Segun Ajayi-Kadir
The Manufacturers Association of Nigeria (MAN) is committed to creating a climate of opinion in Nigeria in which manufacturers can operate efficiently and profitably for the benefit of all Nigerians and those who live in Nigeria. In fulfilling this mandate, MAN engages with other stakeholders and the general public to co-create a climate of opinions that supports industrialization and the economic development of Nigeria. We keenly engage the public sector and other stakeholders to enable a conducive policy and business environment that allows manufacturing to thrive.
It is against this backdrop that the Association seeks the careful reconsideration of the Lagos State Government and attention of the general public concerning the decision of the Ministry of Environment to implement a ban on certain single-use plastics in Lagos State effective July 1, 2025. The Association hereby reiterates its earlier position that this decision was not informed by credible data. It is out of tune with the reality of our socio-economic situation, and is bereft of more ingenious and beneficial solutions. Quite importantly, the proposed ban is riddled with needless, potentially adverse economic and social impacts on the State and the Country.
The decision is predicated on the unsubstantiated claim that plastics, and especially some single-use plastics (SUPs) are associated with adverse health and environmental impact and therefore need to be banned. The Ministry is yet to publish any study to substantiate this claim. On the contrary, plastic is indeed a versatile and highly durable material that is supporting mankind in various endeavours across industries. It is the failure of management of plastic waste that may result in adverse environmental and social impacts.
The Association and its members share the global concern on the challenges created by plastic waste mismanagement and therefore recognize that a policy environment that enables circularity is indispensable in ending the so-called plastic pollution in Nigeria as a country and globally. The approach to achieving circularity in the plastic system needs to be life-cycle oriented, contextually relevant, and systemic, with strong consideration for the interaction of the societal system, human behaviour, and environmental impacts.
It is this realization that has led the Federal Government to develop the National Plastic Action Roadmap for Nigeria. This document (which was developed when the draft National Plastic Waste Control Regulation (NPWCR) 2023 was at its development stage) indicates specific and practical aspirations and steps for achieving plastic (including SUPs) circularity within the Country. Its development process gave appropriate consideration to the provisions of the draft NPWCR, an enabling law to execute the aspirations of the National Policy on Plastic Waste Management (NPPWM), 2020. It also contemplated the different plastic types and their uses. Its consultation process was participatory, ranking high on the public participation continuum as it sought to understand the viewpoints and challenges of Stakeholders, including the industry. Its output was therefore widely endorsed and accepted as the process was inclusive and evidence-based, even though the aspirations were not favourable to industry.
Issues with the Lagos State Ban on Single-Use Plastic
The process for the pronouncement on the ban on SUPs in Lagos State was not inclusive. It began with the development of the draft Lagos State Plastic Waste Management Policy (LSPWMP) 202, requesting that manufacturers should mandatorily subscribe to the creation of a Lagos State Plastic Waste Fund, a complete duplication of the Extended Producer Responsibility Programme being concurrently implemented. This is evidenced by about 40 members of the Association already subscribed to the Food and Beverage Recycling Alliance (FBRA).
It is important to note that there was no participatory consultation or social dialogue about the challenges of the industry and everyday users of these items preceding the announcement of these bans. The industry was not given a room for any form of discussion on the challenges that could be associated with the ban and how to mitigate them.
The ban focuses on the easiest approach to address the issue of plastic pollution rather than the most sustainable approach that gives balanced attention to social, economic, and environmental considerations.
Addressing SUP waste mismanagement through a ban will not bring about a lasting solution; it will only be a replacement of the polluting material.
There is objective evidence that one of the major causes of SUPs pollution in Nigeria, Lagos inclusive, is a function of the inadequate waste collection and management system in the Country. The practice of dropping skip bins for waste collection in markets and crowded areas, which releases a lot of waste into the environment, the absence of sorting infrastructure such as material recovery facilities, and low recycling rates are significant issues in the system.
Enormous economic, environmental, and social benefits are associated with advancing circularity through improved recycling solutions. The global plastic recycling industry was valued at USD 55.71 billion in 2023 and is projected to reach USD 114.18 billion by 2032, with a compound annual growth rate (CAGR) of 8.3% between 2025 and 2032. Providing an enabling environment for expanding mechanical and or chemical recycling in the State should be a major priority. While plastic recycling businesses have increased in the country over the years, the recycling rates are still low. The current plastic packaging recycling rate in Nigeria is estimated at less than 15%. Comparatively, the percentage of plastic packaging recycling values in the United Kingdom and Germany were 52.5% and 68.9%, respectively, as of 2023. The existing capacity of most local recycling facilities is underutilized due to insufficient feedstock.
Therefore, advancing provision for improving plastic waste collection is critical to fully harness the associated value, which includes improved livelihoods through increased income; job creation opportunities, and a boost in government revenue through payment of tax. The State Governments need to support improved plastic recycling with infrastructure, especially the leasing of lands as dumpsites for sorting at scale to enable recyclers access plastic feedstocks.
Consequences of the Ban
In line with our fundamental principle of advancing fact-based advocacy and data-informed positions, we sought to understand the potential impact of the ban on the economy. A recent MAN-supported study evaluating the possible impacts of the Lagos State SUPs ban revealed significant adverse economic, operational, and social implications across the value chain, from manufacturers to wholesalers, traders, and end users. It has been noted that only poor and developing countries often tilt towards plastic ban as a strategy to combat environmental problems.
