Safeguarding Scotland's Resources - A Programme for the Efficient Use of Our Materials: Analysis of Consultation Responses

3. Products And Packaging

Sustainable design

3.1 To make lasting improvements in efficient use of resources it is important to look at the start of the process of design and manufacture of products. Around 80% of a product's lifetime environmental impact is decided by its design. The Scottish Government proposes to promote sustainable design of products and services (taking account of the key findings of their earlier review into reducing waste through better product design), including:

• ensuring the right further and higher education provision on sustainable design through integrating design into current projects looking at Low Carbon Opportunities and Skills Implications (led by Scottish Enterprise);
• providing guidance and training on the benefits of sustainable design in resource efficiency advice to businesses and Resource Efficient Scotland's programme of seminars and events;
• supporting the work of the Product Sustainability Forum^[8] to assist businesses in identifying key areas to improve product design;
• promoting the case for sustainable design in EU legislation and policies, such as the Ecodesign Directive and the Eco-Innovation Roadmap.

Question G: We are interested in receiving feedback on the proposals designed to encourage more efficient use of material resources in providing the products and packaging we need. Do you agree with the actions identified to support sustainable design of products?

3.2 Fifty five respondents (56% of standard responses) answered this question as follows:

	No.	%
Agree with actions	40	73
Partially agree	10	18
Disagree
Commentary only	5	9

3.3 A few respondents pointed out that there is much current and completed work on sustainable product design which should inform the proposals. One respondent (Man) urged that promotion and support of sustainable design should be framed in such a way as to allow for bespoke solutions, and the flexibility to accommodate the needs of different companies and sectors. Some respondents emphasised that promotion should focus on design for reuse; recycling; disassembly; easy and economic repair; long life; and end-of-life disposal.

3.4 Of the four featured ways in which the Scottish Government intends to promote sustainable design of products and services, the proposal to include design in education provision attracted most explicit cross-sector support. This was seen as providing long term gains and opening up potential for transfer of knowledge across industries. Comments included:

'....there should be strong links made with academia, so as to bed the knowledge and expertise within the education system in Scotland and also to develop strong working relationships with trade associations who could promote best practice to members' (The Chartered Institution of Wastes Management).

3.4 Explicit support for the work of the Product Sustainability Forum was provided by three respondents. One remarked:

'We see this forum as the most appropriate body for industry, government and academia to engage on improving the sustainability of products' (Scottish Food and Drink Federation).

3.5 Regarding the proposal to provide guidance and training on the benefits of sustainable design, two respondents provided explicit support with one (PR-C) commenting that local guidance could fill in any gaps in UK-wide provision. Three local authorities remarked that as householders contribute to driving markets, then guidance and education should also be directed at them, to support more informed choices.

3.6 Two waste management companies addressed the proposal to promote the case for sustainable design in EU legislation and policies. One commented:

'....we would like to see the Scottish Government develop strong links with global and pan-European businesses with Scottish economic interests, as well as design initiatives from the EU, as there will be merit in maximising collaboration opportunities on this set of issues' (Resource Association).

Perceived challenges and concerns

3.7 A recurring comment was that as most of the goods purchased in Scotland are designed and manufactured elsewhere, the proposed measures have limited potential for impact (13 mentions). Two respondents remarked that it will be difficult for Scotland to work in isolation on this, and instead will need to look at opportunities to work collaboratively with other nations.

3.8 Other concerns were:

• As the UK is a single market, Scottish initiatives need to avoid duplication with measures elsewhere (2 mentions).
• The proposals should ensure that the full lifecycle of products are properly accounted for and the relevant metrics are used to assess their design (1 mention).
• For the proposals to come to fruition, they need a supporting framework of grants, consultancy and access to expertise (1 mention).
• Shifting the attitudes of the consumer is more difficult and needs to be factored in (1 mention).
• The design of sustainable products needs input from raw material suppliers. Suppliers do not often get involved at the design stage, which restricts consideration of a range of design alternatives (1 mention).

