will not be included in the new charges. There were 5 billion disposable coffee cups used in the UK last year. Noble Lords only have to look at the aftermath of any big event to see the plethora of paper cups left littering the venue and its surrounding areas. A charge on all single-use items would go a long way to decreasing the number of disposable cups being used. Studies show that a charge of just 25p could reduce that use by more than 30%.

There were similar fears of plastic being substituted by aluminium cans, which can have a similar devastating effect on the environment. Aluminium production is energy intensive and accounts for 1% of global greenhouse gas emissions. Studies show that UK aluminium has one of the highest greenhouse gas impacts per kilogram of any packaging in the UK.

PwC examined the greenhouse gas impacts of packaging types currently used in the UK of the behalf of the Circular Economy Task Force. It found that all materials used for packaging consumed annually in the UK account for 13.4 megatonnes of carbon, or 2% of this country’s carbon emissions. The scale of emissions created by packaging, revealed by this study, makes it clear that the Government’s resources strategy should prioritise the reduction of all virgin materials. In a recent survey of stakeholders, one supermarket said about the drive to reduce plastics:

“The whole agenda needs to be more aligned and more encompassing with carbon. We’re so focused on the plastics that we seem to have lost sight of the impacts around climate.”


This amendment will go far to remedy these threats by bearing down on single-use materials consumption and shifting this country’s focus to a culture of reuse and refill, which must be a priority in developing the circular economy promoted by this Bill. Driving down material consumption and shifting to the reuse of materials must remain the Government’s highest priority.

When a similar amendment to this one was tabled in the other place, the Minister, Rebecca Pow, said that, when looking at this Bill, it bears down on this country’s disposable culture. She said that it needs to be taken into account

“how much of the Bill is aimed at tackling”—[Official Report, Commons, 12/11/20; col. 439.]

single-use plastic. Is this answer sufficient to win the war on single-use culture? Can the Minister explain to the Committee why the Government should not introduce these wider charges? Surely they should be encouraging manufacturers and consumers to reuse as many products as possible; it is a vital part of the circular economy.

[Lord Blencathra (Con)]

My Lords, the noble Viscount, Lord Colville of Culross, has made a very powerful speech on cracking down not just on single-use plastics but on every single-use product. It merits deep consideration.

I was also fascinated by what the noble Baroness, Lady Jones of Whitchurch, said on Amendment 141 about those horrible little plastic sachets. I agree entirely with her that they should be banned, not just because they are dangerous for the environment but because they are fiendish little things. On the few occasions I have had them, I could not get them open, but once you stick them in your wash-bag, they burst spontaneously. There is not much point in them.

Before speaking to Amendment 140, I want to comment on something that the noble Baroness, Lady Bennett of Manor Castle, said in the last debate: that her fridge lasted only 27 years. She should have bought the same model that I believe our late Majesty Queen Elizabeth the Queen Mother bought for Mey Castle, which was still going after 60 years. That is a good use of material.

Amendment 140 seeks to introduce a new clause to ban the use of polystyrene as used for food containers or packaging material by 1 January 2023, and ban its use in construction by 31 December 2026, in five years’ time. Why do I want to do that? Polystyrene is lightweight and has superb insulation properties for keeping items cold or hot. It is widely used for a whole range of functions but where safer alternatives could be used instead; because it is widely used, it is one of the most dangerous and polluting plastics damaging our environment today.

Of course, the manufacturers say than it can be recycled. No doubt it can—that is, if you can get enough of it to a sophisticated facility, it could be done, but does any noble Lord know of any council that actually collects polystyrene, either in food containers or the big chunks of it you get protecting televisions and other electronic items? I have not seen a big bin for polystyrene at any recycling centre, and all the council advice I have seen says to put it in the waste garbage bin.

Environment Bill

Viscount Colville of Culross Excerpts

Committee stage
Monday 5th July 2021 Lords Chamber

[The Earl of Caithness (Con)]

My Lords, I rise to speak to Amendment 133A, to which I have put my name, which was tabled by the noble Baroness, Lady Jones of Whitchurch, and is also supported by the noble Viscount, Lord Colville of Culross, and the noble Baroness, Lady Boycott. This amendment is about what is known as an all-in deposit scheme, which means it catches as many items as possible. The noble Baroness, Lady Bennett of Manor Castle, is absolutely right that our priority ought to be to reduce waste in the first place and so, if we are going to reduce waste, we need a comprehensive deposit scheme. We must stand back and look at what we are trying to do, which is to protect the environment. The bigger and wider the deposit scheme, the more chance we have of keeping the environment in the state in which we would like it to be.

However, I know this causes an awful lot of worry for those who have set up return or deposit schemes at the moment, have invested money in them and do not want to change. It is the nature of industry that there will always be vested interests, but I hope that my noble friend will stand back from them and say that this is needed in the interests of the environment.

My noble friend Lord Trenchard rightly mentioned that any scheme must be pretty much the same across the whole United Kingdom. However, I challenge him on one thing. He said that Scotland had rushed ahead; no, I think that England is the laggard. Why should Scotland have to wait until England finally gets its house in order and its act together? Scotland has once again led the way, and it is time that England got on and followed suit.

Getting a UK comprehensive plan will be very important. There was a consultation on an all-in deposit scheme in 2019, which was overwhelmingly endorsed as the right way forward. All I ask my noble friend the Minister is that, when he introduces a scheme, he keeps it as simple as possible; I ask him please to use the KISS principle with this if he is going to get us to participate in this scheme and make it work in the best way possible.

