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

5. Strengthen the circular economy

This chapter presents analysis of responses to Questions 7 and 8, which explored views on the priority and further actions identified under the Strengthen the circular economy strategic aim.

5.1 Strengthen the circular economy: priority actions

Q7: To what extent do you agree with the priority actions proposed within the Strengthen the circular economy strategic aim? Please provide evidence to support your answer if possible.

Three quarters (76%) of those who answered Q7 agreed to some extent with the priority actions in the Strengthen the circular economy strategic aim; 39% strongly agreed and 38% agreed. A further 9% were neutral and 14% disagreed.

Among individuals who answered, two thirds (66%) agreed to some extent, including half (51%) who agreed strongly. Overall, 81% of organisations agreed, with at least 80% of all sectors agreeing to some extent with the exception of third sector organisations (63%). However, 32% agreed strongly with the priority actions; this was the highest level of strong agreement recorded across the four strategic aims. Strong agreement was particularly high among retail and packaging organisations (53%), public bodies (50%) as well as among third sector organisations (38%). Disagreement among organisations was limited to third sector organisations, of which one third (32%) disagreed.

There were 105 open text comments submitted under Q7. While the overall ambitions of this strategic aim were broadly welcomed, some respondents felt the priority actions lacked detail, specificity and ambition. For example, they were described as “weak”, “vague”, “ambiguous”, “high-level” and “lacking substance”, and there were calls for more detail, specificity or commitments to direct action. For example, the 'One Bin to Rule Them All' Team at the University of Manchester felt this section requires more specific objectives and suggested that alignment with the EU’s circular economy action plan would be beneficial.

As with other sections, a few respondents urged greater consideration of the costs associated with the actions set out. 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.

A few raised general concerns that overall, the Route Map is too narrow in scope and focuses too closely on environmental measures, without addressing the wider economic drivers and levers necessary to deliver a circular economy.

Develop a Circular Economy strategy every five years.

Most comments on this priority action were supportive, with respondents from a mix of sectors welcoming the introduction of a requirement for Scottish Ministers to publish or refresh a circular economy strategy every 5 years.

“We fully support the pragmatic approach of reviewing the CE strategy every five years and welcome the opportunity to review success and help support any gaps in reaching targets.” – McDonalds UK and Ireland

Some organisations felt that a national strategy will give a clear indication of priority sectors and help key stakeholders to better understand the strategic direction of travel within a circular economy context. A few others, including Waste and Resources Action Programme (WRAP) added that publishing a five-year Circular Economy strategy will help Scotland to react and adapt to rapidly changing environmental issues and regulatory landscapes.

“We agree that the development of a Circular Economy Strategy at national level will help provide clarity over the direction of travel and priority sectors. A cross-cutting approach will also strengthen systems thinking which is critical in achieving long-term and sustainable change. Revising the strategy every five years will ensure it remains current and takes into consideration any advancements towards targets.” – Glasgow City Council

There were calls for extensive stakeholder engagement to inform the development of the strategy, including input from local government, the waste management sector, communities and businesses from various sectors.

A few emphasised the importance of public education and awareness about the circular economy and called for this to be a priority area with the Circular Economy strategy. Others called for the strategy to recognise the role of anaerobic digestion as a circular waste management option that can contribute to Scotland's circular economy and net zero goals. A few respondents from the third sector called for both carbon and material consumption reduction targets for Scotland to be included in the strategy.

While some recognised the need for a Circular Economy strategy, 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 publishing a strategy document. Others, including Common Weal, made similar points, noting that it is important that the renewal of the strategy does not become a distraction to implementing the aims and objectives within it.

“Clear and effective actions with no strategy document will make change: a strategy document without the required actions will not.” – Action to Protect Rural Scotland

“It may be better to concentrate on actually achieving the targets set out in any strategy rather than create a new strategy altogether.” – Stirling Council

On timings, Stirling Council questioned the feasibility of publishing a strategy every five years, and The Royal Town Planning Institute Scotland, highlighting the vital role that planning can play in moving towards a circular economy, suggested that a 10-year period may promote better synchronicity with NPF4 and Local Development Plans. The Food and Drink Federation felt a longer term strategy would be best, suggesting a strategy to 2045 in line with the Scottish Government’s net zero commitments with a refresh every 5 years. They also highlighted overlap in the Scottish Government’s Climate Change Plan, Net Zero commitment and Circular Economy Route Map and proposed combining these into one overarching long-term strategy with KPIs and refreshes every 4-5 years. Two respondents suggested that annual updates to the Circular Economy Strategy should be published.

