Developing Scotland's circular economy - proposals for legislation: analysis of responses
Independent analysis of responses to the “Developing Scotland’s circular economy: consultation on proposals for legislation” paper which included proposals for a circular economy bill and two secondary regulations relating to single-use carrier bags and procurement.
4 Reuse: encouraging use and reuse to prevent waste (Q4-Q7)
4.1 Section 2 of the consultation paper discussed the importance of improving monitoring, measurement and reporting of waste across all sectors of the Scottish economy - not just within the recycling and waste management sector. The point was made that, by obtaining a clearer idea about the type and quantities of waste being generated, measures to deal with waste can be targeted more effectively. The consultation paper highlighted the commitment that Scotland has made to work with other UK countries to develop electronic systems to record waste data. At the same time, it pointed out that there is a need for greater transparency in key sectors - such as the food and textile retail and manufacturing sectors - about the production of unwanted stock and waste.
4.2 The consultation laid out proposals for the introduction of a power to enable Scottish Ministers to require mandatory public reporting of unwanted surplus stock and waste of certain materials by Scottish businesses. The initial priority for subsequent secondary legislation (following further consultation) would be to introduce reporting on food surplus and waste. However, the Scottish Government also wished to explore whether this requirement should also be applied to textiles and, potentially, other waste streams. The consultation included four questions on this issue, as follows.
Question 4: To strengthen monitoring, measurement and reporting of waste across all sectors, do you agree with the principle that Scottish Ministers should have the power to require mandatory public reporting of:
(i) Business waste? [Yes / No / Neither agree nor disagree]
(ii) Business surplus? [Yes / No / Neither agree nor disagree]
Question 5: Do you agree with the proposal to prioritise introduction of mandatory public reporting for businesses of:
(i) Food waste? [Yes / No / Neither agree nor disagree]
(ii) Food surplus? [Yes / No / Neither agree nor disagree]
Question 6: Are there any other items, such as textiles and clothing, that mandatory reporting requirements on waste and surplus should be expanded to in the future? [Yes / No / Don't know] If yes, please specify.
Question 7: Do you have any suggestions on how to encourage the reuse and redistribution of unwanted surplus stock, such as clothing and textiles? [Yes / No / Don't know] If yes, please specify.
4.3 Questions 4 and 5 were multi-part closed questions, and the findings are presented in Tables 4.1, 4.2, 4.3 and 4.4 below. Questions 6 and 7 both included a follow-up question for those who answered 'yes' to the tick-box question.
4.4 Note that some organisations provided comments at Question 6 which discussed the principle and practical aspects of introducing mandatory public reporting of business waste and surplus and / or food waste and surplus. These comments have been summarised briefly following the findings for Question 5 (at paragraph 4.11 below).
Mandatory public reporting of business waste (Q4(i))
4.5 Question 4(i) asked respondents if they agreed that Scottish Ministers should have the power to require mandatory public reporting of business waste. Table 4.1 shows that a large majority of respondents (93%) were in favour. There was a similar pattern of response among organisations (88% said 'yes') and individuals (96% said 'yes'). Food, drink, hospitality, tourism and retail organisations were less likely than other organisations to answer 'yes' to this question. However, in general, respondents who did not answer 'yes' were more likely to answer 'neither agree nor disagree' rather than 'no' at Question 4(i).
Organisation type | Yes | No | Neither agree nor disagree | Total | ||||
---|---|---|---|---|---|---|---|---|
n | % | n | % | n | % | n | % | |
Environmental charities, third sector and community sector organisations | 28 | 100% | - | 0% | - | 0% | 28 | 100% |
Public sector organisations | 25 | 96% | - | 0% | 1 | 4% | 26 | 100% |
Food, drink, hospitality, tourism and retail organisations | 11 | 50% | 3 | 14% | 8 | 36% | 22 | 100% |
Environmental consultancies & resource management organisations | 17 | 94% | 1 | 6% | - | 0% | 18 | 100% |
Academic and professional bodies and business representative bodies | 8 | 89% | - | 0% | 1 | 11% | 9 | 100% |
Packaging and other manufacturing organisations | 9 | 90% | - | 0% | 1 | 10% | 10 | 100% |
Beverage and vending companies | 12 | 100% | - | 0% | - | 0% | 12 | 100% |
Total organisations | 110 | 88% | 4 | 3% | 11 | 9% | 125 | 100% |
Total individuals | 256 | 96% | 3 | 1% | 8 | 3% | 267 | 100% |
Total organisations and individuals | 366 | 93% | 7 | 2% | 19 | 5% | 392 | 100% |
Percentages may not total 100% due to rounding.
