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

3. Modernise recycling

This chapter presents analysis of responses to Question 3 and 4, which explored views on the priority and further actions identified under the Modernise recycling strategic aim.

3.1 Modernise recycling: priority actions

Q3: To what extent do you agree with the priority actions proposed within the Modernise recycling strategic aim? Please provide evidence to support your answer if possible.

Three quarters (76%) of those who answered Q3 agreed with the priority actions proposed in the Modernise recycling strategic aim. One quarter (25%) strongly agreed and 51% agreed, with one in ten (9%) neutral and 15% disagreeing.

Organisations recorded a higher level of agreement than individuals (81% compared to 67% respectively), with the majority of organisations again agreeing rather than strongly agreeing. Levels of agreement varied considerably across different sectors. Support was lowest among construction and development organisations (50% agreed and none agreed strongly) and third sector organisations (53% total agreement and 34% disagreeing). However, at least 86% of all other sectors agreed to some extent, including all waste management organisations and 94% of retail and packaging organisations.

Question 3 received 99 open text comments. As with Questions 1 and 2, some respondents provided overall feedback on this aspect of the Route Map. For example, some expressed general approval of the priority actions, with one individual describing them as “excellent ideas”. A few welcomed the Route Map’s ambition for Scotland to become a world-leader in recycling, where recycling and reuse services are easy to use and accessible to all.

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 repeatedly raised that the 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, hamper or interfere with the implementation of legislation related to Extended Producer Responsibility and the Deposit Return Scheme. As with other areas of the Route Map, a few respondents felt that there is a disproportionate focus on the actions of households and local government, and called for more actions targeted at retailers, businesses and producers. Some respondents, including Consumer Scotland, called for the Route Map to place greater emphasis on actions higher up the waste hierarchy, stressing that preventing waste and reducing consumption is of higher importance than recycling and disposal.

3.1.1 Priority actions under Section 1: Modernise household recycling

Facilitate a co-design process for high quality, high performing household recycling and reuse services with households, COSLA, local authorities and service operators.

Many comments submitted under this question focused on the further actions which the co-design process will inform, e.g. the development of a statutory Code of Practice, as opposed to the co-design process itself. As such, these comments have been considered under the relevant further action subheadings in the next section.

The majority of comments which directly addressed this priority action were positive, with respondents welcoming the focus on high quality and efficient collections. Several individuals and organisations from a mix of sectors expressed support for a collaborative and multi-method service design approach involving a broad spectrum of stakeholders.

Some respondents in the retail and packaging sector, including Scottish Beer and Pub Association and British Glass, recommended that the process should be open to all stakeholders within the packaging value chain including brands, retailers, reprocessors and recyclers. Glasgow City Council advised that the co-design process should involve citizens from areas with low recycling rates to identify current barriers to recycling and ways to overcome these. There were also calls for engagement with communities and businesses to take place at a local, grass roots level in addition to national consultation.

However, Argyll & Bute Council raised concerns about the practicality of applying co-design principles to waste and recycling services, fearing that this may result in negotiations being removed from local government control during service changes. The Highland Council, LARAC and CIWM Scotland echoed these concerns, discussing the difficulties of managing the expectations of multiple stakeholders and the likelihood of conflicting views if several stakeholders are involved. A few, including the Association for Renewable Energy and Clean Technology, advised that local authorities may be best placed to lead discussions.

Some respondents, including various local authorities, requested more detail on how the proposed co-design process will be funded and the extent of local government involvement in the plans.

Some comments focused on a desire for more consistent recycling service provision across each of Scotland’s local authority areas, with a few respondents suggesting that a more aligned approach will result in less confusion and higher recycling rates. However, others recognised the challenges of this approach, given differences in geography, housing types and the local availability of recycling infrastructure across Scotland.

3.1.2 Priority actions under Section 2: Commercial recycling

Review of compliance with commercial recycling requirements.

The review of compliance with commercial recycling requirements was broadly welcomed, with a few reflecting on issues with the quality of material collected from commercial premises and others noting this will help to understand, and subsequently address, barriers to compliance with the requirements.