Packaging waste

3.9 The Scottish Government proposes to work with other UK administrations to amend existing Producer Responsibility Regulations to enable separate identification of packaging waste arising in Scotland to use as a baseline for subsequent separate Producer Responsibility targets for packaging waste in Scotland.

Question H: Do you agree with the principle of amending the existing Producer Responsibility Regulations to enable separate identification of packaging waste arising in Scotland; to use as a baseline for subsequent separate Producer Responsibility targets for packaging waste in Scotland?

3.10 Sixty three respondents (64% of standard responses) answered this question as follows:

	No.	%
Agree with principle of amending PRR	21	33
Partially agree	7	11
Disagree	31	49
Commentary only	4	6

NB Percentages may not add to 100% exactly due to rounding.

Concerns regarding the proposal

3.11 Whilst many respondents agreed with the principle of producer responsibility for packaging waste there were strong concerns particularly from retailers, manufacturers and packaging organisations that the predicted additional burden and associated costs resulting from this proposal may not be offset by the benefits to accrue. The proposal was not seen to be in keeping with the Better Regulation agenda. Typical comments included:

'....this proposal does not sit well with a stated Scottish Government aim to promote better regulation, to simplify and reduce burdens on businesses' (Scottish Grocers' Federation).

'....the costs and administrative burden for producers of implementing these requirements will lead to no environmental benefit and could in fact lead to a dis-benefit as resources are moved away from on the ground environmental improvements to reporting activity' (RePIC Ltd).

3.12 The potential complexity of the requirements for businesses with markets outwith Scotland were remarked upon repeatedly, with a recurring view that the accuracy of the information collected may be questionable. One respondent's view was typical:

'Our members would not be able to quantify with any accuracy the amounts of their packaging placed into the Scottish market... our members do not ...have full control over the final location of stocks' (Food Service Packaging Association).

3.13 The risk of potential abuse of the proposed scheme and fraudulent reporting was raised by two respondents.

3.14 A recurring theme was that more research should be undertaken into the reasons for Scotland's relatively poor performance in terms of recycling packaging waste and also a cost-benefit analysis of the proposal should be carried out, before deciding to pursue this option (10 mentions).

3.15 Another recurring view was that the proposal could contribute to lack of parity with and inconsistency between Scotland and the rest of the UK (7 mentions). One respondent commented:

'We agree that Scotland-only data would be interesting but would suggest that it is also very nationalistic and so, perhaps a bit divisive. At the moment, Scotland is still part of the UK and as such, is covered by the UK-wide legislative framework' (Scotpak).

3.16 Other concerns about the proposal included:

• There have been several new measures and regulations introduced and we should wait to see what impact they are having before going down this route (4 mentions).
• The proposal would require greater regulatory oversight of the Packaging Recovery Note (PRN) system and stricter data requirements on manufacturers (WM).
• Reprocessors would require to be accredited with both the Environment Agency and SEPA which would add to their costs (Pack).

Reasons given in support of the proposal

3.17 Those agreeing with the proposal represented seven different respondent sectors, and included over half of the local authority respondents. Some described the rationale behind their support, with each of the reasons below provided by one or two respondents:

• the proposal is in keeping with the principle of polluter pays
• it will result in a higher level of recycled packaging in Scotland
• it will reap rewards without creating unnecessary red tape
• it is needed in order to contribute to ZWS
• it will reduce unnecessary packaging at source
• it could be linked to identifying costs of packaging which will assist manufacturers and consumers
• it reflects the different Scottish geography and socio-demography
• it is sensible to have distinct Scottish data as Scotland has set more challenging targets than England.

Retailers

3.18 The Scottish Government proposes that retailers who are already required to report under the Producer Responsibility Regulations on packaging of products sold will also need to provide a separate figure for the proportion sold in Scotland.

Question H-1: Do you agree with the approach regarding retailers?

