JT' JTI response to Towards a Litter- Free Scotland. The Scottish qooernment's consultation on a strategy to tackle and prevent litter and fly tipping

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1 - JT' JTI response to Towards a Litter- Free Scotland The Scottish qooernment's consultation on a strategy to tackle and prevent litter and fly tipping 26 th September 2013

2 JAPAN TOBACCO INTERNATIONAL Japan Tobacco International (JTI). JTI is part of the Japan Tobacco Group of Companies, a leading international tobacco product manufacturer. JTI has its UK headquarters in Weybridge, Surrey, and has a long-standing and significant presence in the UK market. Its cigarette brand portfolio includes Benson & Hedges, Silk Cut, Mayfair and Sterling, as well as a number of other tobacco products including roll-your-own tobacco (RYO), also known as hand-rolled tobacco (such as Amber Leaf), cigars (such as Hamlet) and pipe tobacco (such as Condor). JTI manufactures product for the UK market at sites in the UK (in Northern Ireland) and other European countries (for example, Germany). In the UK alone, JTI employs over 1,800 people. JTI contributed over 3.9 billion in tobacco product duty and a total of over 4.9 billion in tax to the UK Exchequer in Gallaher Limited is the registered trading company of JTI in the UK. Address JTI, Members Hill Brooklands Road Weybridge Surrey KT130QU Confidentiality JTI is happy for this consultation response to be made public. INTRODUCTION This document is submitted as JTI's response to "Towards a Litter-Free Scotland", the Consultation on a strategy to tackle and prevent litter and fly tipping. JTI acknowledges that some smokers may discard cigarette ends and packets without regard for the environment. Therefore, our response focuses on our approach to tackling this problem, in the context of our general strategy to support the reduction of litter in general. There are challenges relating to cigarette litter that are unique to the product. Consumers are dealing with a flammable product that must be extinguished safely before consumers can dispose of it responsibly. Since the introduction of the smoking ban in public places it has become increasing difficult for smokers to safely dispose of their cigarette, as often there are limited facilities to safely extinguish a lit cigarette. Currently 23% of the Scottish population smoke 1 and in the 12 months to August 2013 in excess of 4 billion duty-paid cigarettes were consumed", Scottish consumers on average will consume 12 cigarettes a day. JTI has only provided a response when we feel that our experience can add value to the debate, 1 Scottish Household Survey Nielsen MarketTrack 2

3 Strategic approach Q1. Do you agree that the strategic approach proposed (Action 1) should form the basis of the National Litter Strategy's overall vision, mission, values and objectives? JTI takes very seriously the need to encourage individuals to dispose of their litter in a way that does not negatively impact the surrounding environment. We expect smokers, like all members of the public, to accept their responsibilities to keep our environment clean and tidy by disposing of all litter, including Cigarettes ends and packaging, carefully and responsibly. It is our view that the most effective way of addressing the issue of litter is to communicate responsible behaviour through practical and sustainable solutions, such as ensuring adequate provision of bin facilities. In addition, if the problems relating to litter are to be tackled in an effective way, a partnership approach is essential. This means Government, local authorities, NGOs and businesses, including JTI, must each recognise they have important role to play in the fight against litter. We support the Scottish Government in their aim to "help(ing) people understand why binning their waste responsibly matters, and by providing the facilities and services they need to do so. " As part of this, we believe that the Scottish Government should invest in viable, sustainable litter campaigns and the provision of bins in outdoor public areas. We would also strongly encourage local authorities to provide adequate, permanent ashtrays in public areas. Information strategic direction Q2. Do you agree that improved communications (Action 2), education resources (Action 3) and business engagement (Actions 4 and 6) should be the National Litter Strategy's information focus for preventing litter? Agree JTI believes that the best way to prevent litter is through changing people's behaviour by educating, encouraging personal responsibility and providing solutions. In our view there should be a three-pillared approach to tackling litter: (1) Public education campaigns focusing on anti-littering messages; (2) Providing disposal resources for people; and then (3) The enforcement of existing penalties. In our view it only becomes reasonable to pursue the third pillar of penalties when the first two pillars have been fully explored. We believe that government authorities should dedicate a proportion of expenditure to a public education advertising campaign focused on anti-littering messages. For example, Keep Britain Tidy, one of JTl's partners, believes that there tends to be a misconception that cigarette ends are not litter. In order to change behaviour it must be communicated to members of the public that cigarette ends are litter too. As a company, our main focus has, so far, been directed towards the second pillar: providing the means of responsible and safe cigarette litter disposal for those who choose to use our products. 3