“We would urge the Scottish Government to engage widely with businesses to identify the underlying reasons or barriers to compliance including, among other aspects, whether they have reasonable access to facilities that make sustainable waste decisions practical and cost-effective, and if not, why not and what is needed. ICAEW would be pleased to support this effort through engagement of its members.” – Institute of Chartered Accountants in England and Wales

Some respondents suggested that additional support for businesses would be welcomed, for example to help encourage more diversion of recycling, reduce overall waste and reduce the contamination of trade recycling bins. More widely, a few stressed that any measures taken to improve commercial waste recycling must be underpinned by adequate resources, both for communication to raise awareness of the requirements but also for enforcement.

While the specified timeframe for this action was welcomed by a few, it was described as highly ambitious by others, who felt it may not be achievable.

Co-design measures to improve commercial waste service provisions.

Several respondents expressed support for this priority action, recognising the need for a broad spectrum of stakeholders including local government, the waste industry and businesses to participate in the co-design process. Engagement with the business community was seen as particularly important by some, with a few respondents recognising the need to gather insight on the different waste streams and commercial needs of businesses to maximise efficiency and compliance. A few organisations within the retail and packaging sector advised that the co-design process should involve all stakeholders within the packaging value chain; others emphasised the need to consult a wide variety of businesses, including both larger corporate organisations and SMEs.

INCPEN endorsed the timeframe of this priority action, noting that the timescales proposed offer opportunities for learnings from the co-design process on household recycling to be fully maximised.

Aberdeenshire Council cautioned that, as a local authority which collects trade recycling on household collection routes, significant differences between commercial and household collection services would require additional resources and infrastructure. The Highland Council sought greater detail on the proposal, noting that most commercial waste collectors operate in a highly competitive environment, which has the potential to make co-design with stakeholder engagement extremely difficult.

The decision not to proceed with mandatory commercial zoning measures was welcomed by a number of respondents in the retail and packaging sector.

3.1.3 Suggestions for additional priority actions

The most common suggestion for an additional priority action in this area related to labelling; some called for the introduction of a requirement to include simple, clear recycling labels on packaging. Other suggestions included a priority action aimed at optimising recycling of construction materials and a specific action on anaerobic digestion, for example ‘explore opportunities to increase food and garden waste collection and anaerobic digestion treatment’.

3.2 Modernise recycling: further actions

Q4: To what extent do you agree with the further actions to 2030 listed across the Modernise recycling strategic aim? Please provide evidence to support your answer if possible.

Levels of support recorded for the further actions to 2030 in the Modernise recycling strategic aim were very similar to support for the priority actions. Overall 76% of those who answered agreed to some extent, with 27% strongly and 49% agreeing.

Over four fifths (82%) of organisations agreed to some extent, compared to 66% of individuals, although again individuals were more likely to agree strongly (41%). At least 85% of organisations who answered in each sector agreed with the further actions to some extent, including all three organisations in the construction and development sector. However, support was lower among third sector organisations, with only half of those answering expressing agreement with the further actions and one quarter (28%) disagreeing.

Question 4 received 93 open text responses. Analysis of feedback on each of the proposed further actions is provided below.

3.2.1 Further actions under Section 1: Modernise household recycling

Develop a statutory Code of Practice for household waste services.

Plans to develop a statutory Code of Practice^[4] for household waste services were welcomed, with respondents describing this as a key driver in increasing household recycling rates. A few organisations, including Scottish Environment LINK and Circular Communities Scotland, suggested this further action should be upgraded to a priority action. A small number highlighted that communication will be key to the success of the statutory Code of Practice, highlighting the importance of consumer engagement and education.

Some felt that the Code of Practice could help to establish a consistent approach to collections across Scotland, which will reduce confusion and secure greater buy in among households. However, this view was not unanimous; some were concerned that the Code of Practice may present a ‘one-size fits all’ approach, which they felt would be unsuitable and unlikely to deliver improvements in some areas.

“Waste and recycling services are currently designed by local authorities, who are directly accountable to residents of their area. This has led to continued diversity in service provision, reflecting the needs and choices of each area. Mandatory compliance would remove the scope for councils to operate collection services that meet local needs, transferring more control of how services are provided by central government while applying greater accountability on councils.” – West Lothian Council

A few organisations raised concerns about the quality of recyclate entering the waste stream and suggested that source-separated recycling collection systems should be mandated in the Code of Practice to reduce the risk of contamination.