4.6 In addition, 1,244 individuals who submitted responses through the Friends of the Earth Scotland campaign stated that they fully supported the Scottish Government's proposal to 'require mandatory public reporting of business waste'. It may be inferred that these individuals have answered 'yes' to Question 4(i).
Mandatory public reporting of business surplus (Q4(ii))
4.7 Question 4(ii) asked respondents if they agreed that Scottish Ministers should have the power to require mandatory public reporting of business surplus. Table 4.2 shows that a large majority of respondents (87%) were in favour. There was a similar pattern of response among organisations (81% said 'yes') and individuals (90% said 'yes'). Among organisations (i) food, drink, hospitality, tourism and retail organisations and (ii) packaging and other manufacturing organisations were less likely than others to answer 'yes'. However, in general, respondents who did not answer 'yes' were more likely to answer 'neither agree nor disagree' rather than 'no' at Question 4(ii).
Organisation type | Yes | No | Neither agree nor disagree | Total | ||||
---|---|---|---|---|---|---|---|---|
n | % | n | % | n | % | n | % | |
Environmental charities, third sector and community sector organisations | 27 | 96% | - | 0% | 1 | 4% | 28 | 100% |
Public sector organisations | 22 | 85% | 1 | 4% | 3 | 12% | 26 | 100% |
Food, drink, hospitality, tourism and retail organisations | 10 | 45% | 3 | 14% | 9 | 41% | 22 | 100% |
Environmental consultancies & resource management organisations | 16 | 89% | 2 | 11% | - | 0% | 18 | 100% |
Academic and professional bodies and business representative bodies | 8 | 89% | - | 0% | 1 | 11% | 9 | 100% |
Packaging and other manufacturing organisations | 6 | 60% | 2 | 20% | 2 | 20% | 10 | 100% |
Beverage and vending companies | 12 | 100% | - | 0% | - | 0% | 12 | 100% |
Total organisations | 101 | 81% | 8 | 6% | 16 | 13% | 125 | 100% |
Total individuals | 241 | 90% | 7 | 3% | 19 | 7% | 267 | 100% |
Total organisations and individuals | 342 | 87% | 15 | 4% | 35 | 9% | 392 | 100% |
Percentages may not total 100% due to rounding.
4.8 In addition, 1,244 individuals who submitted responses through the Friends of the Earth Scotland campaign stated that they fully supported the Scottish Government's proposal to 'require mandatory public reporting of business surplus'. It may be inferred that these individuals have answered 'yes' to Question 4(ii).
Mandatory public reporting of food waste (Q5(i))
4.9 Question 5(i) asked respondents if they agreed with the principle that Scottish Ministers should have the power to require public reporting of food waste. Table 4.3 shows that the vast majority of respondents (91%) did so. There was a similar pattern of response among organisations (83% answered 'yes') and individuals (94% answered 'yes'). Food, drink, hospitality, tourism and retail organisations were less likely than other organisations to answer 'yes' to this question. However, in general, respondents who did not answer 'yes' were more likely to answer 'neither agree nor disagree' rather than 'no' at Question 5(i).
