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Submission to the Council for Sustainable Development on Public Engagement on Control of Single-use Plastics

  • Consultation Papers
  • 2021.12.29

  1. The Consumer Council (the Council) is pleased to provide views on the Public Engagement on Control of Single-use Plastics (the PE exercise) launched by the Council for Sustainable Development (SDC).


  1. With its vision on advocating sustainable consumption (SC), the Council published its first[1] and second[2] in-depth study report on the subject in 2016 and 2021.  The 2021 report features a tracking study aimed to review the latest local and overseas development on SC after five years and to find out the status of change in consumer attitude and behaviour.  Findings of the tracking study suggested that there was progress, albeit marginally, in consumers’ attitude and behaviour towards SC since its baseline survey in 2015.  However, although Hong Kong consumers have demonstrated stronger support to various SC behaviours under studied, recycling practice has remained stagnant.  Specifically, 32% of the respondents in the study indicated they seldom or never recycled plastics, which has increased as compared with the Council’s baseline survey (27%).


  1. In the 2021 report, the Council put forward, from the perspective of consumers, 9 recommendations for the consideration of all stakeholders concerned in addressing barriers experienced by consumers to drive behavioural change in realising SC, the 9 recommendations are summarised in Annex 1.


  1. Echoing the recommendation of inviting the Government to introduce measures to achieve specific SC goals, the Council welcomes the launch of the PE exercise and supports the development of different control measures in minimising, and in the long run, eliminating single-use plastic products in local market.  With the initiatives from the United Nations to reduce single-use plastic in 2030, the Mainland China and many other countries are setting up or have implemented policies and legislations to cut down the use of different types of single-use plastic products.  Hong Kong should not be lagged behind in coming up with solutions and taking prompt actions to be a sustainable city.


Concern on single-use plastics


  1. With the current low recycling rate of plastic and ever-increasing amount of waste disposal at landfill, it is a top priority of Hong Kong to mitigate plastic pollution to minimise the impact generated from this waste.


  1. Among the different categories of single-use plastic products suggested by the SDC in the PE exercise, the Council is of the view that all single-use plastic products shall eventually be controlled by regulatory measures but at different priorities.  Higher priority and more stringent control measures shall be given to those plastic products which possible sustainable alternatives are readily available in the market or there is no essential need in using such products in daily life.  Examples are certain plastic packaging materials and plastic shopping bags.


Types of product to be controlled, timeframe and approach for controlling them


  1. It can be found that many products are over-packaged, typical examples are those from online shopping that most of the packaging materials cannot be reused.  However, the banning of all packaging materials for retail and online products is not practical as market need exists.  By referring to the other regions, the Government may consider to ban/restrict plastic materials which are difficult to recycle, such as Polyvinyl Chloride (PVC) and foam type packaging materials, in the first place as these materials may contain and/or release harmful chemicals to the environment or in the sea.


  1. For disposable hotel toiletries, they can be readily controlled and regulated as they can be easily replaced by bulk and refillable showering products.  Good-quality reusable toothbrushes or combs can be provided by the hotel upon request or with certain charge to discourage the usage of single-use plastic products.  Moreover, it is noted that many local and international hotel groups already have sustainability initiatives in their current policy, such that the transition to the regulation on single-use plastics toiletries could be carried out more easily.


  1. Other products such as festivals and celebration products and miscellaneous items (e.g. signage for meetings) are rather difficult to control at regulatory levels.  A collaborative approach between the Government and related business sectors would be more effective to work out appropriate measures to minimise the use of difficult to recycle materials, to improve product design for easy recycling, or to have the related business parties to take the responsibility for recycling the used materials.