A few encouraged the development of strategies at a local and community level as well as national, and there were calls for greater discussion of how the Circular Economy will align with other national strategies.

“We agree with the priority action that a refreshed Circular Economy strategy should be developed every five years. However, the key issue is that the strategy aligns with other Scottish Government strategies (especially the National Strategy for Economic Transformation, Innovation Strategy, Environment Strategy and Climate Change Plan) so it genuinely becomes a whole of Government approach.” – Scottish Enterprise

Setting new circular economy targets beyond 2025.

There was broad support for this priority action, with some reflecting on how targets will help to drive action and consistently monitor progress. A few organisations supported the move away from weight-based metrics towards factors like carbon emissions, noting that this shift allows for a more comprehensive understanding of the actual costs associated with material use and disposal. Others welcomed the Route Map’s recognition of the need for a robust monitoring framework to be put in place to accompany any new targets.

The need for outcome-based targets which are realistic, flexible and achievable was discussed by a few respondents. Edinburgh Chamber of Commerce added that targets need to be clear, measurable and relatable for businesses and other stakeholders. As with the development of the circular economy strategy, there were calls for extensive stakeholder engagement to inform the creation of targets, the data required and the frequency of reporting.

“In Valpak’s experience targets have proven to be an effective instrument at the disposal of regulators in encouraging the environmentally sound management of particular resources at end-of-life. As such, we support the installation of circular economy targets and hope that any future targets are the result of industry engagement, including but not limited to formal consultation.” – Valpak

A few requested more detail on what the targets might look like, with one anonymous organisation withholding support for this priority action until the targets are defined, noting they would not support reuse targets for paper and board. LARAC highlighted the importance of extending the new circular economy targets to include producers and manufacturers.

Scottish Environment LINK described this priority action as urgent and requested clarity on the timeframe. They advised that the Scottish Government should set these targets as soon as possible or by 2025 at the latest.

A few suggested that terms such as ‘recycling’, ‘downcycling’, ‘waste’ and ‘re-use’ should be clearly defined to assist with the delivery and monitoring of outcomes. Comhairle nan Eilean Siar advised that the new circular economy targets must be aligned with Producer Responsibility so that any new financial burdens are included in funding steams such as EPR. With regard to the setting targets for the construction industry, the UKRI Interdisciplinary Circular Economy Centre for Mineral-Based Construction Materials advised that targets should not be limited to waste, but also include factors such as reuse, refurbishment, longevity of materials, decarbonisation, or protection of natural capital.

Suggestions for additional priority actions

A few respondents, including Ostrero, suggested including a priority action about promoting education, behaviour and mindset change. The Recycling Association recommended including a priority action aimed at developing circular product standards using end-of-waste criteria.

5.2 Strengthen the circular economy: further actions

Q8: To what extent do you agree with the further actions to 2030 listed across the Strengthen the circular economy strategic aim? Please provide evidence to support your answer if possible.

Over four fifths (81%) of those who answered Q8 agreed with the further actions to 2030 across the Strengthen the circular economy strategic aim. This was the highest level of total agreement recorded across the four strategic aims. Over one third (37%) strongly agreed, 44% agreed, 5% were neutral and 14% disagreed with the further actions.

Individuals held almost identical views of the further actions compared to the priority actions, with 66% agreeing to some extent and 49% agreeing strongly. Among organisations who answered, 89% agreed to some extent including 30% that strongly agreed. All local authorities, public bodies, waste management and construction and development organisations agreed with the proposals. While 86% of retail and packaging organisations agreed, over half (57%) of these organisations agreed strongly with the further actions; this was the highest level of strong agreement recorded by a sector across the four strategic aims. Although 73% of third sector organisations agreed with the further actions, one quarter (26%) expressed their disagreement.

Question 8 received 97 open text comments. Some respondents expressed broad support for the three cross-cutting themes identified under the Strengthen the circular economy strategic aim, agreeing that these are all necessary areas of focus in the transition to a circular economy.