[Viscount Colville of Culross (CB)]

My Lords, I have put my name to Amendments 133 and 133A because the DRS is one of the most important parts of this Bill. It will have a seismic effect on consumer behaviour, improve our environment and strengthen the circular economy. I and many noble Lords have already spoken about the blight of litter. Two-thirds of roadside litter is estimated to be made up of drinks containers.

The scheme is so important that it needs to be wider in scope and swifter in implementation. The present target of late 2024 at the earliest is far too slow for such an important measure. It was first announced by Michael Gove in October 2017; the initial consultation promised implementation at the start of 2023; now we are told it will be the end of 2024 at the earliest. This chronology means that the present target for the much-anticipated DRS will mean at least six and a half years before implementation, as the noble Baroness, Lady Jones, said.

I know this scheme is complicated, but it is so important that all speed is needed to implement it. I ask the Minister to listen to the words of his colleague Michael Gove who, in praising this scheme in his 2019 speech at Kew Gardens, cautioned:

“Time is running out to make the difference we need; to repair the damage we as a species have done to the planet we have plundered.”


Does the Minister agree with the Environmental Audit Committee, which described the 2024 target as “disappointing”?

I also support Amendment 134 as the Government need to ensure that the scope of the scheme is as wide as possible, as the noble Earl, Lord Caithness, said. They need to embrace the all-in scheme; I can see why the on-the-go 750-millilitre criterion has been posited as an option, but a recent survey of stakeholders in the beverage container sector, which includes supermarkets, manufacturers and consumers, shows 69% support all-in while a mere 15% support on-the-go. To quote Michael Gove’s Kew Gardens speech again,

“I believe an ‘all-in’ model will give consumers the greatest possible incentive to recycle.”


The UK’s recycling record has been dire in recent years. This is an opportunity for us to slack off that shocking record and lead the world in recycling.

It is not hard to understand why all-in is the preference of so many. It allies simplicity and maximum benefit for the environment, and goes to the heart of the circular economy. Studies estimate that an all-in scheme will recycle 3.2 times as many drinks containers as an on-the-go one. The Minister knows only too well the limitations of kerbside collections. Recycling centres have problems separating out the wide variety of materials, and often there are problems finding ways to use the recycled material effectively. I ask the Minister to listen to manufacturers, which say that the specially designed reverse vending machines in the scheme must be much more effective at separating different materials and consequently creating a much higher quality of material for recycling. As a result, the use of recycled material will increase. As the noble Baroness, Lady Bennett, said, reverse vending machines are proving effective in other countries; obviously, the more types of materials and sizes of drinks containers included in the scheme, the more material will be recycled.

The extra materials covered by the amendment would allow clarity for both manufacturers and consumers and conformity with other nations in the UK. The cut-off point of 750 millilitres for drinks containers could distort the market in unthought-of ways. It could encourage consumers to buy bigger bottles of unhealthy fizzy beverages to cover the deposit’s charge, and manufacturers could invent methods to avoid the scheme. A distortion in the market leads to all kinds of unintended consequences. I will give an example from Germany: the exclusion of milk products from such a deposit scheme resulted in soft drinks companies introducing milk protein into their drinks to make sure they were excluded from the scheme. As a result, Germans who were lactose intolerant suddenly could not buy or drink soft drinks. Surely it would be better to make this deposit scheme as simple and wide-ranging as possible to avoid such a distortion.

One of the aims of the Bill is to dazzle the COP 26 with our world-leading environmental legislation. What better way to do that than by the Government putting a DRS on the face of the Bill which would be quick to take effect and wide-ranging in its impact? It would be a statement to the world that Britain intends to reduce its carbon emissions and litter problem and become a recycling superpower.

[Baroness Parminter (LD)]

My Lords, we very much agree with what the noble Viscount, Lord Colville, said about the potential of this deposit return scheme to show us to be a global frontrunner as we move towards a more circular economy. We also very much support the opening amendment moved by the noble Baroness, Lady Jones of Whitchurch, which highlights the laggard nature of the Government in bringing forward this DRS, with the latest consultation showing that it will not come in until the end of 2024. We absolutely agree with her that the Government ought to get on with this by next year as an initial step.

We agree with almost all noble Lords that this must be an all-in scheme. There are costs to that, which the noble Earl, Lord Caithness, highlighted; another is the cost to local councils, as with an all-in system you remove aluminium, which is one of their most valuable recycling assets. However, we very much believe that the benefits outweigh those costs. We must resist those voices saying not to go down the all-in route. The Government’s impact assessment shows that there are very strong benefits to all-in, in the amount of recycling and the impact on cutting littering. That is important, but for me the issue mentioned by the noble Viscount, Lord Trenchard, about consistency with Scotland is the strongest case for all-in. We know where the Scots are going with their DRS; we feel very strongly that, to get the maximum benefits from DRS, there should be consistency with Scotland.

On that basis, although I listened to the very articulate arguments put forward by the noble Baroness, Lady Bennett of Manor Castle, on the case for a differential rate for sizes, I am not sure I want that put in the Bill at this stage, as there is an issue about ensuring that consistency with Scotland is uppermost in our mind. I therefore wish the Government to look at that again but do not support that going in the Bill at this stage, although I understand and accept the arguments she made. I hope the Government will look at them carefully. I look forward to the Minister’s reply.