Enhancing the Plastic Shopping Bag Charging Scheme


  1. From a waste reduction perspective, the Council believes that tightening the existing Plastic Shopping Bag (PSB) Charging Scheme is a way to reduce waste at source, especially when plastic bags are one of the major plastic wastes in the city.[3]  In general, the Council agrees the suggestions in tightening the current exemption arrangements as proposed in the PE exercise for the sake of further encouraging consumers to develop the habit of “Bring Your Own Bag”.  For instance, the current exemption for PSB carrying frozen/chilled foodstuff in airtight packaging should be removed, foodstuff already fully wrapped by non-airtight packaging should not be provided with free PSB, and only one PSB should be exempted for carrying foodstuff not fully wrapped by any packaging. 


  1. Nevertheless, the Council is aware that some consumers may still want to have a “flat-top bag” for carrying fresh food for hygiene concerns, for example, for fresh meats sold in the supermarkets that are packed in plastic platter and wrapped with cling film only, blood may easily seep out from the packaging and cause contamination.  In this connection, the Council urges the Government to provide reasonable transition period and sufficient education for the retailers and consumers for them to adapt to new and more environmentally friendly selling and shopping practices before removing the current exemptions.


  1. That said, in order to reduce the use of “flat-top bag” during the transition period, the Government may impose measures to control the use of it in supermarkets or similar outlets to avoid the misuse by consumers in other purposes not under the exempted conditions.  For instance, the Government may collect information about the usage, limit the locations where these bags are placed in supermarkets (e.g. only have these bags available at the check-out counter) and require the monitoring of such use by staff of supermarkets.


  1. As for the charging level of PSB, the Council is aware that a recent local survey showed that under the current charging level (HK$0.5 per bag), nearly half of the respondents would still use PSBs in their daily lives.  However, if the charging level were to increase to HK$1 per bag, only about a quarter of the respondents would continue to take PSBs, such percentage further fell to less than one-tenth if the charging level were to increase to HK$2 per bag.[4]  The Government may take these findings as a reference when it considers the adjustment level. 


  1. Having said that, the Council considers it important that the Government should monitor the usage of PSBs after the adjustment and conduct reviews on the charging level on a regular basis (e.g. every 5 years) so that the charges would not degrade its effect over time.  Nevertheless, the Council believes that cutting waste at source (such as less packaging or use of recyclable package) is equally important and more efforts should be given apart from imposing a high cost for consumers in the hope of changing their behaviour in using of PSBs.  


  1. The Council is also of the view that the existing feature of allowing retention of the PSB charges by sellers/retailers should be reviewed to provide a peace of mind to the public that the charges, as an environmental levy, are used for related purposes but not for business profiteering.


  1. Subject to the effectiveness of the adjustment of charging level, the Council suggests that the Government may explore if other policy measures could be implemented to lower the usage of PSBs further in the long run.  Across the globe, various places have already implemented policies to regulate PSBs, such as economic instruments (e.g. taxes) and marketing restrictions (e.g. bans). 

  • Australia, Canada, France, Germany, Taiwan, South Korea, and some locations in the United States, have already banned or will ban the distribution of PSBs.[5]

  • In the Mainland China, non-degradable plastic bags are banned in phases subject to business sector and location started from 2020; a fully ban across all sectors and in all cities to happen by the end of 2025.

  • In Sweden and the UK, taxes are imposed on PSBs.


  1. In the above cases, exemptions are granted for some occasions, for instance, very lightweight plastic bags (with a wall thickness below 15 microns) are exempted from the ban in Germany, lightweight plastic bags are still available for meat and fish, and in bakeries in South Korea, where a charge are applied to the plastic bags.


  1. While extensive consultation, social discussion and wide public support are essential for the establishment of any policy measures, the Council puts forward the above experience in other places for consideration of the Government should it explore further steps in regulating PSBs and other types of plastic bags.


Information on the recyclability and percentage of recycled content of a single-use plastic product


  1. The Council agrees that the information of recyclability and percentage of recycled content of a single-use plastic product is important to consumers when making the right choice.  The Council has worked with the Consumers International in early 2021 to conduct a research project to study packaging of 11 popular global household products and evaluate their materials, labelling and ease of recycling.  The results revealed that the packaging materials of most of the products are difficult to recycle (i.e. use of composite materials and stickers), lack of plastic code or the contained recycled content of these products.  From consumers’ perspectives, there is inadequate information for proper disposal.  Hence, it is suggested that plastic packaging or products to be clearly and correctly labelled on their recyclability so that consumers would know how and where to dispose them to improve recycling.


