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

2. Reduce and reuse

This chapter presents analysis of responses to Question 1 and 2, which explored views on the priority and further actions identified under the Reduce and reuse strategic aim.

2.1 Reduce and reuse: priority actions

Q1: To what extent do you agree with the priority actions proposed within the Reduce and reuse strategic aim? Please provide evidence to support your answer if possible.

Base	n=	Strongly Agree	Agree	Neither	Disagree	Strongly disagree	No answer
All respondents (n=)	156	39	65	13	8	10	21
All respondents (%)	156	25	42	8	5	6	13
All answering (%)	135	29	48	10	6	7	-
Individuals (%)	42	45	29	5	5	17	-
Organisations (%)	93	22	57	12	6	3	-
- Retail & packaging	22	23	36	23	5	14	-
- Third sector	17	12	71	0	18	0	-
- Local Authority	15	33	47	13	7	0	-
- Public body	8	38	63	0	0	0	-
- Waste management	8	13	50	25	13	0	-
- Construction / Dev[2]	7	14	86	0	0	0	-
- Other	16	19	69	13	0	0	-

Among those who answered Q1, over three quarters (77%) agreed to some extent with the priority actions within the Reduce and reuse strategic aim; 29% agreed strongly and 48% agreed. A further one in ten (10%) neither agreed not disagreed, and 13% disagreed to some extent.

While organisations recorded slightly higher levels of total agreement than individuals (78% compared to 74% respectively), individuals were more likely to agree strongly with the priority actions (45% compared to 22%). This pattern of organisations having higher total agreement but individuals recording higher strong agreement was evident across all closed questions.

Support for the priority actions varied by type of organisation, ranging from all public bodies and construction and development organisations agreeing to some extent, compared to 63% of waste management organisations and 59% in the retail and packaging sector.

Question 1 received 113 open text comments. Most respondents commented on each of the priority actions in turn, and as such, this section is structured around feedback specific to each of the priority actions.^[3] However, some respondents shared more general views on the Reduce and reuse strategic aim and the priority actions as a whole. For example, many expressed broad approval of the four proposed priority actions; 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 the priority 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. For example, one pointed out that most of the priority actions focus on planning or scoping measures as opposed to delivering direct action. As with the previous iteration of the Route Map, some respondents argued that the proposed actions place too much responsibility on the individual consumer, suggesting that more measures should be targeted at addressing the actions of producers, retailers, manufacturers and businesses.

2.1.1 Priority actions under Section 1: Drive responsible consumption, production and re-use

Develop and publish a Product Stewardship Plan to tackle the environmental impact of priority products.

Plans to develop and publish a Product Stewardship Plan were met with broad support. Respondents discussed the benefits of a Product Stewardship Plan, describing it as important in driving reuse and repair, tackling problematic waste streams, reducing fly tipping and ensuring products last longer and are repairable. Several respondents welcomed the emphasis on environmental accountability across all activities in the supply chain, and others highlighted the importance of shared responsibility throughout a product’s lifecycle. There were calls for a more ambitious timeframe for the publication of the Product Stewardship Plan, with a few respondents suggesting it would be best to publish an initial version in 2024 and then improve upon this by the 2025/26 timeframe specified in the Route Map.

“Given that work has been ongoing on this issue since 2016, we would urge a quicker adoption of widespread producer responsibility/product stewardship: the Route Map does not commit to an implementation date, and only proposes the publication of a plan by 2026.” – Action to Protect Rural Scotland

Several respondents expressed support for the priority products approach and agreed with the selection of the three products under consideration in the Route Map, recognising the carbon impact of these items.

“Supportive of the inclusion of “mattresses, tyres and textiles” in the list of priority products based on Zero Waste Scotland’s latest carbon metric report where textiles make up nearly a third (32%) of the carbon impact of Scotland’s household waste.” – Highlands and Islands Enterprise

References were made to the success of similar approaches in other countries. For example, Glasgow City Council noted that Extended Producer Responsibility policies for textiles have been successfully implemented in countries across the EU. A few organisations with expertise relevant to the priority products made detailed comments about the schemes/processes currently in place to maximise the circularity of such products. For example, the British Tyre Manufacturing Association discussed how its members are committed to developing the circular economy for tyres through the increased use of sustainable and recycled raw materials, extended product lifecycles and improved recovery outcomes for end-of-life tyres.

