Scotland's Circular Economy and Waste Route Map to 2030 : Analysis of consultation responses

Executive Summary

Introduction

The Scottish Government published an updated draft ‘Circular Economy and Waste Route Map to 2030’ in January 2024. This incorporated findings from a consultation on a previous draft, alongside further complementary research and updated impact assessments. The updated draft Route Map has been streamlined from seven packages to four strategic aims, each with priority actions and further actions: Reduce and reuse: Modernise recycling; Decarbonise disposal; and Strengthen the circular economy.

The Scottish Government sought views on the revised Route Map through a public consultation exercise, which took place from 18 January 2024 to 15 March 2024. The consultation contained 24 questions about the proposals, comprising eight closed and 16 open questions. In total, 156 consultation responses were received from individuals, and organisations across a variety of sectors, including waste management companies, retail and packaging organisations and local authorities.

Overview of findings

A high-level summary of responses to the closed questions in the consultation is presented in the table 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 actions set out under each of the strategic aims.

Summary of level of support for each set of actions

There were consistently high levels of support for the actions within the four strategic aims, ranging from 71% for the Reduce and reuse further actions, to 81% for Strengthen the circular economy further actions.

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 actions, or providing caveats to their support.

Strategic Aim 1: Reduce and reuse

Many respondents expressed broad approval of the actions under this strategic aim; they were described as “sensible”, “well-considered” and “important”. Others welcomed the inclusion of Reduce and reuse as the first and most prominent strategic aim in the Route Map, noting that this embraces the ethos of a circular economy and reflects the principles of the waste hierarchy.

However, some general concerns were also raised about actions under the Reduce and reuse strategic aim. A few respondents described the proposed measures as vague and non-specific, and others viewed them as lacking sufficient urgency and ambition. Some respondents argued that the proposed actions place too much responsibility on the individual consumer and suggested that more measures should be targeted at addressing the actions of producers, retailers, manufacturers and businesses.

In terms of actions targeted at driving responsible consumption, production and re-use, plans to develop and publish a Product Stewardship Plan were broadly supported, with respondents welcoming the emphasis on environmental accountability throughout the supply chain. The majority of further actions were also well received; however, there was some opposition to the potential introduction of charges for problematic products and single use paper cups, particularly from those in the retail and packaging sector.

Respondents from a mix of sectors supported the actions aimed at reducing food waste, recognising the scale of the issue and describing food waste reduction as critical in reducing carbon emissions and the environmental impact of food production. However, some raised concerns about the additional cost, resource and administrative burdens that mandatory reporting for food waste and surplus could impose on the retail and hospitality sector, cautioning that small businesses may struggle to meet the requirements.

Comments about the actions specific to the construction sector were largely supportive in nature, although some respondents flagged potential barriers to developing regional hubs and networks for the reuse of construction materials, such as securing appropriate sites, licensing matters and quality assurance of reused materials.

Strategic Aim 2: Modernise recycling

Some respondents expressed general approval of the actions under the Modernise recycling strategic aim, with a few welcoming the Route Map’s ambition for Scotland to become a world leader in recycling.

However, one of the main overarching themes under the Modernise recycling strategic aim was questions over how the proposed actions will be resourced; concerns were raised that actions may be difficult to implement due to the financial challenges facing the public sector and lack of available local authority funding and capacity. Additionally, some respondents emphasised the importance of ensuring that the proposed actions do not undermine or interfere with the implementation of legislation related to Extended Producer Responsibility and the Deposit Return Scheme.

Many comments on the household recycling actions were positive, with respondents welcoming the focus on high quality, co-designed services. Several respondents expressed support for a collaborative and multi-method service design approach involving a broad spectrum of stakeholders. Plans to develop a statutory Code of Practice and introduce end destination public reporting of recycling were welcomed, with respondents describing these as key drivers in increasing household recycling rates. However, there were mixed views on the introduction of statutory recycling and reuse performance targets and the measures aimed at stricter enforcement.

The actions focused on commercial recycling were well received, with respondents agreeing that the measures will help to address gaps in data, enhance service provision and increase compliance with requirements. However, it was noted that any measures taken to improve commercial waste recycling must be underpinned by adequate resources and support for businesses.

Strategic Aim 3: Decarbonise disposal

Some respondents welcomed the inclusion of measures which help to minimise environmental impacts of residual waste materials that cannot be avoided, reused or recycled, while others felt that the actions in the Route Map should focus solely on cutting consumption and avoiding waste at source.

Several respondents welcomed plans to develop and deliver a long-term Residual Waste Plan and a Sector-Led Plan to minimise the carbon impacts of the Energy from Waste Sector, noting that these plans will provide strategic direction and lead to more informed decision-making. However, there were mixed views on the proposal to support the inclusion of Energy from Waste in the UK Emissions Trading Scheme, with some respondents expressing support and others raising financial and logistical concerns. A few questioned whether the Energy from Waste should be considered within the Route Map at all, arguing that incineration is not part of a circular economy. The other further actions within this strategic aim were broadly supported by respondents.

Strategic Aim 4: Strengthen the circular economy

While the overall ambitions of the Strengthen the circular economy strategic aim were broadly welcomed, some respondents felt the actions in this section lacked detail, specificity and ambition.

Most respondents welcomed the proposal to publish a Circular Economy strategy every five years, but a small number considered this a low priority, arguing that the implementation of direct producer responsibility measures (e.g. regulation) is of greater importance than producing a strategy document. Some suggested areas they felt the strategy should cover.

There was broad support for the proposal to set new circular economy targets beyond 2025, with some reflecting on how targets will help to drive action and consistently monitor progress. There was strong support for the further actions aimed at research, data and evidence, sustainable procurement and skills and training.