“British Glass welcomes the further strategic actions up to 2030, which maximise impact of circular economy measures, tackle cross-cutting areas to support progress across the waste hierarchy, and contribute to robust monitoring and evaluation of progress. It’s sensible that these are centred across the three themes: research, data and evidence; sustainable procurement; and skills/training.” – British Glass

Review and refresh Scotland’s Waste Data Strategy’s action plan.

Few respondents commented on this further action specifically, but those who did were supportive, recognising the need for empirical data to underpin decision-making. The Recycling Association suggested that it could be beneficial to upgrade this to a priority action as the Waste Data Strategy action plan might help inform other aspects of the Route Map. The Scottish Ecological Design Association also considered the review of waste data capture a high priority, particularly for the construction sector.

The Association for Renewable Energy and Clean Technology expressed support for this further action, but emphasised the importance of making the action plan reasonable and actionable through collaboration with industry stakeholders.

Maintain a programme of research on waste prevention, behaviour change, fiscal incentives and material-specific priorities.

Most comments on this further action were supportive, with respondents welcoming the commitment to a continued programme of research in the identified areas. Circular Communities Scotland recommended that this action be upgraded to priority status.

A few suggested specific areas for future research, including: behavioural interventions to reduce contamination in organic waste recycling; international examples of best practice; and trials of innovative technologies, such as anaerobic digestion and hydrothermal carbonisation, to transform grass cuttings from waste into resources.

The Institute of Chartered Accountants in England and Wales recommended that the ‘Research, data and evidence’ cross-cutting theme should be expanded to include innovation in technologies that support transparency and traceability of supply chains, products and materials, as well as other aspect of the circular economy plan.

Develop public procurement opportunities to reduce the environmental impact of public spending.

There was particularly strong support for this further action, with respondents welcoming efforts to increase the sustainability and circularity of public procurement. A few respondents described this further action as key in supporting Scotland’s transition to a circular economy and others recognised the opportunity for public procurement to help achieve positive environmental, economic, and social outcomes.

“Mandating circular economy and climate obligations in procurement strategies for public bodies would help reuse choices become more mainstream within the public sector and help circular enterprises grow and expand.” – Circular Communities Scotland

Scottish Environment LINK suggested that this action should be upgraded to priority status, with additional focus on reforming public procurement so that it contributes to Scotland’s transition to a circular economy by, for example, using leasing models, refurbished equipment, and imposing take-back requirements on suppliers. Scottish Water suggested developing a public procurement approach in line with the Climate Change (Scotland) Act 2009.

One anonymous organisation requested the implementation of a bio-preferred procurement scheme where the use of bio-based feedstocks is incentivised over fossil-based incumbents. Aberdeenshire Council advised that consideration should be given to the requirements to purchase goods with recycled content or recycled products, noting that for certain industries, there is a need to ensure that goods with recycled content/recycled products meet the same standards as new products from a safety aspect.

Support greater uptake of green skills, training, and development opportunities.

There was broad support for this further action; it was described as ‘vital’, ‘essential’ and ‘very important’ by a few respondents. Several respondents reflected on the need to upskill the workforce and ensure that the education and skills systems are prepared to support an effective transition to a more circular economy.

“RMAS strongly agrees with all measures aimed at supporting training, education and development of skills within the sector and is a strong advocate for the opportunities within the industry. The current system and levels of financial support for education and training in the sector are limited and there need to be clear links at Government level to help deliver long-term change.” – Resource Management Association Scotland (RMAS)

Some called for circular economy education to be integrated into school curriculums to embed the principles of circularity within younger generations.

A few respondents reflected on the training and workforce development needs of specific industries, such as the construction, planning and agricultural sectors. For example, the Construction Industry Training Board (CITB) noted that in order to achieve a circular economy, the current construction workforce must become skilled in maximising reuse; designing for optimisation; using standardisation; and minimising impact and waste. They also reflected on some of the challenges impacting the construction education and skills system including: budget cuts; the withdrawal of key funding streams such as the Flexible Workforce Development Fund for the academic years 2023-2024 and 2024-2025; and limited capacity to plan effectively, due to on-going reforms.

A few called for more detail on how the Scottish Government intends to finance the proposed measures to support greater uptake of green skills, training, and development opportunities.