A few sought clarity on the process through which priority products will be identified, and a number of additional/alternative priority products were suggested. These included aquaculture equipment, lithium batteries and plastic takeaway boxes. Various Local Authorities (including Aberdeenshire, Argyll & Bute and West Lothian Councils) raised concerns about the financial burden of meeting the disposal requirements of items containing Persistent Organic Pollutants (POPs), and suggested products with POPs such as Waste Upholstered Domestic Seating should be considered for selection as priority products. LARAC echoed these concerns, highlighting “a notable absence of initiatives incorporating POPs into Extended Producer Responsibility (EPR) frameworks” and calling for the Route Map to adequately address POPs.

Some respondents, including Action to Protect Rural Scotland, shared concerns about the approach of focusing on three specific priority products, fearing that this would leave the vast bulk of the products used in Scotland within the existing linear economy model and could result in insufficient action in this area. Instead, they advocated for a move towards producer responsibility being the standard approach for all products, with exemptions applied on a case-by-case basis.

The importance of taking a four-nation approach to Product Stewardship was emphasised by a few respondents, with CIWM Scotland and SESA both noting that many policies and interventions related to product stewardship (product design, EPR etc) fall within reserved matters rather than devolved powers. A few respondents advised that the Route Map requires further consideration of the impact of Extended Producer Responsibility, particularly on businesses and SMEs.

A number of organisations within the retail and packaging sector, including The Paper Cup Alliance and Benders Paper Cups, did not support plans to publish a Product Stewardship Plan at this stage, citing significant concerns about the potential introduction of levies and taxes on single use packaging.

2.1.2 Priority actions under Section 2: Reduce food waste

Deliver an intervention plan to guide long-term work on household food waste reduction behaviour change.

Respondents from a mix of sectors expressed support for this priority action, describing food waste reduction as critical in cutting carbon emissions, addressing biodiversity loss, decreasing the environmental impact of food production and supporting food security. Several commented on the scale of current food waste levels in Scotland, with a number of local authorities and organisations in the waste management sector reflecting on recent compositional analysis studies which show significant levels of household food waste in residual waste streams.

“WRAP strongly supports the priority action for a long-term intervention plan for reducing household food waste. Household food waste represents the largest single source of food waste in Scotland (as with the rest of the UK). Therefore, minimising the amount arising and its impact is important to meeting food-waste targets as well as broader environmental targets.” – Waste and Resources Action Programme (WRAP)

Several respondents approved of the focus on driving behaviour change, emphasising the importance of widespread mindset and behaviour change in reducing household food waste.

“In relation to food waste, behavioural change is key and fundamental to unlocking reductions in food waste over the coming period.” – Scotland Excel

Some respondents provided suggestions on how to strengthen this priority action. Glasgow City Council noted that, while education and awareness raising can be helpful, there should also be a clear focus on incentivisation and providing better alternatives to encourage behaviour change and reduce household waste, for example by providing sustained funding for community fridges and developing robust local/regional food systems where local agriculture can meet local food needs.

A few respondents, including NatureScot and a small number of individuals, felt that this priority action should place a stronger emphasis on ‘upstream’ measures as opposed to focussing on the ‘end-of-pipe’ stage of food consumption. They argued that producing food that is healthy and sustainable for the planet would represent more effective resource use, accelerate the transition to net zero, build resilience to climate risks and enhance food-fibre-water security.

Develop with stakeholders the most effective way to implement mandatory reporting for food waste and surplus by businesses.

Several respondents expressed support for this priority action, highlighting significant gaps in data in this area and recognising that mandatory reporting for food surplus will facilitate effective monitoring, management and ultimately reduction of waste.