A platform for sharing information on plastic alternatives among different stakeholders


  1. The Council believes the sharing of information on plastic alternatives or more environmentally friendly product materials among different stakeholders (including businesses, material suppliers and consumers) would be useful for information transparency and decision making.  However, to ensure the alternatives are safe for use, with desired quality and environmental characteristics before introducing these products to the public are also of prime importance.  Currently, there is a lack of relevant product safety standards for the said single-use plastic products in Hong Kong.  The Government or relevant information providers shall have to take the initiatives to safeguard the general public from potential hazardous chemicals released from these products, especially if the product will be used for direct contact with food.  It is recommended that safety regulation for the concerned products could be set up with reference to those in the Mainland China or the European Union (EU) countries.


Green considerations


  1. In response to the PE exercise regarding the questions on the green considerations which would affect a consumer’s choice among different brands for the same type of merchandise, and the willingness of a consumer to pay a premium for the same product made from non-plastic/reusable alternatives, the Council would like to share relevant findings from its tracking study for the reference of the Government.[6]  


  1. The Council’s consumer survey in the study showed that the consumers generally had a strong support to reusable products and were highly concerned about product lifespan, a majority of the respondents were concerned about whether “green material” was used and embraced companies which were environmentally friendly, and an average amount of the respondents concerned about over-packaging.  As for the willingness to pay extra, the vast majority of the respondents were willing to pay a premium for sustainable products, in which most of them were willing to pay an extra 5% or 10%.  Details of the survey results are listed below:

Whether the product can be re-used

  • 69% of the respondents were very concerned or concerned about information as to product lifespan
  • 70% strongly agreed or agreed that they avoided buying single-use products

Whether “green material” is used

  • 57% were very concerned or concerned about whether the product or its materials were recyclable

Whether the brand is “corporate environmental responsible”

  • 58% would give priority to those companies which were environmentally friendly when they chose products or services

Whether the product is over-packaged

  • 48% strongly agreed or agreed that they would consider buying products which were packed in simple or environmentally friendly packaging, or packaging-free products first
  • 55% were very concerned or concerned about whether the product was excessively packaged

Whether the consumer is willing to pay more for the same product made from non-plastic / reusable alternatives

  • 87% were willing to pay a premium for sustainable products; 33% were willing to pay an extra 5% and another 33% an extra 10%


Other comments: A holistic approach to tackle waste


  1. Undoubtedly, due to their massive volume of daily consumption and harmfulness to the environment should they not be disposed of properly, single-use plastics is an important issue which needs immediate and rapid action.  The Council generally supports the overall direction proposed in the PE exercise in eliminating non-essential and hard-to-recycle single-use plastic items.  That said, the Council considers single-use plastics, as well as the wider scope of waste reduction and waste management, should be managed through a holistic approach.  Echoing the Council’s 2021 report, the Council puts forward the following ideas for the consideration of the Government:


Tackle ALL packaging waste


  1. Should regulation be imposed on plastic wrap and bubble wrap used in local packaging for logistics and online shopping, it is anticipated that the packaging material would be shifted to non-plastic options, such as paper-based material.  If such “more-eco-friendly” packaging waste is not disposed of properly and dumped into the landfills, it would still cause waste problem and is not a sustainable solution for the society as a whole.


  1. On this matter, the Council considers reference may be drawn from the EU.  The EU Directive on packaging and packaging waste (Directive 94/62/EC), apart from preventing the production of packaging waste, aims at a wider scope of achievement in promoting the reuse, recycling and other forms of recovering of packaging waste, instead of its final disposal, thus contributing to the transition towards a circular economy.  Most importantly, it covers ALL packaging placed on the European market and all packaging waste regardless of the material used.  The Council suggests that a holistic policy should be established with objectives to promote the logistics industry to minimise weight and volume of packaging, design reusable or recoverable packaging and reduce the amount of packaging waste ends up in the landfills, irrespective of the material of the packaging.