As with other actions, some respondents stressed that any statutory measures must be adequately resourced, advising that additional requirements stemming from new obligations must be costed and local authorities appropriately remunerated for any additional costs.

“Any statutory Code of Practice must be fully funded, with additional, ring-fenced revenue support for remote island local authorities essential. This support must cover revenue shortfalls, as the value of product collected, regardless of how good the quality might be, is unlikely to cover collection, storage, haulage and gate fee charges.” – Comhairle nan Eilean Siar

One anonymous organisation said that they would welcome the introduction of an equivalent statutory Code of Practice for commercial recycling.

Introduce statutory recycling and reuse local performance targets for household waste services.

There were mixed views on the introduction of statutory recycling and reuse performance targets. Some respondents recognised the success the Welsh Government has achieved in utilising statutory recycling targets to drive improvements in local recycling rates and suggested that lessons can be learned from the Welsh approach.

“Evidence from Wales shows that effective policy levers, such as statutory targets, and implementation of residual restrictions, separate collections, and enforcement are successful at reducing costs, carbon emissions and waste.” – Waste and Resources Action Programme (WRAP)

However, a few local authorities opposed the introduction of statutory performance targets, raising various concerns including: a lack of clarity on how new targets will be set and assessed; concern about the additional obligations on councils; and other significant legislative changes being introduced over the next few years such as DRS, EPR and changes to the WEEE Regulations.

A few organisations supported the introduction of statutory recycling targets but opposed reuse targets, reiterating concerns made under the proposed further action to ‘Review the feasibility of setting reuse targets’ under the ‘Reduce and reuse’ strategic aim.

The need for a nuanced, flexible approach to setting local recycling and reuse targets was raised, with respondents emphasising the need to consider regional and geographic variations. The following were flagged as important by at least one respondent:

• quality and extent of local recycling service provision
• the nature of the housing stock, including consideration of the percentage of multi-occupancy properties
• urban/rural differences in garden access and size, and the impact this has on garden waste rates
• population density
• the demographics of the local population

A few added that local recycling and reuse performance targets should consider the challenges that remote, rural and island communities face, for instance a lack of recycling infrastructure and limited opportunities for reuse. Others discussed the need to set realistic targets which do not result in undue burdens and penalties for local authorities.

Some noted that, for best results, local authorities will require support with service planning, implementation and citizen engagement. Others reiterated the need for adequate financial resources to underpin the measures.

“As new statutory targets will necessitate legislative changes and impose additional legal burdens on councils, full funding from the Scottish Government is essential to enable compliance with any new duties.” – LARAC

Some comments focused on the timescale for this action, with a few agreeing that the 2030 timeframe proposed is sensible given the need for further research and the range of policy and legislative changes which are ongoing in parallel. However, some organisations, including RMAS and SUEZ Recycling and Recovery UK Limited, expressed disappointment at the long-term timeframe proposed.

A few organisations in the retail and packaging sector proposed having separate targets for ‘dry recycling’ (e.g. packaging and other similar materials) and organics (food waste and green garden waste).

While supportive of this further action, Trivium Packaging opposed setting recycled content targets for metal packaging, discussing differences between the outcomes of metal recycling versus plastic recycling.

“On no account should recycled content targets be set for metal packaging… Metal recycles forever and a huge and dependable recycling economy and infrastructure already exists to the benefit of carbon reduction. Recycling metal saves the carbon of initial manufacture regardless of whether or not there is recycled content in packaging…This is unlike plastics, where the inclusion of recycled content is intended to provide an outlet for end-of-life plastic that would otherwise go to landfill, incineration or the environment and where a plastic packaging tax has been used in an attempt to create a viable market for recycled material.” – Trivium Packaging

Strengthen Householder’s duty of care in relation to waste.