“The first step for countries and food chain operators to take meaningful food waste reduction measures is to actually measure current levels of food waste, and publicly report them. Upon discovery of waste in operations, businesses will take action to eliminate this waste given it is costly and inefficient.” – Too Good To Go

The collaborative approach set out in the Route Map was welcomed by a number of organisations in the waste management and retail and packaging sectors, among others.

However, some organisations from a mix of sectors, including local authorities and retail and packaging, raised concerns about the additional cost, resource and administrative burdens that mandatory reporting could impose on the retail and hospitality sector, cautioning that SMEs may struggle to meet the requirements.

“Small businesses understand that as part of the transition to net zero, system-wide transformation will have to be undertaken in relation to waste. However, placing further reporting requirements on small businesses will increase pressure on already squeezed resources.” – Federation of Small Businesses (Scotland)

Others advised that adequate time, investment and support for businesses will be required to facilitate mandatory reporting for food waste and surplus.

“For food waste reporting processes to be implemented, the Scottish Government must ensure that a stable and attractive policy and investment environment is created, to give businesses the confidence and knowledge to invest. Similarly, if a change in reporting process is implemented, realistic timescales must be provided to allow businesses to prepare, invest and embed the necessary changes, including behavioural change and education.” – Company Shop Group

Scottish Wholesale Association called for further detail on the practical implementation of the reporting and the calculation methods to be used, requesting clarification on how the information will be captured, assessed, and ultimately utilised. McDonald’s UK and Ireland also called for further detail, seeking clarity on the definition of food waste.

“We urge the Scottish Government to clarify the definition of food waste. Whilst we can report on food waste from the kitchen, most of the food waste generated in our kitchen is unavoidable, such as eggshells and coffee grounds. Additionally, we follow food safety and quality standards, which results in some food being thrown away.” – McDonald’s UK and Ireland

Edinburgh Chamber of Commerce questioned whether mandatory food waste reporting would apply only to commercial businesses or whether it would it also apply to other non-domestic organisations such as charities that provide food, or schools. A few respondents called for clear definitions and classifications of waste and surplus which explicitly separates edible stock from non-edible products. As with other priority actions, a few respondents, encouraged the Scottish Government to proceed with an aligned four-nation approach, arguing that Scottish-specific reporting would be more complex and require further resources for businesses that operate at a UK level.

2.1.3 Priority actions under Section 3: Embed circular construction practices

Support the development of regional Scottish hubs and networks for the reuse of construction materials and assets.

This priority action received less feedback than others, with a number of respondents noting that they had little expertise on construction and therefore did not have any comment to add. This was also reflected in the corresponding further actions relating to construction. However, most comments which did address this priority action were supportive in nature. Respondents pointed out some of the potential benefits of this action, including a more circular and sustainable construction industry, the creation of economic/commercial opportunities for businesses and strengthened local supply chains. United Kingdom Without Incineration Network (UKWIN) referred to the success of similar approaches in the USA, where reuse parks for embedding circular construction practices are helping to ensure that surplus resources are not treated as ‘waste’ when they can be reused.

Organisations within the construction and development sector were broadly supportive of this priority action, with a few acknowledging the leading role the construction sector can play in implementing circular economy practices and others welcoming efforts to share best practice, reduce barriers, and facilitate reuse of materials.

“We consider regional hubs and networks supporting reuse of construction materials and assets as a potentially positive step towards ensuring that local – and suitable – materials can be recycled where possible.” – BEFS (Built Environment Forum Scotland)

While supportive of the prioritisation of circular construction within this aim, UKRI Interdisciplinary Circular Economy Centre for Mineral-Based Construction Materials highlighted a number of broader issues limiting the potential success of platforms for listing and sourcing reclaimed materials. These included: a need for quality assurance of secondary materials for construction in terms of longevity, strength and durability; challenges with material characterisation data; and systemic barriers, such as insurers being reluctant to support firms who use reclaimed or reused products.

Scottish Ecological Design Association suggested additional actions under this objective, including net positive waste practices, integrating waste reduction into all phases of delivery, promoting Material Conservation Management Plans and mandating End of Life Phase plans.

