Circular economy and waste route map to 2030: Fairer Scotland duty - summary assessment

Fairer Scotland Duty Summary

Scotland’s Circular Economy and Waste Route Map to 2030

Policy Aim

1. The Scottish Government is committed to moving towards a circular economy and playing its part to tackle the climate emergency. A circular economy, based on sustainable consumption and production, is essential to power Scotland’s transition to a fair, green and sustainable economy, and critical to meeting our obligations to tackle the twin climate and nature emergencies. Material consumption and waste are primary drivers of nearly every environmental problem Scotland currently faces, from water scarcity to habitat and species loss.

2. Founded on evidence and collaboration, the Circular Economy and Waste Route Map (CEWRM) is part of the Scottish Government’s wider response to these challenges. It is designed to drive progress on three key fronts:

a. Setting the strategic direction and laying foundations for how we will deliver our system-wide, comprehensive vision for Scotland’s circular economy from now to 2030.

b. Setting out priority actions from now to 2030 to accelerate more sustainable use of our resources across the waste hierarchy.

c. Reducing emissions associated with resources and waste.

3. In 2022, the Scottish Government set out a range of proposals across the resources and waste system through its first CEWRM consultation.^[1] The consultation sought views on the feasibility and ambition of these proposals to drive progress against 2025 waste and recycling targets, and to achieve the long-term goal of net zero by 2045. In April 2023, the analysis of responses to this consultation was published.^[2]

4. The second and final public consultation,^[3] which ran from 18 January to 15 March 2024, requested feedback on a revised draft CEWRM. This sought to prioritise and focus on the key actions that will unlock progress across the waste hierarchy to 2030 - along with questions on the accompanying suite of impact assessments. The consultation set out further information on specific proposals, noting that each intervention will be fully defined as the measures are developed.

5. In August 2024, the analysis of responses to the second consultation was published.^[4] This impact assessment builds on the findings from this analysis, and reflects the final CEWRM published in December 2024.^[5]

6. The consultation contained 24 questions about the proposals, comprising eight closed and 16 open questions. In total, there were 156 responses to the consultation from individuals (43) and organisations (113).

7. Across the consultation most respondents agreed or strongly agreed with each strategic aim, and respondents provided constructive feedback on the proposals and associated impact assessments. There were consistently high levels of support across the CEWRM’s four strategic aims:⁶

• 77% agreed with the Reduce and Reuse priority actions. 71% agreed with its further actions.
• 76% agreed with both the priority and further actions within Modernise Recycling.
• 78% agreed with both the priority and further actions within Decarbonise Disposal.
• 76% agreed with the Strengthen the Circular Economy priority actions. 81% agreed with its further actions.

Strategic aims and associated interventions within the CEWRM

8. The CEWRM includes a range of additional legislative and non-legislative measures that can contribute positively to the delivery of our circular economy and resource objectives and make progress towards net zero goals. Actions have been grouped into four strategic aims, which span action across the waste hierarchy. These are:

A. Reduce and reuse

B. Modernise recycling

C. Decarbonise disposal

D. Strengthen the circular economy

9. To ensure the right structures and support are in place to enable action across the circular economy these strategic aims incorporate a number of specific interventions. Full details of these can be found in Appendix 1.

Interaction with other policies (draft or existing):

10. The Circular Economy (Scotland) Act 2024 contains provisions to underpin Scotland’s transition to a circular economy and modernise Scotland’s waste and recycling services. The Act will require Scottish Ministers to publish a strategy for a circular economy every 5 years as well as create new circular economy targets. Additional provisions include:

• Restricting the disposal of unsold goods.
• Providing local authorities and Scottish Ministers with new powers and responsibilities for collection of household waste, including allowing Scottish ministers to set recycling targets.
• More enforcement powers to tackle issues such as fly-tipping.
• Improvement of waste monitoring.
• Powers to introduce charges for single-use items.

11. The Climate Change (Scotland) Act 2009,^[6] amended in 2019 through The Climate Change (Emissions Reduction Targets) (Scotland) Act. This Act sets out Scotland’s commitment on tackling climate change, with actions laid out in the various Climate Change Plans. The most recent update to the Climate Change Plan, Securing a green recovery on a path to net zero: climate change plan 2018 -2032 update (2020), lays out both the progress of the circular economy and waste sector in reducing its greenhouse gas emissions, but also ongoing issues and the remaining challenges ahead to meet the sector’s target of 0.9MtCO₂e by 2025, and 0.7MtCO₂e by 2030. The CEWRM strategic aims and priority interventions all support progress towards meeting those targets.