4 In Japan, our parent company has engaged in the "Pick Up Litter and You Will Love Your City" initiative since May 2004 in an effort to eradicate public littering by raising awareness of the problem and organising rubbish collection activities. This initiative is aimed at occasions such as community festivals and other public events, and is conducted in cooperation with a variety of parties, including governments, companies, and volunteer groups. Since this initiative began, community clean up events have been held at a total of over 1,400 events, bringing the number of participating groups and organisations to 2,950, and the number of participating individuals to 1.4 million. Approximately 700 tons of litter has been collected over the course of the programme. JTI Italy has also worked with Milan City Council and its local waste disposal company in providing "cenerinos" (free standing ashtrays) to bars and restaurants in the city. They also distributed "Stub-Tidy" pocket ashtrays through national magazines. Details of JTI UK's Stub Tidy campaign and other initiatives are given in answer to subsequent questions. Q3. If you are responding on behalf of a group/organisation: as a business or organisation (Including litter duty bodies) would you find It valuable to have a national recognition scheme which supports you in encouraging positive behaviour (Action 5)1 Yes JTI is a partner of both Keep Britain Tidy and the Campaign to Protect Rural England (CPRE), working with both organisations on a number of projects across the UK. A national recognition scheme may raise awareness of the problem of litter and encourage responsible corporate behaviour from businesses that do not currently have a litter strategy. JTI has long taken a pro-active approach to the problem of Cigarette litter. In 2010 JTI formed part of the Litter Challenge Group, along with the UK Department for Environment, Food and Rural Affairs (DEFRA), Keep Britain Tidy, CPRE and other business organisations. The group was formed in order to develop a nationwide anti-litter campaign, Love Where You Live, which was launched in October As part of our participation in the Love Where You Live campaign, JTI is working with Keep Britain Tidy on a number of anti-litter projects. This includes teaming up with the Liverpool Business Improvement District to support a competition at the University of Liverpool's product design school. Students have been challenged with creating a stubbing plate for the city's heritage waste bins to stop cigarettes from ending up on the floor around them. The successful student's design will then be produced and installed in Liverpool city centre. In addition, we are partnering with the CPRE to work with a group of residents in Middlewich, Cheshire. The Middlewich Clean Team is installing wall mounted cigarette bins in litter hotspots near pubs and bookmakers in the town. We believe that if a sufficient number of cigarette bins are provided, smokers are more likely to dispose of their tobacco litter responsibility. As part of the project, JTI will be measuring the level of smoking-related litter before and after the bins go in, to see how effective the scheme is. There are also plans in place to introduce the lnltlative in other areas across the UK. 4

5 Infrastructure strategic direction Q4. Do you agree that businesses and other organisations have a key role to play in the design of products and packaging to reduce Jitter and that those with litter control responsibilities should be encouraged to recycle more (Actions 6 and 7)1 Partially agree JTI is committed to reducing the impact of smoking-related litter and encourages all smokers to show consideration for the environment and those around them. Our experience has shown that messages in relation to litter should be ones of ownership, personal responsibility and encouragement; we believe messages such as 'Love Where You Live' and 'I Love My City', resonate best with consumers: Aspart of this commitment JTI produces Stub Tidy, a portable, reusable pocket ashtray, for distribution to smokers free of charge. This initiative has been running for the past eight years. In 2013, JTI produced the Stub Tidy (see image below) in conjunction with our partners at Keep Britain Tidy and their Love Where You Live campaign. Since their introduction JTI typically distributes around 100,000 Stub Tidies each year. As the consultation highlights, cigarette litter - cigarette ends and packaging - is the most prevalent type of litter in Scotland. As outlined in our above responses, JTI encourages its customers to behave responsibly, however it is clear that more needs to be done. Greater action needs to be taken by local authorities, businesses and hospitality venues to ensure that smokers are provided with the means to dispose of their cigarette ends responsibly. The increase in smoking-related litter was an inevitable consequence of the ban on smoking in public places, as smokers have been driven outside to smoke with limited facilities to safely extinguish a lighted cigarette. Legislative authorities should acknowledge that regulations like the smoking ban do have a negative impact and/or unanticipated consequences; it is important that full consideration is given to these before introducing any new regulations. We believe that such considerations should have been made via a comprehensive impact assessment. Existing legislation regarding health warnings on packs, the requirements for tar, nicotine and carbon monoxide levels to be printed on packs, and the 'UK Duty Paid' mark have encroached on the amount of space available on tobacco products' packaging. Despite these packaging obligations JTI features the Green Dot on all its tobacco products in the UK. The Green Dot logo is a symbol of JTI's commitment to responsible and efficient packaging waste management. 5

6 Enforcement strategic direction Q11. Do you agree National Parks Authorities should have the power to issue Fixed Penalties (Action 14)? We recognise that enforcement of existing anti-litter laws is one of the tools available to help tackle the problem. However, we would always prefer better facilities and further education rather than further fines and levies for smokers. Ultimately fines and enforcement are an Q11 a. Are there other public bodies you believe the power to issue Fixed Penalties should be extended to, and why (Action 14)? As per our response above, we believe that better facilities and further education are the more effective way to tackle litter rather than an increase in fines and the number issued. Q12. Do you believe it would be valuable to have the option to offer a discount to encourage prompt payment of Fixed Penalties for littering (Action 14)1 As per our response to question 11, we believe that ultimately fines and enforcement are an Q13. Do you agree that the level of Fixed Penalties should be increased to 80 for litter and 200 for flytipping (Action 15)? As per our response to question 11, we believe that ultimately fines and enforcement are an Q15. Do you agree there is a case for future improvements in the enforcement system to make it more effective in preventing littering and flytipping (Action 17)? As per our response to question 11, we believe that ultimately fines and enforcement are an General comments Q16. Do you have any further comments on or ideas for the National Litter Strategy? Yes We believe that government authorities should dedicate a proportion of expenditure on a ' public education advertising campaign focused on anti-littering messages. As mentioned in question 2, Keep Britain Tidy, one of JTI's partners, believes that there tends to be the misconception that cigarette ends are not litter, in order to change behaviour it must be communicated that cigarette ends are litter too. 6

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