Scottish Water proposed that machines and parts should be included in this initiative, and suggested that a construction materials library/database could be utilised by all businesses at design stage in order to “reduce virgin product use in construction and grow the market for recycled materials”.

Some individuals and organisations, including Mineral Products Association Scotland and BEFS (Built Environment Forum Scotland), called for further detail on how materials hubs would work. A few respondents, including LARAC, Argyll & Bute Council and Comhairle nan Eilean Siar advised that responsibility for the reuse of construction materials should not lie with local authorities but rather with relevant industry bodies.

The Highland Council highlighted potential challenges in the development of regional hubs and networks for the reuse of construction materials, such as securing appropriate sites and licensing matters. These concerns were echoed by other respondents; for example, The Royal Town Planning Institute Scotland felt that the Route Map would benefit from greater consideration of the spatial consequences of regional hubs for reclaimed or reusable construction materials/assets, advising that these will need to be located within a reasonable distance from sources or end users and accessible to suitable transport infrastructure, e.g. rail and road networks. In addition, the Insulation Manufacturer’s Association advised that consideration needs to be given to whether third party certification would cover construction products if reused, and one individual questioned whether warranties would remain intact for reused products.

2.1.4 Suggestions for additional priority actions

A priority action focussing on consumer education was suggested by a small number, and a few respondents expressed disappointment at the absence of any actions targeted at supermarkets and retailers. These respondents suggested additional measures such as: stricter regulation around production within the fast fashion industry; limitations around supermarket offers/deals which promote overconsumption e.g. buy one get one free; and a review of rules around ‘sell by’ and ‘use by’ dates on perishable items to minimise food waste.

“You should also tackle the lack of seasonality in Scotland’s supermarket profit-driven ‘food culture’ – which would also have a substantial impact on food import and transportation emissions, and the levels of waste created.” – Individual

A few respondents called for actions aimed at increasing donations/redistribution of surplus food. For example, the City of Edinburgh Council suggested learning could be drawn from a scheme in France whereby large supermarkets and mass caterers are required to establish a partnership with a charity to donate unsold food products and food retailers are forbidden to destroy food products still fit for consumption.

Too Good To Go proposed a number of additional actions for consideration, including:

• A strengthened mandatory food waste reporting framework which includes primary production, and phased-in reporting for medium sized businesses.
• Legally binding food waste reduction targets as recently set out by the European Commission and Parliament.
• An adjustment to financial incentives to better prioritise actions higher up the food waste hierarchy.
• Mandating the use of ‘doggy bags’ in restaurants.
• Adding food waste prevention to the curriculum for excellence to shape behaviour.

2.2 Reduce and reuse: further actions

Q2: To what extent do you agree with the further actions to 2030 listed across the Reduce and reuse strategic aim? Please provide evidence to support your answer if possible.

Base	n=	Strongly Agree	Agree	Neither	Disagree	Strongly disagree	No answer
All respondents (n=)	156	27	69	15	13	12	20
All respondents (%)	156	17	44	10	8	8	13
All answering (%)	136	20	51	11	10	9	-
Individuals (%)	42	40	29	5	7	19	-
Organisations (%)	94	11	61	14	11	4	-
- Retail & packaging	23	0	30	35	17	17	-
- Third sector	17	12	59	0	29	0	-
- Local Authority	15	27	60	13	0	0	-
- Public body	8	13	88	0	0	0	-
- Waste management	8	13	88	0	0	0	-
- Construction / Dev	7	0	71	29	0	0	-
- Other	16	13	75	6	6	0	-

Seven in ten (71%) of those answering Q2 agreed with the further actions to 2030; one in five (20%) agreed strongly and just over half (51%) agreed. There was slightly higher disagreement with the further actions than the priority actions, with 19% disagreeing to some extent.

Although total agreement with the further actions was similar among individuals and organisations (69% compared to 71% respectively), there was a more marked difference in strong agreement. Two fifths (40%) of individuals agreed strongly, compared to one in ten (11%) of organisations. While organisations in most sectors were in broad agreement i.e. over 70% agreeing to some extent, support was lower among retail and packaging organisations. Among those in this sector who answered, none agreed strongly with the proposals, 30% agreed, 35% were neutral and 34% disagreed.