Organisation type | Yes | No | Neither agree nor disagree | Total | ||||
---|---|---|---|---|---|---|---|---|
n | % | n | % | n | % | n | % | |
Environmental charities, third sector and community sector organisations | 26 | 93% | - | 0% | 2 | 7% | 28 | 100% |
Public sector organisations | 23 | 88% | 1 | 4% | 2 | 8% | 26 | 100% |
Food, drink, hospitality, tourism and retail organisations | 11 | 48% | 3 | 13% | 9 | 39% | 23 | 100% |
Environmental consultancies & resource management organisations | 17 | 94% | 1 | 6% | - | 0% | 18 | 100% |
Academic and professional bodies and business representative bodies | 10 | 100% | - | 0% | - | 0% | 10 | 100% |
Packaging and other manufacturing organisations | 8 | 80% | - | 0% | 2 | 20% | 10 | 100% |
Beverage and vending companies | 11 | 92% | - | 0% | 1 | 8% | 12 | 100% |
Total organisations | 106 | 83% | 5 | 4% | 16 | 13% | 127 | 100% |
Total individuals | 253 | 94% | 7 | 3% | 8 | 3% | 268 | 100% |
Total organisations and individuals | 359 | 91% | 12 | 3% | 24 | 6% | 395 | 100% |
Percentages may not total 100% due to rounding.
Mandatory public reporting of food surplus (Q5(ii))
4.10 Question 5(ii) asked respondents if they agreed with the principle that Scottish Ministers should have the power to require mandatory public reporting of food surplus. Table 4.4 shows that a large majority of respondents (89%) did support this principle. There was a similar pattern of response among organisations (81% said 'yes') and individuals (93% said 'yes'). Among organisations (i) food, drink, hospitality, tourism and retail organisations and (ii) packaging and other manufacturing organisations were less likely than others to answer 'yes'. However, in general, respondents who did not answer 'yes' were more likely to answer 'neither agree nor disagree' rather than 'no' at Question 5(ii).
Organisation type | Yes | No | Neither agree nor disagree | Total | ||||
---|---|---|---|---|---|---|---|---|
n | % | n | % | n | % | n | % | |
Environmental charities, third sector and community sector organisations | 26 | 93% | 1 | 4% | 1 | 4% | 28 | 100% |
Public sector organisations | 20 | 80% | 1 | 4% | 4 | 16% | 25 | 100% |
Food, drink, hospitality, tourism and retail organisations | 13 | 57% | 3 | 13% | 7 | 30% | 23 | 100% |
Environmental consultancies & resource management organisations | 16 | 89% | 2 | 11% | - | 0% | 18 | 100% |
Academic and professional bodies and business representative bodies | 10 | 100% | - | 0% | - | 0% | 10 | 100% |
Packaging and other manufacturing organisations | 6 | 60% | 1 | 10% | 3 | 30% | 10 | 100% |
Beverage and vending companies | 11 | 92% | 0% | 1 | 8% | 12 | 100% | |
Total organisations | 102 | 81% | 8 | 6% | 16 | 13% | 126 | 100% |
Total individuals | 247 | 93% | 7 | 3% | 13 | 5% | 267 | 100% |
Total organisations and individuals | 349 | 89% | 15 | 4% | 29 | 7% | 393 | 100% |
Percentages may not total 100% due to rounding.
Views on the principle and practical aspects of mandatory public reporting
4.11 A range of organisations (though generally not environmental charities, third sector or community organisations) made comments at Question 6 (below) which related to Questions 4 and 5. In general, regardless of whether they answered 'yes', 'no', or 'neither agree nor disagree' in response to the closed questions, this group highlighted practical considerations relating to the implementation of these proposals. However, very occasionally, they described the proposals as potentially onerous and / or expressed concerns. This latter view came from a small number of organisations in the food, drink, hospitality, tourism and retail sectors. Both these views are summarised briefly here.
