Namibia's plastic bag levy: A call for transparency and improvement

The levy on plastic carrier bags was implemented on 2 August 2019, which aimed to reduce plastic bag use and generate income that will be ploughed back into waste management. Five years on, I studied whether this levy has achieved its purpose. I found several weaknesses in the levy showing that it is not working as it should in Namibia.

The levy is gazetted under the Customs Excise Act No. 20 of 1998 as an environmental levy together with fuel/carbon emission levies, and not a separate levy for plastic bags levy. Although the levy targets manufacturers and importers of plastic bags, the price is shifted to the end-users who pay for the plastic bags as they purchase their goods at retail stores.

The Ministry of Finance collects the revenue like any other environmental levy and channels an unknown portion of it to the Environmental Investment Fund (EIF) to be used for waste management-related activities. This contradicts government statements before implementation in August 2018, promising that 100% of revenue will be channelled to EIF to be ploughed back into waste management-related activities.

Given that the levy is collected like any other levy in Namibia, was the plastic carrier bag levy implemented as a double-dividend levy, or is it intended solely to generate income to help with waste management in addition to reducing plastic bag use? The concept of double dividend means that, beyond its primary purpose, the levy yields an additional advantage. The first dividend is an environmental benefit, as the tax is aimed at discouraging plastic carrier bag use and improving waste management. The second dividend is economic: the revenue generated through the levy can be used to lower other taxes or fund public services. The plastic bag levies implemented in Ireland and South Africa provide interesting comparisons for Namibia's levy.

The Irish plastic bag levy is known to be the most effective in the UK – leading to a 90% reduction in plastic carrier bag use – and was designed without a double dividend effect. The revenue generated was all ploughed back into an environmental fund operated by the Department of the Environment, Heritage and Local Government, to be used for defraying the costs of administration of the levy, building recycling facilities and associated infrastructure, and running environmental education programmes. Administration of this fund costs less than 5% of the revenue collected. Although the levy was just a small portion of the shopping bill, it made an impact due to extensive consultation, proper monitoring and reporting.

South Africa introduced their plastic bag levy in May 2003 as a standalone regulation under the Department of Environmental Affairs. The regulation specifies the acceptable types of plastic carrier bags in the country and the penalties for violations. While the government levied 3 cents per bag, retail shops charged 30–60 cents per bag to cover production costs for the thicker bags required under the new law. Fourteen years after the levy was implemented, the South African public discovered that the revenue earmarked for recycling facilities had been diverted to the National Revenue Fund with only half of the revenue channelled to recycling facilities.

Irish people support their plastic bag levy because they see the impact based on monitoring and reporting on revenue earned and the reduction of plastic bags in the environment. In contrast, South Africans still question what is happening with the rest of the plastic bag levy revenue that is not going towards recycling facilities.

Could it be that Namibia copied the plastic bag levy from South Africa without investigating other levy models that achieve the desired results? How much revenue has been generated by the plastic bag levy thus far? What is the levy revenue used for regarding waste management? The National Solid Waste Management Strategy of 2018 stated that the total revenue collected from the plastic bag levy, expenditure on the project and results of the projects would be made publicly available through regular reporting. In the five years since the levy was established, no public reports have been produced.

While Namibian citizens remain in the dark about the progress and outcome of the levy, a plan to ban plastic carrier bags in the country is now being considered. It therefore seems that the levy has failed to reduce plastic pollution, yet no one knows exactly how the revenue it generated was spent.

Is the levy supposed to discourage plastic bag sales or increase retailer profits?

The levy is 50 cents per plastic carrier bag, which was initially what consumers paid at retail stores per bag. In February 2021, however, the retail stores started charging N$ 1.00 to cover production costs without announcing this change to the public. Price creep has continued, as plastic bags currently cost between N$ 2.00 to N$2.50 in some stores, while others are providing plastic bags for free. The levy has inadvertently created a new source of profit for some retail stores, while in others it has made no difference to plastic bag use.