Question 2 received 113 open text comments. The following section provides a summary of views on each of the 17 proposed further actions.

2.2.1 Further actions under Section 1: Drive responsible consumption, production and re-use

Deliver a prioritised approach to the introduction of environmental charges for problematic products.

There were mixed views on this further action. Some respondents, including a number of local authorities and organisations in the waste management sector, agreed that financial charges will help to disincentivise the use of problematic products and help consumers to make more sustainable choices. Aberdeenshire Council suggested that income from environmental charges could be used to ensure end markets for the recycling of all the material streams/products being placed on the market.

However, a similar number of respondents, including NFU Scotland and a number of organisations in the retail and packaging sector, expressed concern about the potential negative impacts this measure may have on businesses and consumers. A few highlighted the need to consider the viability of alternatives before implementing environmental charges for problematic products.

“SWA expresses concern about the potential ongoing introduction of new environmental charges. Any impact on the food and drink supply chain reverberates throughout the sector. When more food and drink-related products are labelled as “problematic,” businesses face additional burdens. These burdens ultimately affect consumers through higher costs or reduced availability.” – Scottish Wholesale Association

Some called for clarity on the process through which items will be defined as problematic products. A few organisations, including the Cosmetic, Toiletry and Perfumery Association, advised that decisions around which products will be subject to environmental charges should be data driven and evidence based, for example underpinned by evidence that the products are commonly littered and pose a risk of harm to the environment.

While supportive of this further action, SUEZ Recycling and Recovery UK Limited expressed concern that the timeline of 2025 and lack of detailed data would mean that the deadline is not achievable or that the action may be ineffective.

Introduce a charge for single-use disposable cups.

Respondents from a mix of sectors endorsed this further action, with some reflecting on the scale of single-use disposable cups usage/waste and the potential benefits of a reduction in their usage, e.g. a reduction in the need for raw materials to produce fibre for cups. Some agreed that introducing a charge is likely to influence behaviour change and encourage consumers to embrace more sustainable options, as has been evidenced by the introduction of the carrier bag charge.

“LARAC endorses the proposal for Scotland to introduce a charge for single-use disposable cups by 2025. This alignment is supported by compelling reasons, including that an estimated 4,566.6 tonnes of single-use cups and 583.1 tonnes of plastic lids are placed on the market annually. LARAC anticipates that implementing a charge for single-use cups would contribute to a significant reduction in their sales, as well as other disposable items. Such a decrease in demand is expected to result in a long-term reduction in the need for raw materials, such as timber felling, to produce fibre for cups and other related materials.” – LARAC

However, a few questioned the validity of direct comparisons with the carrier bag charge and expressed doubt that the measure will yield similar results, noting that unlike plastic bags, cups need to be cleaned before they can be reused. In addition, single use drinks cups are not typically taken back to the home, and cups cannot be conveniently folded away into an individual’s pocket but need to be physically carried.

There was significant opposition to the proposal among organisations in the retail and packaging sector. Reasons for disagreement included concerns about:

• The financial impact of the charge on consumers and businesses.
• A lack of consultation with stakeholders and impact assessment.
• The sustainability of reusable alternatives to single use disposable cups, which are often not made from particularly environmentally friendly materials and are difficult to recycle once they reach the end of their product life cycle.
• Risks of cross contamination with reused items.
• The scheme undermining the proposed UK-wide retailer takeback of paper cups.

“The Paper Cup Alliance do not consider it appropriate under any circumstances for charges to single-use product to be introduced without full consultation with all stakeholders and with impact assessments.” – The Paper Cup Alliance

Some organisations within the retail and packaging sector also reflected on the existing capability and capacity within the UK to recycle paper cups.

Some respondents recommended the introduction of a mandatory, producer-led takeback obligation whereby vendors or sellers of cups are obligated to accept cups back for cleaning and reuse in lieu of a consumer charge. A few called for stronger measures to be implemented, for example an outright ban on single use disposable cups or the charge to apply to other items such as single use food containers.