3.19 Thirty one respondents (31% of standard responses) answered this question as follows:

	No.	%
Agree with approach regarding retailers	12	39
Partially agree	4	13
Disagree	9	29
Commentary only	6	19

3.20 Those providing reasoning to underpin their support of the proposed approach were largely local authorities and PR Compliance organisations. The consensus was that retailers were typically well placed to be able to identify which packaged products were sold in Scotland and that the requirement to report under the Producer Responsibility Regulations would not add significantly to their existing obligations. One local authority urged that robust enforcement will need to be in hand to ensure compliance.

3.21 Opponents of the proposal (representing different respondent sectors) were largely of the view that benefits arising from the proposed action will not be significant enough to warrant the additional administrative burden which the proposal will impose.

3.22 Four respondents questioned the premise that the effect of cross-border movement will be neutral, particularly for retailers in border areas who may not be clear on whether their packaging ends up in England or Scotland.

3.23 Three PR Compliance organisations and a manufacturer considered that the proposal placed too much of an additional burden on retailers due to the potential complexity of the task.

3.33 Two packaging respondents and one PR Compliance respondent argued that any data arising may not be meaningful due to inaccuracies and omissions (e.g. transit and tertiary packaging discarded at the retailer's premises will not be included).

Supply chain

3.34 The Scottish Government believes that it would be difficult in most cases for businesses at the start of the supply chain (furthest away from the point at which the packaging becomes waste) to determine whether their product ends up as waste in Scotland or another part of the UK. It proposes, therefore, that supply chain companies who are already required to report under the PR regulations on packaging of products sold will only be required to provide evidenced estimates for the proportion sold in Scotland.

Question H-2: Do you agree with the approach regarding the retail supply chain?

3.35 Twenty seven respondents (27% of standard responses) answered this question as follows:

	No.	%
Agree with approach regarding the retail supply chain	5	19
Partially agree	4	15
Disagree	16	59
Commentary only	2	7

3.36 No substantive comments were made by the five respondents who agreed with the proposal. One (LA) qualified their agreement, stating that although they supported the approach they acknowledged that there may be associated complexities. Another local authority supporter urged that regular reviews should be conducted to assess the complexity of the scheme in operation; a third local authority emphasised that the proposal would need to be underpinned by compliance schemes.

3.37 Amongst the 16 respondents disagreeing with the proposal, the overarching concern was that the quality of the data collected would be too poor to be useful. PR Compliance organisations were well represented amongst opponents. Typical comments were:

'Producers further up the supply chain have no way of knowing what proportion of packaging they supply actually ends up in Scotland. Any proportionate figure would be entirely arbitrary. Establishing a separate and parallel system would appear to simply add bureaucracy and cost into the system' (Complypak Limited).

'The quality of the estimated data is likely to be so poor as to render it worthless, and therefore not useful, either statistically or qualitatively' (Hewlett-Packard).

3.38 One respondent (PR-C) expressed concern that each producer might create their own allocation formula, with another (PR-C) arguing for clear guidance on allocation method and acceptability of evidence.

Question H-3: Do you agree with the proposal that those in the pre-retail supply chain should be permitted to use a set allocation of their total output as 'Scottish' waste?

3.39 Twenty nine respondents (29% of standard responses) answered this question as follows:

	No.	%
Agree with set allocation	3	10
Partially agree	4	14
Disagree	20	69
Commentary only	2	7

3.40 Amongst those who agreed or partially agreed with the proposal, two local authorities argued that the underlying principle is sound. One stated:

'The general principle of the proposal is reasonable and should ensure a fair and accurate allocation system' (North Ayrshire Council).

3.41 Others considered that the proposal struck a balance between establishing a reasonable picture whilst achieving an acceptable level of accuracy. Two respondents (PR-C and WM) called for policing of the system and consistency in formulae for calculating Scottish waste.

3.42 As before, the overriding concern amongst opponents was that the data quality will be so inaccurate as to render it meaningless. Once again, it was commented that the benefits of the system will not outweigh the drawbacks in operation, such as likely additional costs.