Practical considerations relating to implementation of mandatory public reporting
4.12 Organisations made the following points regarding the implementation of the proposals.
- Areas for clarity: Organisations wanted further information about (i) exactly how this reporting would be undertaken, (ii) how the data will be analysed, (iii) what, if any, new technology would be required to make this possible, and (iv) what the information will be used for. Those who raised these issues argued that careful consideration would need to be given to how the reporting would be carried out to ensure that the data are robust and useful. There was a question about how mandatory reporting of food waste would account for inedible waste arising from food and drink processing (e.g. shells, bones, or vegetable peelings). There was also a separate request for clarity about whether the proposed mandatory reporting requirements were intended to be met by producers / the business sector, or by local authorities.
- Definitions: Some organisations asked for clearer information about the definition of 'surplus' and how this would be measured in different kinds of businesses. Will it be weighed or estimated by businesses? In addition, the concept of surplus may only apply in certain kinds of business (i.e. food surplus is likely to only occur in food and drink or retail sectors), and surpluses may be relatively easy to measure in some businesses but very difficult to measure in others.
- Burden on businesses: Respondents wanted the Scottish Government to consider the burden any additional requirements would place on businesses and the assistance / resources they may need to meet the requirement. There was a suggestion that any new reporting requirements should be introduced in a staged way to allow lessons to be learned before full implementation.
- Burden on small businesses: Some respondents queried how mandatory reporting arrangements would work for small businesses, in particular. It was suggested that some small businesses would find this difficult, and that there should be exclusions for companies below a certain size. There was also a suggestion that more cost-effective options for disposing of waste should be made available to all businesses, but especially small businesses in remote rural communities.
- Consistency and alignment across the UK: Some organisations emphasised that, in the interests of efficiency, a common reporting system should be used across the UK. Those who raised this issue called on the Scottish Government to work with DEFRA and the relevant offices in other devolved administrations. There were also suggestions that any requirement for additional reporting should be incorporated into existing reporting systems (relating to the provisions of the Waste (Scotland) Regulations 2012), rather than creating a new reporting scheme / method.
- Potential conflicts of interest: It was noted that, while public reporting of business / food waste and surplus could be useful, there may be cases where this requirement would clash with legal and commercial requirements that companies must adhere to. However, further details of these requirements were not provided.
4.13 A small number of organisations made links between these proposals and other existing legislation and reporting systems. It was suggested that other current legislation may need to be amended for these proposals to be implemented. Specific mention was made of legislation relating to animal by-products and food safety. The point was also made that while local authorities have provided assistance to businesses to enable and encourage compliance with the Waste (Scotland) Regulations 2012, there has been no enforcement. There was also a view that SEPA's WasteDataFlow reporting system can be difficult to use.
Opposition to mandatory public reporting
4.14 A small number of organisations voiced opposition to the principle of mandatory public reporting of business surplus. These organisations were in the food, drink, hospitality, tourism and retail sectors. This group highlighted the same points discussed above in relation to the importance of having consistent reporting systems throughout the UK and considering the burden these new requirements would place on businesses.
Future extension of mandatory reporting requirements (Q6)
4.15 Question 6 asked respondents if they thought mandatory reporting requirements for waste and surplus should be extended to include other items in the future, such as textiles and clothing. Table 4.5 shows that around three-quarters of respondents overall (72%) said 'yes'. Individuals (77%) were more likely than organisations (59%) to say this. Among organisations, (i) food, drink, hospitality, tourism and retail organisations (ii) packaging and other manufacturing organisations and (iii) beverage and vending companies were less likely than others to answer 'yes' to Question 6. However, in general, respondents who did not answer 'yes' to this question were more likely to answer 'don't know' rather than 'no'.