As with other measures in the Route Map, a few respondents encouraged the Scottish Government to align action with the UK Government to avoid undue complications for businesses that operate on a UK-wide basis.

Consult on actions regarding the environmental impacts of single use vapes.

Most respondents who commented on this further action were supportive of implementing measures to address the environmental impacts of single use vapes. Several respondents across a range of sectors supported the upcoming ban on single use vapes, citing a range of environmental, health, and safety concerns attached to vaping. Plastic-Free Dalgety Bay suggested restrictions should also be applied to reusable vapes, noting that their low-cost may result in users treating them as disposable in the face of a ban on single-use vapes.

Action to Protect Rural Scotland suggested that introducing a producer takeback requirement may be an effective approach as it would encourage reusability, better product design, and lower levels of littering. Two respondents raised concerns that producers may try to get around the ban by simply adding USB ports to existing disposable models. One anonymous organisation advised that a new Waste from Electrical and Electronic Equipment (WEEE) category should be established for vapes to ensure that producers meet their responsibilities in relation to the safe collection and recycling costs of vapes.

Scottish Grocers Federation raised concerns that this policy will have unintended consequences as it may result in a reduction in the number of people able to access vaping products as a means of tobacco cessation.

Review the feasibility of setting reuse targets.

There were mixed levels of support for the introduction of reuse targets. Some agreed that setting reuse targets may help to promote and drive reuse, and Circular Communities Scotland suggested that this further action should be upgraded to a priority action. However, concerns were raised about the obligations that reuse targets would impose on local authorities, with a few respondents expressing the view that responsibility for driving reuse initiatives should be directed towards producers. A few felt that setting and monitoring reuse targets would be a challenging task, noting that reuse takes place across multiple channels, such as charity shops, online marketplaces and informally through family and friends, and therefore will be difficult to measure.

A number of organisations across different sectors advised that reuse targets should not be set without significant, wide ranging consultation and engagement with stakeholders across the supply chain. One anonymous organisation provided a detailed response outlining a number of concerns about reuse targets specific to the Electrical and Electronic Equipment sector, for example risks that reuse could keep inefficient or unsafe products in use for longer than desirable, or conflict with other policy objectives, such as energy efficiency.

Some felt that additional measures would be required to support the successful implementation of reuse targets, such as support and investment in reuse hubs, additional resourcing for local authorities and further requirements imposed on producers to increase the reusability and repairability of products.

Develop restrictions on the destruction of unsold consumer goods.

Most respondents who commented on this action expressed broad support, considering this action an important step in the move towards a circular economy and welcoming the notion of surplus stock being redirected through avenues such as sales, donations, or recycling. A few highlighted benefits beyond environmental impact, such as the potential to ease cost of living pressures and help households in poverty. Circular Communities Scotland recommended that this further action should be upgraded to a priority action.

A few organisations advised that products that pose a potential safety risk must be taken into consideration when implementing restrictions on the destruction of unsold goods. One anonymous respondent welcomed the proportionate approach suggested in the consultation, describing an outright ban on the disposal of unsold goods as “unworkable” and noting that for the small number of unsold products which are currently destroyed, there is no realistic alternative option. The Cosmetic, Toiletry and Perfumery Association called for clearer definitions of terms such as ‘destruction’, ‘unsold’, and ‘disposal’.

While supportive of the proposed action, Action to Protect Rural Scotland noted they did not expect significant results from this policy, noting that it simply moves “a small number products onto the lowest rung of the linear economy” by switching them from ‘produce-dispose’ to ‘produce-use-dispose’. This was echoed by Scotland Excel, who flagged that it is important that such goods do not find their way almost immediately to landfill or other waste streams through alternative channels.

Develop measures to improve the reuse experience for consumers.

There was broad support for this action, with respondents suggesting measures such as: additional financial support for repair cafes, sharing libraries and food surplus redistribution hubs; strengthening rights-to-repair provisions and addressing the cultural barriers/stigma attached to buying second hand items. A few stressed that this action must be accompanied by further requirements imposed on producers to increase the reusability and repairability of products.