Promote circular economy and lifecycle approach


  1. Apart from packaging for logistics and online shopping, other single-use plastic products listed in the PE exercise are contributing to an essential part of people’s daily lives, such as product packaging, retail packaging, festival products and signage, etc., especially in a civilised society and for people living in the urban city.  Similar to the idea illustrated above, besides waste reduction at source, the promotion of resource efficiency and the minimisation of its disposal at the landfills when a product approaches end-of-life are equally important.  To achieve sustainable production and consumption, the Council believes that the Government may need to promote discussion and development of circular economy among different stakeholders.  As mentioned in the Council’s 2021 report, circular economy provides opportunities to promote closed material loops and enhanced resource efficiency along the value chains.


Reduce the use of microplastic in cosmetic industry


  1. On top of disposable single-use plastic products in the market, microplastics used in consumer products (such as cosmetic products) are also a key concern in causing health and environmental hazards due to the readiness of microplastics in entering the food chain.  According to a study of the Council conducted in 2018, it was found that a large majority of exfoliating and facial cleansing products claimed to contain plastic microbeads.  However, these microplastics will eventually be entering into the aquatic environment and accumulate in aquatic organisms.  Study by the Council on sea salt in 2020 also reflected that the presence of microplastics in sea salt samples.  Cosmetics Europe recommended to its members to discontinue, by 2020, the use of synthetic, solid, plastic particles (microbeads) used for exfoliating and cleansing, that are non-biodegradable in the aquatic environment.  The Government, therefore, should also take into consideration to set up measures to control these types of products.


Facilitate the shift to sustainable production and consumption practices


  1. Afterall, the shift to sustainable production and consumption involves a change to the current production practices and consumption behaviours.  The Government should facilitate such change by providing support to the businesses (e.g. through financial and technical/research supports), providing education to consumers, developing infrastructure and enhancing information dissemination.  The Council would like to emphasis the need of general education and the importance of raising public awareness in leading the changes in behaviour.  The Council believes that the more the support from the businesses and the consumers is received, the sooner the sustainable goals can be achieved.  The Council believes the Government would continue strengthen its effort in facilitating the change towards a more sustainable production practices and consumption behaviours at the same time when it implements regulations or policies on single-use plastics.


Promote behavioural change through incentives/motivations/recognitions


  1. As a means of facilitation towards consumer behavioural change, the Council is of the view that the launch of appropriate incentive/motivation/recognition scheme(s) supported by the Government could be effective aid to the shift towards SC in the city.  The following examples suggest that effective use of incentives/motivations could help put SC actions into consumer daily habit:


  • Germany: A startup company RECUP has implemented a national share system for the collection, washing and refill of takeaway beverage cups. Consumers can order their drink in a reusable cup upon paying a 1 EURO (HK$8.8)[7]deposit, and then return the cups in any other participating shops or restaurants and receive refund. Some eateries offer discount of around 0.25 EURO (HK$2.2) for consumers who purchase their drink in RECUP.[8]  Up to February 2021, RECUP has 6,000 partner locations around Germany and continues to grow.[9]  RECUP estimates that its program reduces carbon emissions by 11,000 tons, conserves 1.5 billion liters of water, and saves 43,000 trees every year.[10]

  • South Korea: the South Korean Ministry of Environment launched the Green Credit Card in 2011.  Cardholders can earn eco-money points when they purchase low-carbon and eco-friendly products, use public transport and save utility rates.  The accumulated eco-money points could then be used to redeem for cash or other various purposes, such as point swap, buy green products, pay public transportation fares, pay phone bill or donation to environmental funds.  Cardholders are also allowed to use the public facilities such as national parks and museums free of charge or at a discount price, which further serves as a means to promote green lifestyle.  As of December 2016, the number of issued cards exceeded 15 million (55% of the economically active population of South Korea).[11]