A hundred percent (100%) of the manufacturers consulted expressed concern over a ban-induced workforce restructuring. Thus, several jobs will be lost in the industry if this ban were to be implemented. It is noteworthy to mention that there is no form of arrangement for social protection for the employees who will lose their livelihoods as a result of this ban. Also, there has been no form of social dialogue on the part of the Government with these workers or the industry on the potential job losses.
- Over eighty-nine (89%) of operators in the plastic value chain depend on the trade of these SUPs as their main source of income, with no alternative source of livelihoods, thus indicating that there will be potential loss of livelihoods on the part of these dealers and their staff.
- Disruptions of the organization’s supply chains, as end-users highlighted their strong dependence on plastic packaging, with more than 75% relying on SUPs, since there are no affordable and commercially available alternatives to the use of these SUPs for the trading of food and other items.
- Dealers, mostly women-led businesses, reported lack of clarity on the policy, with 93% noting that there is inadequate information on the plan to ban or any form of social protection provided to them to absorb the impact of the ban.
- Recyclers decried that it will lead to a further reduction in the availability of feedstock for their recycling plants.
There are other obvious consequences that will be associated with the ban. These unintended consequences include:
- Loss of revenue, including export earnings: Many of the manufacturers of these products have their facilities in Lagos but sell their products in other States and export to neighbouring African countries. Export earnings will be lost, and the supply chain of the dependent industry in those States and other countries will also be disrupted.
- Compromises to product integrity: The availability and affordability of sustainable alternatives to SUPs, such as paper and other compostable materials such as kenaf, lignin, are currently limited and quite expensive for businesses. A rushed transition could lead to compromises on product integrity, and this will lead to increased costs for consumers and businesses alike, thus increasing the economic hardship within the State.
Facts To Know
It is important for the Lagos State Government and the public to note that:
- Plastic products are not the problem; the plastics crisis experienced is as a result of the absence of plastic waste management or mismanagement. This highlights the reason why plastic production is not on a global decline and investments in the sector are increasing at the global level. The Government of Canada at both the federal and provincial levels is supporting Dow Chemical’s $8.9bn Path2Zero petrochemical plant project in Alberta, Canada with financial incentives as high as $1.8 billion, and also contributing up to $400 million through its carbon capture, utilization, and storage investment tax credit and clean hydrogen investment tax credit to the project. Nigeria, as a major producer of crude oil, should not be destroying its petrochemical industry with ban on plastics, but rather seek to close the loop by ensuring that all plastics are recycled.
- Africa as a continent contributes only 4% of the Global Green greenhouse gas emissions, hampering our growing manufacturing industry with bans in the name of environmental protection is a major disservice to ourselves.
- The four pillars of the Decent Work Agenda of the International Labour Organization (ILO) of which Nigeria is a signatory, highlight that social dialogue, social protection, rights at work and employment, are indispensable building blocks of sustainable development and must be at the centre of policies for strong, sustainable and inclusive growth and development. These four pillars must be at the centre of any policy implementation that the public sector is bringing on board.
MAN Recommendations
The Association and its members understand the need to evolve into more recent trends of re-useable plastic products, improved product design that aligns with circularity, and cleaner production processes. The plastic industry sector under the membership of the Association is therefore committed to transitioning to newer business models, fostering expansion in mechanical and chemical recycling, exploring the production of plastic from biomass and captured carbon, while adopting cleaner disposal systems. These developments should be enabled with the availability of circular feedstock and Government incentivizing investments in these circular solutions.
The Association and its members will continue to work collaboratively with Producer Responsibility Organizations as prescribed by the National Sectoral Regulations to fulfil our obligations across the Country. It is therefore unhelpful and needlessly disruptive to introduce parallel arrangements in any State in the Country.
A systems-oriented approach is relevant to achieving circularity in all products, plastics inclusive. In that regard, we therefore advocate for a balanced strategy comprising:
- Evidence-Based Policymaking: Policy must be driven by comprehensive, context-specific data. The current ban lacks adequate empirical grounding and risks unintended consequences for the economy.
- Inclusive Stakeholder Engagement: Government should adopt a consultative process, ensuring the perspectives of manufacturers, traders, waste managers, and consumers are integrated into policy design.
- Support for Local Alternatives and Infrastructure: Invest in local production of sustainable materials, recycling plants, and improved waste collection systems to build a truly circular economy.
- Collaborative Governance: Policies should be co-created with the private sector to ensure that implementation aligns with industry realities and market readiness.
- Deflection of Misleading Narratives: The government must be wary of adopting external policy frameworks without indigenous contextual adaptation. Nigeria requires locally relevant and inclusive environmental reforms.
Conclusion
In the light of the foregoing, we humbly submit that a ban on plastic is a move in the wrong direction and should be discontinued. MAN reiterates its commitment to work collaboratively with the public sector to create policies that allow manufacturing to thrive. We support the environmental intent of plastic waste management, we however believe this can only be achieved through policies that are inclusive, evidence-based, and sustainably implemented.
Segun Ajayi-Kadir, mni is
Director General Manufacturers Association of Nigeria
