Delivering Scotland's Circular Economy - route map to 2025 and beyond: consultation analysis

Executive Summary

Introduction

The Scottish Government is committed to developing Scotland’s circular economy and recognises that moving from a “take, make and dispose” model to one where materials are kept in use for as long as possible is imperative in addressing the climate and nature crises. To deliver this vision, Scotland has several ambitious 2025 waste and recycling targets. While significant long-term progress towards these targets has been made, progress has slowed in recent years, and more action is required if these targets are to be met in full.

In May 2022, the Scottish Government published proposals for a Route Map, which set out a range of proposed additional legislative and non-legislative measures that have the potential to contribute to the delivery of the targets and make progress towards carbon reduction and delivery of a circular economy. Scottish Government also consulted in parallel on a Circular Economy Bill to bring forward the primary legislation needed to underpin some of key policy measures.^[1]

Proposals in the Route Map were grouped into seven change packages, which span action across the whole circular economy:

• Promote responsible consumption and production (including reducing consumption of single-use items, promoting product design and stewardship and mainstreaming re-use)
• Reduce food waste from households and businesses
• Improve recycling from households
• Improve recycling from commercial businesses
• Embed circular construction practices
• Minimise the impact of disposal of waste that cannot be reused or recycled
• Cross-cutting themes: Strengthen our data and evidence, sustainable procurement practices, and skills and training.

The consultation

The Scottish Government sought views on the proposed Route Map through a public consultation exercise, which was an opportunity to understand a wide variety of stakeholders’ views on the proposed strategic approach to advancing a circular economy in Scotland and delivering existing targets by 2025. The consultation contained eight closed questions with an open response component and 12 open questions. In total, 160 consultation responses were received; this included submissions from individuals, and those representing organisations across public, private and third sectors, including waste management companies, retail and packaging organisations and local authorities.

An analysis of responses to the consultation was undertaken by social research agency, The Lines Between.

Overview of findings

A high-level summary of responses to the closed questions in the consultation is presented in Table A below; it sets out the percentage of respondents who answered ‘agree’ or ‘strongly agree’ when asked the extent to which they agreed with the proposed measures and actions set out in each of the packages.

Table A shows high levels of support for all seven Packages, ranging from 69% for Package 4, to 93% for Package 7.

More nuance was provided in responses to the open-ended questions, with respondents setting out the reasons they either agreed or disagreed with measures, raising questions or concerns about some of the proposed measures, or providing caveats to their support.

Package 1: Promote responsible consumption, production and re-use

Package 1 was largely well-received by respondents; it was described by some as comprehensive and ambitious. Several respondents embraced the strong focus on reuse, and others shared knowledge of similar interventions to those set out in the package having successful outcomes in other countries. However, there was some criticism of Package 1; some felt that too much responsibility is placed on the individual consumer, and requested more measures targeted at producers and manufacturers. Others raised concerns that disincentivising the use of products which contain environmentally damaging materials such as plastic may increase the use of substitutes made of other materials which potentially have a more detrimental environmental impact across their life cycle.

Package 2: Reduce food waste

Generally, Package 2 was well-received; respondents agreed that reducing food waste should be seen as a priority, and there was broad consensus that, if delivered successfully, the proposals described in Package 2 will contribute to a reduction of food waste in Scotland. However, as with other packages, a few respondents were critical of the perceived lack of urgency within the measures and called for stronger action. There were also requests for measures aimed at retailers to be introduced into the Route Map, and it was suggested that the package should have a greater focus on how primary producers and the agricultural sector can contribute to food waste prevention and reduction.

Package 3: Improve recycling from households

Respondents were broadly supportive of the current commitments and proposed new measures set out in Package 3. The plans were described by some as “logical”, “appropriate” and “well-considered.” However, there were some calls for greater urgency in improving household recycling rates across the country, and recurring questions from public sector organisations (including most local authorities) about how the Scottish Government intends to fund the measures, given the increased responsibilities that they will impose on local councils.

Package 4: Improve recycling from commercial businesses

The first three proposals set out within Package 4 were largely well-received by respondents; with particularly strong support for a national compositional study of waste from commercial premises. Respondents described this as an ‘essential’, ‘valuable’ and ‘important’ exercise in terms of addressing data gaps within commercial recycling and improving service provision. However, the proposal to pilot a commercial zoning approach was met with some strong opposition. While there was some recognition of the potential benefits of commercial zoning, concerns such as loss of competition and potential monopoly price escalation were raised by respondents from various sectors, including those in the waste management sector and local authorities.

Package 5: Embed circular construction practices

A clear majority agreed with the package of proposals to embed circular construction practices. It was suggested that the Scottish Government should work with industry to accelerate the adoption of best practice standards and explore options for compliance. Mixed views were expressed on mandatory vs voluntary standards. Many emphasised the knowledge within the sector and described who should be involved; and some highlighted the challenges of working with stakeholders. On the proposal to investigate options to incentivise refurbishment of buildings, most welcomed this, but some questioned the cost implications of this approach. Mixed views were evident on the development proposal to coordinate a Scottish programme for reuse of construction materials and assets, and there was also a lack of consensus across comments on using recycling bonds to divert material from landfill. Respondents’ comments on suggested further measures centred on how Scotland’s planning system and standards could embed circular construction practices.

Package 6: Minimise the impact of disposal

Most consultation participants agreed with the measures to minimise the impact of the disposal of residual waste. Some respondents described different aspects of the Residual Waste Plan that they would like to see, asking for more detail about scope, approach and implementation, or noting further aspects of this proposal for the Scottish Government to consider. There were few comments on the proposal to restrict the incineration of fossil materials through the development of a sector-led plan by 2024, and to investigate fiscal measures to incentivise low carbon disposal, including the potential to include energy from waste in the UK Emissions Trading Scheme.

Package 7: Cross-cutting measures

Almost all consultation respondents agreed with the proposed cross cutting measures. Some highlighted specific issues to include within, or consider in, the development of the Circular Economy Strategy. There were also suggestions about what a monitoring and indicator framework should measure or how to gather the data; and mention of specific areas to explore in any research into waste prevention, behaviour change, fiscal incentives and material-specific priorities. On support for green skills, respondents described existing skills training, identified skills gaps and discussed the wider needs of the sector.

Beyond 2025

The final section of the consultation document outlined four key principles to underpin the transformational change required in the years ahead: (1) Achieve net zero by 2045 (2) Reduce the material footprint of our resources and waste (3) Maximise the value of our circular economy and (4) Align with the EU. High levels of agreement were expressed by respondents; most endorsed the principles, and some provided details of the actions they felt would be necessary to achieve the extent of change required. Several respondents called for the inclusion of a 5^th key principle; to ‘achieve nature positive by 2030’.