Organisation type | Yes | No | Don't know | Total | ||||
---|---|---|---|---|---|---|---|---|
n | % | n | % | n | % | n | % | |
Environmental charities, third sector and community sector organisations | 25 | 89% | - | 0% | 3 | 11% | 28 | 100% |
Public sector organisations | 17 | 68% | 1 | 4% | 7 | 28% | 25 | 100% |
Food, drink, hospitality, tourism and retail organisations | 7 | 37% | 2 | 11% | 10 | 53% | 19 | 100% |
Environmental consultancies & resource management organisations | 14 | 82% | 1 | 6% | 2 | 12% | 17 | 100% |
Academic and professional bodies and business representative bodies | 6 | 67% | - | 0% | 3 | 33% | 9 | 100% |
Packaging and other manufacturing organisations | 2 | 20% | - | 0% | 8 | 80% | 10 | 100% |
Beverage and vending companies | - | 0% | - | 0% | 12 | 100% | 12 | 100% |
Total organisations | 71 | 59% | 4 | 3% | 45 | 38% | 120 | 100% |
Total individuals | 204 | 77% | 7 | 3% | 53 | 20% | 264 | 100% |
Total organisations and individuals | 275 | 72% | 11 | 3% | 98 | 26% | 384 | 100% |
Percentages may not total 100% due to rounding.
4.16 Respondents answering 'yes' to Question 6 were asked in a follow-up question to specify which other items they thought mandatory reporting requirements should be expanded to in the future. Altogether, 275 respondents (82 organisations and 193 individuals) provided further comments.
4.17 Among those who answered 'yes', comments focused on (i) the items that mandatory reporting requirements should be expanded to and (ii) the sectors that mandatory reporting requirements should be expanded to. Both these topics are discussed below.
4.18 Note that some respondents made comments at Question 6 relating to the principle or practical aspects of recording business waste and / or surplus, and on food waste / surplus, in particular. This group included some who answered 'no' or 'don't know'. These comments have been covered briefly above in relation to Questions 4 and 5.
Other items that mandatory reporting should be expanded to in the future
4.19 There was general agreement, both among organisations and individuals, that mandatory reporting requirements should be expanded to cover textiles and clothing surplus and waste in the future, with respondents making the following points.
- Some argued that the growth of 'fast fashion' (where clothing is seen as cheap and disposable) creates a clear environmental imperative to monitor and regulate what happens to surplus and waste textiles. A recurring view was that the fast fashion industry is based on a linear business model which promotes overconsumption and generates excessive waste, including plastic waste. Respondents also highlighted the ethical issues of poor working conditions of those employed in these industries.
- Some noted a specific aspect of the fast fashion industry - i.e. the very high level of returns relating to online clothes shopping, encouraged by the availability of free delivery and returns. It was estimated that the cost of handling returns is between £20 and £30 per order. It was suggested that retailers therefore have little incentive to try to resell returned items and consign them to landfill instead.
- While respondents acknowledged that some clothing retailers currently pass all unsold stock on to charities or other organisations for resale, there was a widespread view that this does not happen across the sector. Rather, some respondents cited published evidence or their own experiences of working in retail which indicated that too many clothing retailers destroy or incinerate unsold stock. It was suggested that Scotland should consider adopting the EU requirement to collect textile waste separately and divert it away from landfill or incineration.
- Some respondents commented on the definition of 'textiles'. Most commonly, they thought this should cover clothing, footwear, mattresses, and all soft furnishings (e.g. curtains, carpets and other composite textiles, rugs, etc.). Less commonly, there were suggestions that the definition should also cover car seats and bags.
- There were suggestions that all textiles (some respondents said 'all items') sold in Scotland should carry a label or 'digitised passport' advising consumers where its component parts have come from, what percentage of the item is recyclable and what action consumers can take to recycle it.
4.20 In addition to placing new reporting requirements on businesses, respondents also said there is a need to change attitudes in a society described as having been 'brainwashed' into consuming too much.
4.21 Other items frequently identified by respondents for future mandatory reporting were:
- Building materials, construction waste and construction site personal protection equipment
- Chemicals (including paints, varnishes, fertilisers, pesticides and herbicides and fuel)
- Electrical equipment (e.g. IT equipment, televisions, radios, mobile phones, headphones, charges, household appliances, tools, cables, etc.)
- Furniture (domestic and office)
- Man-made floor coverings (e.g. lino, composite materials).
4.22 Items mentioned less often included surplus or waste relating to:
- Bioresources (from agriculture, forestry, fishing and aquaculture industries)
- Books
- Bubble wrap and polystyrene
- Charity shop / jumble sale items.