  • Plastic Free July is a global initiative which encourages people to refrain from using single-use plastic for the whole month of July.  Its experience-sharing feature could be a motivation for consumers to contribute more in SC.  Participants can visit the campaign website to get tips on plastic reduction, read sharing of other participants and download promotional materials.  In July 2021, an estimated 140 million people across the globe took part in the challenge from 190 countries.  It is estimated that Plastic Free July has reduced global demand by 2.3% of all bottled water, 3.1% of all fruit and vegetable packaging, 4.0% of all plastic straws in 11 years.[12]


  1. As suggested in the Council’s 2021 report, the existing Government’s GREEN$ Electronic Participation Incentive Scheme (the GREEN$ Scheme) could be expanded to reward other scopes of sustainable consumption behaviours apart from waste recycling, such as buying sustainable or environmentally friendly products or services, so as to attract consumers’ participation and promote consumer behavioural change.  In this connection, the Government may consider combining the above incentive/motivation schemes with GREEN$ smart cards, for instance, points be rewarded to consumers participate in designated incentive/motivation scheme(s).  Recognitions may be granted to consumers gaining a certain level of points.




  1. At last, the Council takes the PE exercise as a significant step in enhancing public understanding about the importance of controlling single-use plastics.  With the contribution of views from all stakeholders, the Council hopes the Government, further to the Waste Blueprint 2035, could take a more holistic approach to facilitate the shift to sustainable production and consumption practices and promote circular economy in Hong Kong.


Annex 1

List of the recommendations put forward in the Council’s 2021 report:

Drivers for Behavioural Change of Consumers

  1. Nurture SC understanding and culture through public education and creation of support platform
  2. Strengthen availability and choice of products and services with relevant incentives to encourage consumption
  3. Rebuild recycling habit by convenient, stringent and transparent waste management system

Role and Responsibility of Businesses

  1. Adopt sustainable principles along the value chain, from production to end-of-life disposal
  2. Provide accurate information about the sustainability of products and services
  3. Set measurable sustainability targets and roadmaps

Directions and policies of the Government

  1. Promote research in advancing SC related pattern
  2. Establish long-term and holistic policy to foster recycling and sustainable industry
  3. Introduce legislation and enforcement measures to achieve specific SC goals

For details, please refer to


[1] Sustainable Consumption for a Better Future – A Study on Consumer Behaviour and Business Reporting.  See

[3] According to “Monitoring of Solid Waste in Hong Kong – Waste Statistics for 2019”published by the Environmental Protection Department (EPD) in 2019, “plastic bags” (contributed to 6.9% of total municipal solid waste disposed of at landfills by weight), which include PSB, was the second largest type of plastic waste following “other plastic waste” (10.0%).

[4] WWF. (2021) Existing Plastic Bag Levy Losing Effectiveness - Government should review and promote environmentally friendly practices.

[5]Details of the bans (e.g. types/specifications of single-use plastic bags subject to the ban and exemptions) vary among different places.

[6] See footnote 2.

[7] Exchange rate as of December 2021.

[8] Crossing. (2019) 【德國現場】紙杯其實也不環保:德國人一小時用 32 萬個,他們怎麼解決?

[9]BCG Digital Ventures. (2021) BCGDV Social Ventures Program Part I: Introducing RECUP — One Reusable Container at a Time.

[10]Grist. (2021) This German startup offers a simpler way to recycle your coffee cup.

[11] Korea Environmental Industry & Technology Institute. (2014) Policy Handbook for Sustainable Consumption and Production of Korea.

[12]Plastic Free July. (2021) Our impact.  Plastic Free July is a registered charity based in Australia, but operating across the globe.  It is a key initiative of the Plastic Free Foundation that works towards its vision of seeing a world free of plastic waste.