3.43 One local authority questioned whether the data could not be provided instead by SEPA or through the Waste Transfer Note System.

Question H-4 : If the supply chain businesses chose to provide evidence of the exact amount of their product that ends up as waste in Scotland, what evidence should be accepted?

3.44 Twenty eight respondents (28% of standard responses) addressed this question although several of these simply commented that providing meaningful evidence would be challenging.

3.45 Two respondents (PR-C and NGO) urged that guidance on acceptable evidence should not be overly prescriptive.

3.46 Others provided suggestions for the nature of the evidence to be accepted:

• sales of packaged goods to Scottish distributors (4 mentions)
• market research/surveys and consumer trend data (4 mentions)
• system similar to transfer notes/weighbridge transactions (3 mentions)
• invoicing data (1 mention)
• delivery notes (1 mention)
• waste management firms to supply evidence which is verified by SEPA (1 mention)
• evidence that requires minimum input to report (1 mention).

Question H-5: Should a distinction be made between the different stages of the supply chain?

3.47 Twenty five respondents (25% of standard responses) addressed this question. There were very few substantive points made, with some simply re-iterating earlier points made.

3.48 Three respondents recommended that the Scottish Government examines how the existing PRN system works in order to inform the issues raised, particularly around apportioning of payments. One respondent (WM) urged that the Scottish system should be aligned with UK regulations. Two manufacturers remarked that they do not wish to share commercially confidential information with organisations across the different stages of the supply chain.

3.49 A recurring theme was that distinguishing between the different stages is too confusing and produces poor quality data. It was re-emphasised that parts of the supply chain do not know where packaging ends up. Two respondents (Man, PR-C) suggested that differentiating between the different stages of the supply chain could lead to double-counting.

Importers

3.50 Importers collect the 'rolled up' obligations for activities that take place outside the UK. This ensures that when packaging becomes waste, 100% of the obligations are accounted for. The Scottish Government proposes that as with retailers, importers who are already required to report under the PR regulations on packaging of products sold will also need to provide a separate figure for the proportion sold in Scotland.

Question H-6: Do you agree with the approach regarding importers? Please give reasons.

3.51 Twenty one respondents (21% of standard responses) answered this question as follows:

	No.	%
Agree with approach	7	33
Partially agree	6	29
Disagree	6	29
Commentary only	2	10

NB Percentages may not add to 100% exactly due to rounding

3.52 Amongst those agreeing with the proposal were respondents who envisaged challenges to its operation, but were prepared to support the approach should it become implemented. Two respondents (WM, LA) recommended that a centrally supported awareness campaign should underpin implementation, in order to refresh knowledge of obligations and provide information on what is expected regarding reporting data and why. One respondent (PR-C) urged that research should still take place to investigate whether Scotland should go down the route of setting separate PR targets. One waste management company suggested that further work is done on the most effective way to manage the data collection system to make it fair and clear. Another respondent agreed with the approach providing that this applies only to goods imported directly to Scotland, on the grounds that:

'Companies in other parts of the UK will have difficulty in establishing how much of the imported transit packaging relates to goods that may eventually end up in Scotland' (ThInc).

3.53 Concerns over the proposal were expressed and included:

• Data collection will be complicated and may not be robust (5 mentions). One view was:
  'It could become complicated with national retailers who would have to ensure stock control methodology to accommodate this; also consideration needs to be taken for further cross-border product movement' (North Lanarkshire Council).
• The benefits (seen as estimated data) do not outweigh the additional work required (1 mention).
• Better to maintain UK-wide data rather than try to distinguish Scottish information (1 mention).