- Christmas, Halloween, Easter and other seasonal decorations
- Cosmetics, hair and beauty products
- Costume jewellery
- Lighting
- Medical equipment
- Metals
- Pet food
- Seasonal bedding plants
- Stationery / greeting cards / paper / cardboard / magazines / 'junk mail'
- Storage containers, shelving, clothes hangers
- Toys
- Vehicles (e.g. cars, motorcycles, vans, trucks, etc.)
4.23 It was also very common for respondents (particularly individuals) to make general statements about the types of materials that should be considered for future mandatory surplus / waste reporting - rather than (or in addition to) identifying individual items. For example:
- All waste from all sectors / anything thrown in a bin
- Anything with a high carbon footprint
- Everything.
Other sectors where mandatory reporting requirements should be introduced
4.24 Respondents also specifically mentioned certain industries or sectors of the economy where they thought that mandatory reporting should be introduced in relation to surplus and waste. These were in relation to construction,[8] hospitality, agriculture, horticulture, fishing / aquaculture, healthcare (including pharmacological and medical),[9] online retail, energy (including nuclear energy), and petrochemical manufacturing. More generally, there was a suggestion that mandatory reporting should start with those sectors that have the highest life cycle environmental and social costs, and those with the highest reuse potential.
Ways of encouraging reuse and redistribution of surplus stock (Q7)
4.25 Question 7 asked respondents if they had any suggestions about how to encourage the reuse and redistribution of unwanted surplus stock, such as clothing and textiles. Altogether, 302 respondents (90 organisations and 212 individuals) provided comments. Respondents' suggestions are discussed first below, followed by other relevant points raised in the comments.
Suggestions for encouraging the reuse and redistribution of unwanted surplus stock
4.26 Organisations and individuals made a range of suggestions about how to encourage the reuse and redistribution of unwanted surplus stock. Most of these related to (i) possible mechanisms for facilitating reuse / redistribution of surplus stock, (ii) the types of organisations / groups that could receive redistributed surplus stock, and (iii) the potential challenges of redistributing surplus (or used) stock for certain types of materials. These three main themes are discussed below.
Mechanisms to support redistribution
4.27 Both organisations and individuals highlighted four main mechanisms for encouraging / facilitating reuse and redistribution of surplus stock: (i) legislation, (ii) 'brokerage', (iii) financial incentives (and disincentives), and (iv) Extended Producer Responsibility (EPR). Each of these are discussed below.
- Legislation: Organisations and individuals thought there should be a legal ban on retailers sending unsold stock to incineration or landfill. Respondents frequently pointed to France where such a ban has been introduced in relation to unsold clothing. However, respondents wanted such a ban in Scotland to have wider application and apply to any items that had the potential to be reused, repaired or recycled.
- Brokerage: Organisations and individuals also frequently advocated the development and fostering of new (or existing) partnerships between businesses and local reuse networks. Respondents suggested that a national (or local) 'brokerage service' could provide information to help in making connections between material surpluses in one business and the demand for that material from other industries or businesses. This type of service could take the form of a publicly available database of surplus stock (and waste) that enables potential users of this resource to be made aware of it. Examples of similar brokerage services were identified, including Olio (for surplus food)[10] and Warpit (for a range of resources).[11]
- Financial incentives: Some organisations suggested that there should be financial incentives to pass on waste stock to other producers, and financial disincentives for retailers to dispose of waste stock inappropriately. There were suggestions that the VAT system could potentially be used in this way. Similarly, respondents thought there should be greater incentives for and investments in enterprises that reuse or recycle materials.
- Extended Producer Responsibility (EPR): Organisations often suggested that the EPR scheme should be extended to cover a much wider range of materials than it does at present including, but not limited to, clothing and textiles. Respondents thought the use of this type of mechanism should be consistent across the UK.
