Calling for more joined up thinking to tackle marine litter and UK level

One of our strategic objectives is tackling litter and waste.  Today we submitted our comments to the consultation on the UK Marine Strategy Part One - focussing on the assessments, monitoring and measures relating to Marine Litter (D10). 

We declared a litter emergency in 2022 and our data provides evidence of the ongoing challenge on land to tackle the issue.  Litter, with a high proportion of it being plastic, is a major threat to marine biodiversity, impacts our tourism offer and can pose a risk to human health as it breaks down and enters the food chain.

We welcome the opportunity to respond on the consulation and although we are disappointed that the UK has not met Good Environmental Standards (GES) for (D10) marine litter, we do welcome positive reductions in some areas. 

The Marine Litter Strategy for Scotland contributes to working toward Good Environmental Status in UK waters as part the Scottish Government’s statutory duties under the UK Marine Strategy, and we are proud to play our part in supporting the delivery of this by working to reduce marine litter through our campaigns, training and education programmes.

We note that the 2019 Target (a decrease in the total amount of the most common categories found on surveyed beaches) and the Corresponding OSPAR QSR 2023 Common Indicator (abundance, composition and trends of beach litter) have been met in relation to Beach Litter.  However, we are disappointed that the overall targets have not been met when taking account of seafloor and floating litter.  We recognise that there is legislation, and are strategies, in place designed to provide a strong framework for preventing marine litter and have welcomed a number of policy initiatives in recent years in Scotland and the UK, such as the ban, cotton bud sticks and other single-use plastic items.  But, with other interventions on the horizon, including a ban on plastic web wipes, a Deposit Return Scheme and Extended Producer Responsibility for packaging there is a real need for there to be full accountability and consequences as a result of targets not being met in the future.   Inadequate implementation, under resourcing and a lack of enforcement can, and we believe, is, undermining the effectiveness.

Our overarching comments are:

• The assessment of Good Environmental Status (GES) needs to be more ambitious, incorporating clear targets which must be met, but also incorporating more environmental and policy linkages, in particular making stronger connections between riverine litter and marine litter.
• Riverine/ waterway monitoring must be incorporated as an additional criterion to better understand sources, pathways and transport of litter to the marine environment. By aligning the management of the marine environment with the management of freshwater and terrestrial habitats litter and contaminants, derived from terrestrial or freshwater sources could be prevented from entering the marine environment.
• There is a lack of linkage between marine litter and those other target areas, specifically when it relates to overlapping matters such as bathing water quality and the policy requirements under the Code of Practice for Litter and Refuse (COPLAR).
• To improve the health of Scotland's coastal and marine ecosystems and reduce the impact marine litter can have, there needs to be a greater connection and more consistency in marine policy matters between the UK and the devolved active strategies in Scotland. In particular the Marine Litter Strategy and the National Litter and Flytipping Strategy for Scotland must work in tandem to support the Scottish Biodiversity Strategy Delivery Plan - to accelerate restoration and regeneration - and the forthcoming Marine and Coastal Restoration Plan. Restoring our seas can only happen if our flora and fauna are not smothered by litter and waste.

We note and agree with the evidence challenges for marine litter that are identified in the pressures from human activities MOAT.  In particular, the need to better understand sources, pathways and transport of marine litter.  Under Scotland’s Marine Litter Strategy, our Upstream Battle campaign works with local communities to inform and educate and change littering behaviours and we are involved with the ongoing work with OSPAR to address riverine litter.