This further action was met with a mixed response; some respondents supported the proposal to strengthen householder’s duty of care in relation to waste, welcoming the introduction of new measures which disincentivise waste crime. Fife Council expressed particular support for measures which promote responsible use of third parties to dispose of waste by householders, noting that citizens may not be aware they are still liable for waste they have disposed of in this way. However, organisations from a mix of sectors caveated their support with calls for additional resource to improve capacity for enforcement procedures.

“Highland Council Officers support the proposal to strengthen Householder’s duty of care in relation to household waste. However, the ability to make effective use of these new powers will only be possible through the provision of additional resource at a local government level in order to undertake the investigations and administration processes to identify and enforce potential breaches of this duty.” – The Highland Council

Some disagreed with introducing measures which focus on penalising households, raising concerns about the impact on vulnerable people and the additional administrative burden placed on local councils. A few questions were raised about the enforcement of the strengthened duty of care, including queries about how those using communal bins would be subject to enforcement action and the consequences of not paying fines.

Give local authorities more tools to support household recycling and reduce contamination.

As with the previous further action, this proposal received a mixed response. Some respondents were supportive of this further action, reflecting on the significant costs attached to addressing contamination in recycling and agreeing that this could have a positive impact on recycling buy-in and quality.

“We do welcome this. Failure to use services correctly has consequences, not only for the local authority and the environment but also for other citizens who have to pay for the financial costs associated with this.” – City of Edinburgh Council

However, others disagreed with imposing punitive measures on non-compliant households, describing stricter enforcement as potentially “unfair” due to the lack of clarity among householders about recycling procedures. Specific concerns were raised about the impact of the measures on vulnerable people, including those with disabilities or mental health issues. A few expressed concerns about financially penalising those who may struggle to adhere to the correct recycling procedures due to physical or mental health conditions and suggested that exemptions will need to be applied in some cases.

A few respondents argued that greater impact could be achieved through enhanced producer responsibility and improvements in recycling service provision.

“We would caution against imposing stricter rules and enforcement on households. As our research has demonstrated (Holmes et al., 2023), not only is this likely to be highly costly for local authorities but runs the risk of further ‘turning off’ households from engaging with and appreciating the benefits of recycling. As we advocate the most important thing to improve recycling rates is to make things easier for households in the first place. Much of this must start higher up along the supply chain (product design) and filter through to straightforward waste regimes.” – 'One Bin to Rule Them All' Team, University of Manchester

Undertake a review of waste and recycling service charging.

Most respondents who commented on this further action welcomed a review of waste and recycling service charging. Aberdeenshire Council argued that this further action should be upgraded to a priority action, noting that the outcome of the review would be fundamental to local authority services and will potentially affect the statutory Code of Practice.

A few warned that the removal of waste charges in areas where these are currently in place would have a significant impact on income for local authorities and additional funding would be required to address the funding gap which would be created.

A few respondents supported a move to a Direct Variable Charging^[5] model, considering this a progressive step towards enhancing recycling quality and incentivising waste reduction. United Kingdom Without Incineration Network (UKWIN) echoed this, noting that the case study examples of this published alongside the consultation show this to be a fairer and more circular approach. However, a few individuals opposed charges for such services, suggesting that this may lead to increased instances of waste crime and that costs should be borne by producers.

Dundee City Council requested more information on the requirement to collect garden waste separately, and whether the Controlled Waste Regulations will be amended to remove the right to charge for this.

Review the monitoring and reporting framework for local authority waste services.

Few respondents commented directly on this further action; those that did were supportive of a review of the monitoring and reporting framework for local authority waste services. A few felt that improvements in data collection, collation and analysis processes will be critical in monitoring progress towards a circular economy. LARAC urged the adoption of user-friendly systems and called for funding for local authority data officers to streamline administrative processes. Aberdeen City Council advised that consideration should be given to streamlined, meaningful reporting, and avoiding duplication and unnecessarily increasing the burden on local authorities.

Develop options and consult on the introduction of end destination public reporting of household recycling collected.

Most comments on this further action were supportive, with respondents reflecting on the benefits of public reporting on household waste end destinations. These included: increased transparency in the waste management processes; greater public trust in services; and increased understanding and awareness of waste treatment processes. Some respondents agreed that this may lead to increased household recycling rates, with a few pointing to findings from research conducted by INCPEN, which suggests that a lack of information on what happens to recycling is the top reason that negatively influences citizens participation in recycling. The need for greater transparency was emphasised by a few individuals.