3.54 A few queries were raised:

• Could current information systems such as the Duty of Care Waste Transfer notes not be adapted to suit? (4 mentions)
• Would this be imposed on those importing to the UK or to Scotland? Would it apply to Scottish registered companies (even if based elsewhere) only, or those located in/with a representative in Scotland? (3 mentions)

Reprocessors (recyclers) and exporters

3.55 Accredited Reprocessors and exporters submit data on the tonnages of packaging waste they have reprocessed in the UK or exported for reprocessing abroad. The Scottish Government proposes that Reprocessors and exporters who wish to issue Scottish Packaging Waste Recovery Notes (PRNs) or Packaging Waste Export Recovery Notes (PERNs) would need to demonstrate that the packaging waste was originally collected in Scotland. The Government considers that this is unlikely to require significant extra resource as the Duty of Care requires that waste transfer notes record the origin of the waste. The existing accreditation system is voluntary and it is suggested that the additional Scottish evidence is also voluntary. If the evidence fetches a higher price on the market, the Scottish Government believes it will be more attractive to reprocessors to make the additional investment in administration to record the necessary details.

Question H-7: Do you agree with the approach regarding reprocessors and waste exporters? Please give reasons.

3.56 Twenty seven respondents (27% of standard responses) answered this question as follows:

	No.	%
Agree with approach	8	30
Partially agree	3	11
Disagree	10	37
Commentary only	6	22

3.57 One respondent (PR-C) outlined the reason for supporting the proposal as enabling more accurate representation of the amount of packaging waste arising in Scotland by issuing evidence on the basis of collection source rather than treatment location. There was more commentary from those disagreeing with the proposal and/or those with concerns. Most prominent were:

• Introduces more complexity in an already volatile market (4 mentions).
• Inappropriate in the current situation with insufficient capacity within Scotland for reprocessors to meet demands (3 mentions).
• More research needed first on the relative value of Scottish P(E)RN against P(E)RN (2 mentions).
• If the scheme remains voluntary, companies are unlikely to buy into an approach which presents them with additional costs (2 mentions).
• Difficult for companies to ascertain the difference between Scottish and non-Scottish material (2 mentions).
• Disparity in purchase price between evidence and associated market forces could result in preference for non-Scottish evidence (2 mentions).
• Not clear what the added environmental value of the approach will be (1 mention).
• Scottish PRNs will be in short supply and expensive (1 mention).

3.58 A comment repeated by three manufacturers and one waste management company was:

'.... a level-playing field should be set for Scotland and UK reprocessors by the three devolved administrations and the Westminster Government agreeing to limit the PERN that can be claimed by materials exporters to only the weight of compliant materials exported. The current situation allows PERNs to be claimed on non-target, non-recyclable materials.'

Compliance and fraud/double counting prevention

3.59 Under the proposed system SEPA would extend its existing monitoring of registered compliance schemes and reprocessors to ensure that Scottish evidence is only issued for waste arising in Scotland. As waste from Scotland will potentially be dealt with in other parts of the UK, and it is anticipated that reprocessors and exporters will wish to issue SPRNs/SPERNs on Scottish waste, the co-operation of the relevant agencies to ensure compliance by companies operating outwith Scotland will be required.

Question H-8: We would welcome further views on the proposed approach to prevent fraud and double counting.

3.60 Nineteen respondents (19% of standard responses) addressed this question. Several of these cautioned that the more complex the approach, the greater the risk of fraud and double-counting. Comments included:

'....simplicity in compliance systems reduces fraud' (The Co-Operative Group).

'Further splitting data down to a Scotland subset would result in greater potential for errors. In any system where there is a lack of clarity linked to a regulatory requirement, the potential for fraud is increased and effective policing is decreased' (RePIC).

3.61 Three respondents (two of them PR-Compliance organisations) considered that placing a premium on Scottish PRNs/PERNs would set the context for a greater risk of fraud.

3.62 A concern for four respondents was that additional enforcement systems will be required to police the proposed approaches outlined in the consultation. This would have implications for costs of enforcement and need for consistency across the UK. One local authority argued this provided further argument against a separate system to measure packaging waste arisings in Scotland.