Deliver behaviour change-based approaches focused on sustainable consumption, aligned to Let’s Do Net Zero communications.

Most respondents who commented on this action were supportive, agreeing that behavioural and attitudinal change is key in reducing consumption and encouraging reuse among the public. Several expressed support for investment in national and local communications and education on sustainable consumption.

“Significant work is required nationally, as well as locally, to drive behaviour change and understanding around what is resource and what is waste; the value in reuse or repurposing; buying better, where possible, and keeping longer; and food waste having a real value as compostable material.” – Aberdeenshire Council

A few respondents asked for further detail on how these this action will be funded. The 'One Bin to Rule Them All' Team at University of Manchester stressed the need to move beyond behavioural change approaches in policy and highlighted that the onus should not be on consumers to make the ‘right’ choice but to ensure that sustainability is designed into products i.e. they are made to be reusable and recyclable.

Identify ways to expand business models that prolong product lifespan.

There was broad support for this action, with the lengthening of product lifespans described as “a worthwhile objective” by one respondent. A few organisations stressed the need for supportive policies to drive businesses toward adopting and expanding models that prolong product lifespan, such as incentives and mandates. Resource Management Association Scotland (RMAS) suggested that this section of the Route Map should include a reference to incentivising ‘designed longevity’ alongside ‘upgradeability, repair and circular business models.’ South Lanarkshire Council suggested that Circular Communities Scotland’s model of ‘Re-Use Consortium’ should be further explored in expanding business models that prolong product lifespan.

A few respondents, while supportive of this action, felt this aspect of the Route Map lacked sufficient and meaningful detail, and suggested that more information on the implementation of this action should be provided.

2.2.2 Further actions under Section 2: Reduce food waste

Strengthen data and evidence.

All of the respondents who commented on this action, including Waste and Resources Action Programme (WRAP), Fife Council and West Lothian Council were supportive of the proposed action to strengthen data and evidence around food waste. It was noted that quality data is likely to support effective decision making, help target activities to maximise impact and contribute to service improvement. The Highland Council noted particular interest in securing regular funding and resource support for Waste Compositional Analysis activities at a local government level.

Review the rural exemption for food waste recycling, as part of recycling co-design process.

A review into the rural exemption for food waste recycling was welcomed by some respondents, with a few organisations in the waste management sector describing it as “long overdue”. A few local authorities raised concerns about the review, with Fife Council noting that funding for additional vehicles would be required if the exemption is removed, and The Highland Council highlighting the gaps in accessible infrastructure across Scotland, particularly in the Highlands. While supportive of the review, NFU Scotland and SUEZ Recycling and Recovery UK Limited echoed The Highland Council’s concerns, noting that significant improvements in rural infrastructure would be required and some isolated communities may need to be exempt if the rural exemption is removed.

Investigate feasibility of voluntary food waste reduction action plans.

Few respondents commented specifically on plans to investigate the feasibility of voluntary food waste reduction action plans. A few respondents questioned the likelihood of businesses responding to voluntary measures and expressed a preference for mandatory action plans, with one suggesting that an official regulator such as SEPA would have more influence on this. A small number advised that this action would require consultation and engagement with industry bodies, and the Company Shop Group recommended that the voluntary action plan should only be introduced once a firm decision is made on measurement and reporting processes, as these will come “hand in hand” with one another.

Deliver enhanced support for businesses.

Most comments on this further action were generally supportive, with broad recognition of the need for enhanced support for businesses to reduce food waste. The Scottish Wholesale Association noted that feedback from members suggests that more education and training tools around food waste measurement and reduction activities would be welcomed. While supportive of this action, The Highland Council and The Association for Renewable Energy and Clean Technology both agreed that this will require adequate resources to enforce current and future legislation.

2.2.3 Further actions under Section 3: Embed circular construction practices

Develop new and promote existing best practice standards in circular practices within the construction sector, and assess the options for both voluntary and mandatory compliance.