12. Scotland's National Strategy for Economic Transformation (NSET).^[7] The NSET sets out the priorities for Scotland’s economy as well as the actions needed to maximise the opportunities to 2032 to achieve the vision of a wellbeing economy. Its vision for a Wellbeing Economy: Thriving across economic, social and environmental dimensions is supported by three ambitions, including ‘Greener: Demonstrating global leadership in delivering a just transition to a net zero, nature-positive economy, and rebuilding natural capital’. A number of interventions across the CEWRM may support the NSET.

13. Just Transition – A Fairer, Greener Scotland: Scottish Government response.^[8] Scottish Government’s strategic approach to just transition is aimed at supporting the development of the NSET. The NSET will be supported by specific Just Transition Plans for reinvigorating Scottish manufacturing and industry, supporting Scottish supply chains and creating high-quality jobs. There are a number of interventions within the CEWRM that will also need to align with Just Transition principles.

14. Building just transition into our economic strategy in this way provides a unique opportunity to work with all parts of our economy to deliver a fairer, greener Scotland. Through this work, a number of sector focussed Just Transition plans are expected over the next few years.

15. The Good Food Nation Act.^[9] In 2024 the Scottish Government published the national Good Food Nation Plan (GFNP)^[10] which states “In our Good Food Nation, the people of Scotland can access and enjoy locally produced food that keeps them happy and healthy. Our food industry continues to thrive and grow. The environment is protected, biodiversity loss reversed, and our net zero ambitions achieved. A Good Food Nation enables flourishing rural and coastal communities”. Reducing food waste through redistribution and making the food system more resilient through the measures in the CEWRM will support both the Act and the GFNP by improving access to affordable food and helping to realise the food waste reduction and environmentally friendly disposal ambitions in the Act.

16. Scotland’s Biodiversity Strategy to 2045: tackling the nature emergency^[11] recognises the need to ensure the range of actions we are undertaking are both complementary and coordinated as part of our overall efforts to tackle the twin crises of climate change and biodiversity loss.

17. The Scottish Material Flow Accounts (MFA)^[12] show that the estimated material footprint (Raw Material Consumption) is 19.3 tonnes per capita, significantly higher than the amount experts suggest is sustainable (8 tonnes per person per year). The MFA will continue to form part of the evidence and monitoring functions used to measure progress of the CEWRM interventions.

18. The 2022 Circularity Gap Report for Scotland^[13] found that only 1.3% of the resources used in Scotland are cycled back into the economy, with over 98% of Scotland’s material use coming from virgin resources. Measures laid out in the CEWRM for future action should help to increase resources cycled back into the economy, reducing the need for virgin materials.

19. There are a number of extended producer responsibility (EPR) schemes in place with several reforms underway. These are:

• Packaging Producer Responsibility Scheme^[14]
  • The Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024^[15]
• Waste Electrical and Electronics Producer Responsibility Scheme^[16]
  • Consultation on reforming the producer responsibility system for waste electrical and electronic equipment^[17]
• Batteries and Accumulators Producer Responsibility Scheme^[18]
• End of Life Vehicles^[19]
• Deposit Return Scheme regulation^[20]

20. Reforms to the existing EPR schemes will change how end of life products are managed, how local authorities may be funded to manage that waste and how reuse and repair are championed across the three schemes. For the CEWRM, changes to EPR schemes will be crucial to interventions such as changes to recycling collections and co-design of services.

The Fairer Scotland Duty 2018

21. The Fairer Scotland Duty (the Duty) places a legal responsibility on named public bodies in Scotland to actively consider how they can reduce inequalities of outcome caused by socio-economic disadvantage, when making strategic decisions.^[21]

22. Two interim Fairer Scotland Duty Assessments (FSDAs) were published as part of the Scottish Government’s consultations on the CEWRM.^[22] This document expands on those interim FSDAs with findings from the second public consultation.

23. The CEWRM is a strategic document designed to support planning to 2030 and beyond, however we recognise that not all policy measures are fully ready to be implemented in Scotland and are at different stages of development.

24. The CEWRM is focused on identifying strategic aims and associated interventions. The specific policy detail for each of these will not be fully defined at this stage. It is intended that the CEWRM will enable the Scottish Government to articulate a strategic approach which will contribute towards sustainable resource use and circular economy ambitions.

25. The publication of the CEWRM will not in itself result in impacts on those experiencing socio-economic disadvantage. However, there is potential, once the interventions are implemented, that they may have impacts. This Fairer Scotland Duty Assessment is therefore an overview identifying any broad potential impacts by strategic aim and not a detailed assessment of specific interventions.