On 8 March 2024, Minister Pohamba Shifeta stated that retail stores charging more than the levy is a good thing, as it discourages consumers from discarding plastic carrier bags while encouraging reuse rather than buying new ones.

A survey conducted in 2020 in Ondangwa, Keetmanshoop, Walvis Bay, Katima Mulilo and Windhoek with 3751 respondents found that half of the respondents do not know that the levy was introduced to reduce plastic waste, stating instead that is designed for retail stores and the government to make a profit. Walvis Bay was one of the first towns in Namibia to introduce the plastic bag levy. A 2023 survey carried out in this town with 191 respondents showed that 60% of consumers are uncertain about the plastic bag price. Increasing plastic bag charges without creating public awareness defeats the purpose of the levy, as people may still buy them without realising that they are becoming more expensive. Public awareness materials should include notices on price changes, information on the reason for the levy and ways to shop without buying plastic bags.

The levy was introduced without providing alternative options for carrying goods, leaving retail stores to find their own solutions for customers. Many stores responded by offering reusable bags that are significantly more expensive 4 to 6 times the cost of standard plastic bags or paper bags costing around N$4 each. As a result, consumers continued to choose plastic bags as the cheapest option, undermining the levy's goal of discouraging plastic bag use. To make reusable options more attractive, subsidising their cost and implementing deposit-return systems or discounts for using reusable bags would create financial incentives for customers and support the transition to sustainable practices.

Unlike the South African legislation, Namibia does not specify the thickness, printing or size of reusable plastic bags. Some local manufacturers question why they should design and produce high-quality plastic bags, while importers and other manufacturers still produce thin, low-quality single-use bags. However, my 2023 survey revealed that even the thicker plastic bags are disposed of in the same manner as any other plastic carrier bags used to dispose of waste or not reused especially if it was carrying wet goods. The levy also did not specify the type of plastic bags that are suitable for importation despite concerns raised during the consultation that plastics containing calcium carbonate are not suitable for recycling purposes. Consequently, if importers find cheaper plastic bags that are made of calcium carbonate, they can import them as long as they pay the levy. This means that cheap, non-recyclable bags can still be produced and disposed of, despite the levy.

Are Namibians prepared for a shopping experience without plastic carrier bags?

In June 2023, Minister Shifeta announced the government's intention to ban single-use plastics – including carrier bags – by the end of the year. While this has not yet happened, some of the results from my surveys of consumers point to challenges that need to be overcome if plastic bags are banned. Some of the stores that started using paper bags once the levy was introduced later reverted to plastic bags. This could be due to paper bags breaking when carrying heavy or wet goods.

Some consumers indicated that after they stopped buying plastic bags, they realised that they had nowhere to put their waste before disposing of it in the household refuse bin. Dust bin bags are necessary, as town municipalities require domestic waste to be bagged prior to their collection. The 2023 survey found that 90% reuse their plastic bags at home for this purpose.

Although reuse is encouraged, it does not solve the problem of plastic bags ending up in landfills. Further, plastic carrier bags that are contaminated with organic waste (i.e. those used as bin bags) are difficult to recover and recycle to feed in the circular economy as stipulated in the Waste Management Strategic Plan. Organic waste that is disposed of in plastic bags produces more methane than without bags, as the anaerobic (oxygen-free) conditions within the bag allow methane-producing bacteria to flourish.

Namibia's plastic bag levy has lacked public communication, monitoring and reporting. My surveys show that it has been ineffective in changing consumer habits, although it has increased retailer profits. Whether or not the government funds were allocated appropriately and used to achieve environmental goals is unknown due to the lack of transparency.

Ultimately, Namibia must prepare for a future with reduced reliance on plastic carrier bags. This transition will require policy changes, public engagement and education to promote sustainable alternatives and responsible waste management practices. I hope that the lessons learned from the plastic bag levy can be applied to the planned ban to ensure greater public support and understanding of the need to reduce plastic waste in our environment.