Among comments directly relevant to this action, there was broad support for the development of new, and the promotion of existing, best practice standards. A few respondents, including The Royal Town Planning Institute Scotland and organisations from other sectors, noted that this will play an important role in facilitating a move towards more circular practices in the construction sector. Historic Environment Scotland recognised that such concepts are new for many businesses, and therefore national standards and practices would be of benefit and likely lead to more businesses mainstreaming them. There were mixed views on whether compliance should be voluntary or mandatory; a few felt that uptake of voluntary compliance is often limited, and advised that mandatory compliance is the most effective way to proceed. However, the Institute of Environmental Management and Assessment favoured an approach which involves compliance levers, such as a voluntary ‘comply or explain’ approach, with mandatory compliance reserved for the most important drivers to transition to a circular economy.

Investigate and promote options to incentivise and build capacity for the refurbishment of buildings.

Response to this further action was generally positive, with a few reflecting on the financial and environmental benefits of retrofit. A few organisations, including The Royal Town Planning Institute Scotland, Historic Environment Scotland and Glasgow City Council welcomed the proposal to work with relevant stakeholders to better understand how the local application of circular economy planning principles set out in NPF4 can support more refurbishment of existing buildings over new build.

While supportive of this further action, the Institute of Environmental Management and Assessment cautioned that when refurbishment is combined with a change of building use, stronger regulation is required to ensure any conversions provide safe and healthy spaces.

Investigate and promote ways to reduce soil and stones disturbance, movement and volumes going to landfill.

Some supported this action, welcoming the ambition to reduce soil and stone disturbance, movement and volumes going to landfill. Aside from this, there was little consensus among comments on this further action. CL:AIRE highlighted that promotion of existing best practice in circular practices is fundamental to the ways of reducing volumes of soil and stones going to landfill, citing an example of a scheme in England and Wales which has had great success in diverting soils and stones from landfill by applying the CL:AIRE Definition of Waste Code of Practice (DoW:CoP) on behalf of the Environment Agency (EA) and Natural Resources Wales (NRW).

UKRI Interdisciplinary Circular Economy Centre for Mineral-Based Construction Materials recommended that Scotland should consider how soil reuse depots can be incentivised and scaled up, so that there is a viable alternative to landfill, but recognised that there are complexities to consider such as storage costs, data capability and initiatives for separation of soil to prepare for reuse. The Institute of Environmental Management and Assessment advised that it is important to consider that soil ecology is often uniquely adapted to a particular area and so removal from site, even if the soil avoids landfill and is used elsewhere, will reduce the soil’s capacity to support biodiversity and act as a carbon sink.

One anonymous organisation felt that this action does not go far enough and recommended that soil and stones should be banned from landfill, suggesting it is easily recycled to feed circular building materials.

Review opportunities to accelerate adoption of climate change and circular economy focussed purchasing in construction.

Few respondents commented on this further action; those who did were supportive, with one highlighting that circular procurement in construction offers a significant opportunity to reduce carbon emissions and consumption in the sector.

Consider how devolved taxes can incentivise the use of recycled aggregates and support circular economy practices.

Some respondents expressed support for this further action, recognising that taxes can be a strong tool in incentivising the uptake of recycled materials.

“We strongly agree with the proposed action to consider how devolved taxes can incentivise the use of recycled aggregates and support circular economy practices. To enforce, encourage and enable circular economy activities, taxes that curb consumption and penalise undesirable behaviours are an essential implementation tool alongside regulations, incentives and reporting.” – Institute of Chartered Accountants in England and Wales

However, a few questioned the impact of this proposal, suggesting there is little scope to significantly increase the efficiency of aggregate recycling in Scotland due to current high levels of compliance. Mineral Products Association Scotland noted that policy measures and interventions to extend the lifespan of buildings could lead to a reduction in the supply of demolition waste which can be used as recycled aggregates.

While supportive of incentivising aggregate recycling, a few advised that more caution is needed with respect to incinerator bottom ash aggregate. For example, United Kingdom Without Incineration Network (UKWIN) highlighted a need to ensure that the use of incinerator bottom ash aggregate is closely regulated due to the potentially hazardous or toxic properties of this material, and is not classed as ‘recycling’.