4.28 Other mechanisms for encouraging reuse and redistribution, mentioned less often, included: (i) introducing a 'reuse donation' option at all local authority recycling centres, (ii) developing voluntary agreements with producers / retailers to redistribute surplus stock, and (iii) supporting businesses to rebrand their surplus stock for sale in international markets. Regarding the last point, it was noted that some companies have reservations about the effect on their brand image of re-selling products at cheaper prices, and so might prefer to re-label their products in these circumstances.
The types of organisations / groups that could receive unused surplus stock
4.29 There was a general consensus among organisations and individuals about the kinds of organisations or groups that could receive unused surplus stock, including used clothing / textiles.
4.30 The most common suggestion was that it should be donated to charity shops, community projects or other third sector organisations that sell or use clothing and textiles for creative / upcycling projects. Some such groups, mentioned by name, were the Revolve Network,[12] the Community Resources Network Scotland (CRNS),[13] Mary's Living and Giving shops,[14] and R:evolve Recycle.[15]
4.31 Other more general suggestions mentioned frequently were: (i) clothing banks (i.e. foodbanks for clothes), (ii) hostels, soup kitchens, and charities for refugees and people who are homeless, and (iii) recipients of benefits (e.g. through the Scottish Welfare Fund). Less often, respondents suggested that surplus clothing / textiles could be redistributed for use in higher education or further education fashion / textile departments, or in hydrothermal carbonisation applications (i.e. energy production).
4.32 In relation to food redistribution, it was suggested that community projects that work according to Dignity Principles (e.g. Community Larders and Community Meals) should be preferred over those who use the more dominant handout model.[16]
4.33 There was, however, also a caveat voiced by some respondents in relation to the redistribution of clothing and other textiles to charities. The point was made that this can have unintended consequences. Some respondents commented that a very large proportion of donated clothing (from around the world) ends up in Africa. This can have a negative impact on textile industries in emerging economies and has led to some African countries banning the import of second-hand clothing. It was suggested that care needs to be taken in the management of redistribution.
Potential challenges of redistributing surplus (or used) stock for certain types of materials
4.34 Occasionally, respondents highlighted practical challenges in arranging for the redistribution of certain kinds of products or materials - specifically branded clothing / uniforms and surplus unsold food.
4.35 With respect to branded clothing / uniforms, respondents highlighted security concerns in relation to the redistribution of such items, given the potential for individuals to pose fraudulently as an employee of a company / organisation for criminal purposes. There was a suggestion that a networked service carrying out brand removal from donated company clothing should be established. It was noted that some public bodies can access the Defence Equipment Sales Authority (DESA) where used uniforms can be processed for resale / reuse.
4.36 With respect to the redistribution of food, some respondents highlighted hygiene / health challenges - particularly with respect to food (e.g. chicken) that has already been cooked. However, others described successful food redistribution schemes. It was noted that companies like Food Donation Connection[17] and charities like FareShare[18] have expertise in locating organisations that can safely use surplus food, arranging transit and mitigating legal and hygiene risks. However, the provision of such schemes is geographically patchy, and the irregular availability of food waste presents logistical challenges.
Other points relevant to reuse and redistribution of unwanted surplus stock
4.37 In addition to the topics discussed above, respondents made a range of other points in their comments at Question 7. Those mentioned most often were the following.
- Respondents repeatedly argued that retailers and manufacturers should take action not only to enable the redistribution of unused surplus stock but, more importantly, in their view, to reduce production so that surplus stock is not created in the first place. This view was particularly common among environmental charities, third sector and community groups, and individual respondents. Some respondents suggested that manufacturers and retailers should be encouraged to develop a 'lend and lease' business model, rather than requiring products to be purchased in all cases.
- In addition to putting in place systems for reporting business surplus and waste, respondents suggested there should also be systems to track the reuse of materials / products that have been redistributed.
- Finally, some respondents made the point that government can only do so much. What is needed is 'cultural change', and more efforts should focus on persuading people that it is 'uncool' to throw things away.
Contact
Email: circulareconomy@gov.scot
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