3.63 One retailer queried how SEPA intended to get the co-operation of agencies outwith Scotland without the support of regulation. A waste management company recommended that those currently operating the system should be engaged with fully, in order to address the issues of potential double-counting and fraud.

Deposit return schemes

3.64 Many countries run deposit return schemes particularly for drink containers which regularly achieve return rates of over 80%. Alternatively 'reverse vending' schemes can provide an incentive for recycling certain containers, e.g. through reward card points. The consultation did not pose a specific question seeking views on such schemes, but some respondents alluded to deposit return schemes at various points in their responses on other issues. A summary of the key points made follows (although these views may not represent those of the entire respondent population as a question on deposit return schemes was not asked).

3.65 Seven of the standard responses (three local authorities; two individuals; NGO; Pub-Oth) welcomed future piloting of deposit return schemes in Scotland which they felt had worked well in other countries, leading to benefits such as reduced litter and less packaging waste. The WWF campaign supported the introduction of a nationwide deposit return system (see Annex 2 for text).

3.66 Eight respondents (including three retailers and three manufacturers) argued against such schemes. Their key arguments were that these:

• are expensive to operate
• are inefficient in comparison to existing household recycling schemes
• open up opportunity for fraud
• undermine existing local authority provision for recycling
• potentially would create a significant price differential between drinks in Scotland compared with the rest of the UK.

Critical materials

3.67 Small waste electronic and electrical items contain valuable but potentially hazardous materials and can also have a high reuse value. However, all too often they are simply thrown away and their value is lost. Only around 22% of small waste electrical and electronic equipment (WEEE) is collected for recycling in the UK at present. ZWS, with support from SEPA, will therefore work with retailers and local authorities to encourage voluntary action to help more people return more of this type of equipment for recycling and reuse.

Question I: For those involved in the sale of electronic and electrical equipment or collection of WEEE, we would welcome views or good examples of the most effective approaches to making it easier for people to return more of this type of equipment for recycling and reuse.

3.68 Thirty three respondents (33% of standard responses) addressed this question.

3.69 The overarching recommendations emerging from most of these responses were for increased, accessible collection provision supported by public awareness raising and education campaigns. There was general agreement that out-of-town collection centres for small WEEE were not as useful as local collection points, particularly for householders who are elderly, disabled or have no access to vehicles.

3.70 One manufacturer suggested that the presence of collection points in busy retailing outlets will contribute to increasing public awareness. A few other respondents, however, highlighted potential problems with returning heavier items to retailers, such as kettles and televisions. One view (PR-C) was that disadvantages of take-back schemes for very small WEEE are that they are less likely to yield large tonnages and they open up the possibility of theft. Another respondent (Ind) commented that it would be challenging to accommodate small WEEE bought online within a take-back scheme.

3.71 One way to make collection easier for householders is by increased/dedicated kerbside collection of unwanted WEEE. This was recommended by several respondents, some of whom suggested special, well publicised collections such as twice a year kerbside amnesties. Two local authorities, however, suggested that there may be a need to subsidise kerbside collections through producer responsibility or a third party so that local authorities are not over-burdened by the additional costs incurred.

3.72 Other recommendations were for:

• More focus on making it easier to reuse items including community reuse schemes (4 mentions).
• Introducing mandatory take-back schemes (2 mentions).
• Actively involving community groups already specialising in the collection and processing of WEEE (1 mention).
• Incentivising take-back (e.g. by offering discount on upgrades if the old equipment is returned) (1 mention).
• Setting increased recycling targets for each category of WEEE (1 mention).

3.73 Many respondents highlighted examples of effective initiatives and/or aspects of schemes which work well. A recurring theme was that the involvement of local authorities enables collections of WEEE to be harmonised with other waste streams, and supports effective implementation of schemes. Specific examples of effective local authority partnership working were provided:

• Scottish Borders Council and North Ayrshire Council both work with their WEEE Producer Compliance schemes on local community reuse schemes.
• Highland Council worked with the social enterprise group ILM (Highland) who carry out collections on behalf of RePIC. By working in partnership with the council, ILM (Highland) built up the expertise required to enable it to bid for contracts on a level playing field.

