A consultation has launched as part of NHS Scotland’s ‘journey to net zero’ on proposals to reduce or remove unnecessary plastic packaging

It includes a proposal that all plastic packaging for goods purchased by NHS Scotland from April 2025 will need to be able to be reused or recycled in the UK.

This will apply to new suppliers, but existing suppliers will also be asked to review their packaging to ensure it meets the requirements.

NHS National Services Scotland (NSS), which carries out procurement on behalf of NHS Scotland, says in the consultation that plastic pollution is a ‘major environmental problem’ which impacts health.

Its proposals now seek to reduce both the layers and quantities of packaging wherever possible.

Leading the new consultation as part of wider efforts to meet Scotland’s commitments to sustainability across the health service, NSS states:

‘We look forward to starting this joint approach to ensuring that NHS Scotland further improves the health for the population of Scotland and the wider population through environmental sustainability and stewardship.’

The proposals acknowledge that plastic is an important material in healthcare but add that the polluting impacts cannot be ignored, quoting the United Nations:

“Plastic pollution can alter habitats and natural processes, reducing ecosystems’ ability to adapt to climate change, directly affecting millions of people’s livelihoods, food production capabilities and social wellbeing.”

As a baseline, at least 30% of plastic packaging would be made from recycled material, in order to meet the requirements of a UK-wide tax that came into effect in April 2022.

Where this is not possible, suppliers will be asked to explain why 30% recycled materials could not be achieved.

As it is the businesses providing products who will be taxed, the proposal says that requiring recycled plastics as part of NHS Scotland contracts will also assist businesses in providing sustainable packaging while avoiding the need to pay the additional tax.

Yet, the consultation also recognises that this tax will apply in variable ways depending on the products.

Human medicinal products, such as those in immediate contact with medicines, are not subject to the tax but packaging like containers or other secondary or tertiary plastic packaging can be taxed.

The consultation says:

‘For now, we wish to understand whether there are any difficulties for our suppliers in using recycled material in their plastic packaging.

‘It is NHS Scotland’s position that the cost of paying the UK Plastics Packaging Tax should not be passed onto NHS Scotland. Suppliers should instead endeavour to ensure that their packaging includes 30% recycled material.’

NHS Scotland says it will work with suppliers to increase the amount of recycled content and the quality of plastic which can be recycled for the products it needs.

It is also working with its clinical waste contractor to increase the amount of clinical plastic waste – once decontaminated – which is recycled.

This will help Scotland meet its wider target of an NHS in which 70% of all general waste is recycled or composted.

In its proposals, the NSS provides an NHS Scotland plastic hierarchy based on ease of recyclability within Scottish infrastructure, and asks that suppliers share their perspectives:

‘We appreciate there are some circumstances in which other products containing plastics not listed in the hierarchy may still be required. In these situations, we may ask the suppliers of those products on a voluntary basis, to explain the reasons why non-hierarchy plastics must be used in their products and encourage them to use our preferred plastics where possible.

‘We welcome proposals from the suppliers of products using non-hierarchy plastics for end-of-life management plans for those products e.g. take-back schemes.’

Looking to the future, the proposals say NHS Scotland is considering bringing the consideration of recycled materials in the products it buys into its evaluation process for choosing potential suppliers.

However, it states that since it is ‘already common practice’ for packaging to be made of recyclable material, these changes proposed are not likely to present any ‘major challenges’ to potential suppliers.

Future considerations include ensuring all secondary plastic packaging meets a minimum of 40% recyclable materials.

The consultation is now open in early access until 19 August.

Read more: New green inhaler prescribing guidance; Working together for climate action and good health; Medics warn pollution is risking children's health; Blue-green prescribing for climate and public health; Support grows for LEZs in Scotland; Doctors call for action on air pollution

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