Welsh Assembly Government
Proposals for a charge on
single use carrier bags
National Pharmacy Association
38-42 St Peter’s Street
Herts AL1 3NP
01727 858687 ext 3376
NPA response to WAG Consultation on - proposals to charge on single use carrier bags
The NPA welcomes this opportunity to respond to the WAG proposals for there to be a charge
to end users for single use carrier bags.
The NPA fully supports the WAG’s aim to reduce the adverse impact on the environment of
single use carrier bags by reducing litter, reducing the energy consumption and the non
renewable resources consumed during their production. We agree that charging for single use
bags is one method of changing public habits.
Q3 Which retailers, if any should be exempt from the proposed single use carrier bag
The NPA believes that all registered pharmacies should be exempt from the single use carrier
bag charge for the reasons stated below.
The NPA welcomes the recognition that it may be necessary for NHS prescriptions to be given
out in single use carrier bags. However this is followed by the statement that this should only be
applicable to pharmacies that only deal with NHS prescriptions. These two statement’s
contradict each other by virtue of the fact that no community pharmacy solely dispenses NHS
prescriptions, all pharmacies also dispense private prescriptions and sell medication for self
care as well as a range of other bulky products including feminine hygiene and incontinence
products the sale of which requires sensitivity and discretion and for which patient confidentiality
needs to be assured.
Having said this for the smaller pharmacies, that is the average community pharmacy, over 90%
of their income, is derived from NHS business which for the main part is dispensing
Pharmacists have a duty of confidentiality to their patients as set out in the Code of Ethics1
published by the Royal Pharmaceutical Society of Great Britain (RPSGB) and to which all
pharmacists and their staff must adhere, this states;
DUTY OF CONFIDENTIALITY
Patients have the right to expect that information you obtain about them is kept confidential and
is used only for the purposes for which it was given. This duty of confidentiality applies to all
information obtained about a patient during the course of professional practice and extends to
all members of the pharmacy team. Maintaining a patient’s confidentiality is fundamental to the
partnership between yourself and
the patient. A patient may be reluctant to seek advice from you in your capacity as a healthcare
professional where he/she has concerns that you will not maintain confidentiality.
Confidential information includes:
• personal details (including information that is not directly relevant to
a patient’s medical history):
• information about a patient’s medication (both prescribed and non-prescribed)
• other information about a patient’s medical history, treatment or care.
In the context of this consultation, this means that all supplies of medical products or surgical
appliances must be suitably and securely packaged so that the contents cannot be identified
during transport from the dispensary, or in the case of medicines purchased for self-care from
the pharmacy counter. For larger items or a large number of smaller items this will involve the
use of single use carrier bags. In addition NHS prescriptions are free to all residents of Wales,
to make a charge, if single use carrier bags are needed, will run counter to this. Patients who
requires bulky / heavy items such as ‘ostomy products, dressings or sip feeds may have these
items packed in several bags so that they can carry them home. The reuse of patients own bags
may present not only hygiene considerations but practical problems for pharmacies, especially
when the pharmacy collects the prescription from the surgery, orders the items, dispenses them
and has them waiting for the patient or their carer to collect. (To ensure confidentiality and
security the majority of pharmacies bag and seal the items on a prescription as soon as it has
Having said that dispensed medicines, medicines sold for self-care and other bulky sensitive
items supplied or sold by community pharmacies requiring packaging in single use carrier bags
should be exempt from the charge we need to look at the business context of this exemption.
Many community pharmacies are small or medium sized enterprises (SMEs) who are already
highly regulated, by virtue of being pharmacies as well as SMEs, and for whom the burden of
regulation can be onerous. To exempt part of the business from charging for the bags and
expect the charge to be levied when the bags are used for other products for example baby
nappies and milk will be virtually impossible to interpret, implement and maintain accurate
records. Not only will the application by the pharmacists and their staff be difficult but monitoring
and enforcement (trying to identify where a charge should have been levied and where the
items sold or supplied when a transaction exempt from the levy) will also be virtually impossible.
Any legislation can only be effective if the enforcement of it has a dissuasive effect.
In addition if the system is difficult for the staff to understand it will be even harder for their
customers who may well not understand why they have to pay a charge one day and not the
next. In addition people may think that they are being defrauded if not charged the levy one day
and then charged the next. Explaining the legislation to someone who may well be under stress,
because of their own poor health or the poor health of someone they are caring for, will not be
easy is likely to be time consuming and may well result in the pharmacy business paying the
levy as the easiest solution to maintaining the goodwill of their customer.
We notice that business supplying services are to be exempt from charging the levy (section
4.3) we would argue that pharmacies are providing services, such as dispensing and support for
self-care and that the sale or supply of the medicinal product or surgical appliance is the product
of that service and therefore if a single use carrier bag is required to package that product, it
should be exempt from the levy.
Pharmacists are as a group highly respected by members of the public2 and also recognised by
the government as being an under utilised health care resource. In fact WAG wishes to increase
the use of community pharmacy to supply health services to their populations and assist in
reducing health inequalities.
We therefore propose that all supply of single use carry bags by community pharmacy
should be exempt from the levy. This is a pragmatic solution to what otherwise would be
a situation which is not only near impossible to manage but also risks damaging the
relationship between patients and healthcare professionals in the community.
Code of Ethics for Pharmacists and Registered Technicians
Understanding the pharmacy market in England: findings from desk research and stakeholder
interviews June 2009 Department of Health www.dh.gov.uk
The National Pharmacy Association (NPA)
The NPA is the body which represents the full spectrum and vast majority of community
pharmacy owners in the UK. We count amongst our members nationwide pharmacy multiples,
regional chains and independent pharmacies. This spread of large and small member
companies, our UK-wide geographical coverage, and our remit for NHS and non-NHS affairs
means that we are uniquely fully representative of the community pharmacy sector. In addition
to being a representative voice, we provide members with a range of commercial and
professional services to help them maintain and improve the health of the communities they