3.74 Other examples of successful working were provided and included:

• Large WEEE taken back by supplier at the time of delivery of new goods (3 mentions). One retailer commented:

'We collect over 250 items of large WEEE a month and we pass it onto a business called Washroom Partnerships. The process of collecting large WEEE is simple for our customers and it works well because they do not have to do anything in particular to have their WEEE recycled/reused' (The Co-Operative Group).

• A local authority introduced small WEEE collection to its kerbside collections.
• Small WEEE collection points were set up at schools following a campaign, with the schools receiving a proportion of the income generated by this.
• Higher civic amenity site provision per capita produced better than average collection of WEEE.
• Dedicated WEEE communication/awareness activities were linked to amnesty days.
• Wecycle in the Netherlands works on behalf of 6 producer foundations, and amongst other functions, mobilises a team organising nationwide collection and high grade recycling of WEEE.
• Dumfries and Galloway Council operates a larger goods uplift service for a charge; also trialling the use of 'in town' small WEEE recycling banks.
• The Co-Operative Group operates small WEEE collections in all of its Scottish food stores.
• Perth and Kinross Council set up a WEEE collection point at its largest recycling centre to divert WEEE (computers, laptops, printers, mobile phones etc) from landfill to reuse. Perth College WEEE Centre refurbishes these for resale at affordable prices or strips unusable/un-repairable items down to their individual components for recycling. The students doing this gain a qualification which helps them in securing further employment.
• In North America a scheduled WEEE collection service is operated by local authorities at the kerbside on dedicated days of the month.

Question J: We would be interested in your views on priorities to increase resilience of the Scottish economy to supply risks associated with critical materials, and for maximising the opportunities for Scottish businesses.

3.75 Twenty seven respondents (27% of standard responses) addressed this question.

3.76 The most common response (eight respondents, five of whom were local authorities) was to recommend investment in innovation in infrastructure and technology with the aim of developing specialist reprocessing facilities within Scotland. One respondent commented:

'Many of the desired policies and objectives of the Scottish Government are based on growing the volumes of materials captured, raising the quality standards of materials and then creating jobs by processing and treating that material in Scotland. This requires a reprocessing infrastructure which may require specialist support in the form of investment, enterprise support engaging existing manufacturers and innovative processes and technologies' (The Chartered Institution of Wastes Management).

3.77 The theme of investment in research and development was taken up by others (5 mentions) who advocated: identification of alternatives to these critical materials; mapping of the current destination of critical materials; and auditing of current provision for reprocessing in Scotland. One respondent remarked:

'It has to be acknowledged now that if the economy is to remain resilient in the long term, new technologies and alternative materials will be required. What is necessary both now and in the long term is support for innovation and cross-party research which utilises the expertise of Scottish universities, design experts and business' (Scottish Council for Development an Industry).

3.78 Five respondents considered that improving packaging design to facilitate recycling and sustainability will increase resilience and reduce risks. A further five respondents recommended that the Scottish Government get tougher by: setting industry-specific resource efficiency and recovery benchmarks for these critical materials (WM); stockpiling and banning the export of critical materials (PR-C); establishing a national strategy/resource security action plan (LA, WM); and exerting more pressure on businesses to accept WEEE (Ind).

3.79 Other suggestions for increasing reliance and maximising opportunities for Scottish businesses were:

• Offer incentives (e.g. tax breaks, grants, rewards) for collection and recycling to ensure products containing these critical materials are collected separately from other items (4 mentions).
• Increase communication between the recycling industry and producers to enable more recycling (3 mentions).
• Allow processors to trade WEEE evidence (1 mention).
• Perhaps actively encourage the import and reprocessing of these materials in Scotland (1 mention).
• Make it easier (relax regulations) to facilitate the entry of critical materials into Scotland (1 mention).