“People need to understand what happens to their recycling when they dispose of it, there is not enough transparency on how the waste is treated/re-processed. People think they are wasting their time and cannot see what value their waste has e.g. a large proportion of the population are likely to understand the value in an aluminium can or a glass bottle but less likely to understand how their food waste could generate energy or plastic film could be made into a construction board.” – Individual

United Kingdom Without Incineration Network (UKWIN) questioned the proposed timeframe of this action, suggesting it could be accelerated. They also advised that end reporting should be extended beyond household waste to include commercial waste.

Moray Council advised that public information about household waste end destination is already available via the waste data flow tool, and cautioned that this further action could result in a duplication of efforts. Glasgow City Council noted that local authorities already endeavour to obtain information to comply with the duty of care requirements, and advised that more emphasis should be placed on the waste treatment supply chain to provide all relevant information to assist local authorities meet these requirements.

While supportive of the ambition to increase transparency within the waste management system, The Highland Council felt that this responsibility should not lie with local authorities but should instead fall to treatment providers and to the regulator, who hold and record this information as part of their existing legal duties. West Lothian Council echoed this, noting that placing the primary responsibility on councils will create additional cost and sub-optimal outcomes which could be avoided by placing a parallel duty on all stages in the reprocessing chain.

3.2.2 Further actions under Section 2: Commercial recycling

Conduct a national compositional study of waste from commercial premises.

There was broad support for this action, with a few respondents recognising the value of a national compositional study of commercial waste in addressing gaps in data and subsequently enhancing service provision and increasing compliance with requirements.

“HIE backs the need for a national compositional study of waste for commercial premises, as there is currently no detailed national data to refer to. By improving the quality of data available it will be possible to identify priority materials and the sectors requiring further interventions.” - Highlands and Islands Enterprise

A few welcomed the commitment to an ongoing programme of commercial waste analysis, noting that this will help to evaluate the impacts of upcoming policy interventions affecting the waste management system. A small number advised that the compositional study sample should include a wide range of business types, ensuring variety in size, location and sector.

“The compositional study should also, if possible, consider a range of different business types to identify composition based on business type as each business will have different waste/recycling/reuse streams based on what their primary function is e.g. office, retail, construction, etc.” – Aberdeenshire Council

A few local authorities said that they will struggle to support the delivery of a compositional study of commercial waste due to budget and capacity constraints. Some felt that a compositional analysis of commercial waste will be a difficult undertaking given the wide range of business waste streams.

Aberdeenshire Council argued that this further action should be upgraded to a priority action, noting that findings from the compositional study could feed into the co-design of commercial recycling services.

Investigate further steps to promote business-business reuse platforms.

Most respondents who commented on this further action welcomed exploration of measures to encourage business-to-business reuse platforms.

“We strongly agree with the proposed further action to investigate further steps to promote business-business reuse platforms by 2027. The Scottish Government has an essential role to play in bringing businesses together and helping create ecosystems for the reuse system, overseeing the platform and its operations.” – Institute of Chartered Accountants in England and Wales

Scottish Water noted a desire to see a database of Scottish business assets and waste that can be used by other businesses to create products and facilitate the reuse of waste streams. RMAS shared examples of existing business-to-business reuse platforms including WARP IT, an office furniture and equipment resource distribution network. It was noted that public and commercial awareness are critical to the success of such sites, and support to publicise them would be beneficial.

As with previous actions relating to reuse, a few organisations felt that the responsibility of driving such initiatives should lie with producers rather than local or national government.

One anonymous organisation highlighted the limitations of reuse platforms for paper and cardboard-based products and packaging, noting that recycling such materials can have advantages over reuse in terms of usability and sustainability.

While supportive of actions aimed at helping businesses to adopt circular business models, Scottish Enterprise found this particular further action “confusing and difficult to understand.” They felt that this section of the Route Map simply describes ways in which businesses can innovate and does not relate to creating a business-to-business reuse platform.