26. Further, more detailed FSDAs will be carried out where appropriate when individual measures are designed and developed fully, including further engagement with stakeholders and evidence gathering as required. However, in order to offer additional insight, this document will assess each strategic aim broadly and highlight, where possible, likely impacts on socio-economic disadvantage and any key inequalities that may arise.

27. Two of the interventions in the CEWRM have already been progressed to date, with associated FSDAs as detailed below.

28. The four UK governments are introducing legislation to ban/prohibit the sale and supply of single-use vapes. While this has not been a direct result of the CEWRM, it does fulfil one of its interventions. The detailed FSDA for this policy identified that use was higher in lower socio-economic groups. Homeless groups were highlighted as less able to use reusable vapes and a wider impact was noted regarding the potential increase in the cost of vaping. Full details can be seen in the Prohibition of the sale and supply of single-use vapes: FSDA.^[23]

29. An interim FSDA has been published alongside the Charging for Single-Use Disposable Beverage Cups: Consultation.^[24] The accompanying interim FSDA did not identify any definitive impacts on those who experience socio-economic disadvantage. However, it identified potential issues for low-income groups that should be explored further – as well as the potential positive impacts on perceptions in local areas, such as a reduction in visible litter. Full details can be seen in the Single-Use Disposable Beverage Cups Charge: Fairer Scotland Duty Summary.^[25]

30. Alongside the first consultation on the CEWRM proposals, to accelerate progress in this area, we also consulted on provisions for a Circular Economy Bill to bring forward primary legislation to underpin our key policy measures. A Fairer Scotland Duty assessment was completed when the Circular Economy (Scotland) Bill was published.^[26] The Bill became an Act on 8 August 2024 and contains provisions that underpin Scotland’s transition to a circular economy and modernise Scotland’s waste and recycling services.^[27] The Act primarily delivers new powers that set a framework for taking action into the future. The direction and actions set out in this CEWRM are complemented by the provisions in the Act, and in some places are dependent on enabling powers created by the Act.

Summary of evidence

31. Initially evidence was gathered and collated that should be considered in the development of individual interventions which are likely to impact directly on people and their communities. That evidence was shared and commented on during an initial public consultation in 2022. This document was updated following the analysis of the first consultation responses and shared again as part of the second consultation in early 2024.

32. This document has been updated once more to include all relevant information gathered from the second consultation process. This document will be used during the development of individual CEWRM interventions, as a basis for the development of detailed Fairer Scotland Duty Assessments where they are required.

33. Respondents to the first consultation highlighted future policy development in other areas, such as investment in transport, infrastructure or community resources, as an opportunity to minimise potential increases to living costs as a result of any CEWRM interventions. The first consultation analysis highlighted that consideration is needed to identify and mitigate potential differences between the economic impacts of proposals in rural and urban communities.

34. In the second consultation the most common theme was concern regarding the socio-economic impacts of CEWRM proposals on low-income households – and the need to ensure that the proposals do not inadvertently adversely affect them when developed and delivered. This was noted regarding any potential future additional environmental charges or waste management costs.

35. Following the analysis of the second public consultation for the CEWRM, this FSDA has been updated to show how different socio-economic groups may be impacted differently to others in Scotland if implementing the interventions. A number of areas for consideration have been highlighted. These are:

• Potential economic benefits/disbenefits for those facing socio-economic challenges.
• Accessibility to affordable goods/services.
• Accessibility to high quality goods/services.
• Employment and skills.

36. All of the areas for consideration will impact on each strategic aim to a greater or lesser extent. The sections below incorporate the most relevant issues linked to the areas for consideration for each strategic aim. They also highlight specific interventions, deemed most likely to have relevance with regards to socio-economic inequalities, and set out early considerations for any subsequent impact assessment.

A. Reduce and Reuse

Responsible consumption, production and re-use

37. The introduction of some measures which would increase the access to affordable goods via secondary markets may have the benefit of normalising second-hand and reused goods. The socio-cultural complexities around using second-hand or reusable goods should be considered when developing relevant interventions. For example, quality, style and cleanliness of clothing all play a role in consumer choices;^[28] also perceived contamination has consequences for rental services and second-hand exchange.^[29] However, care would be needed to ensure that organisations supporting communities experiencing socio-economic disadvantage are able to benefit from any measures.

38. The consultation analysis highlighted that respondents believed it important that opportunities to access reused goods must be affordable and accessible for all, irrespective of socio-economic status. Improving the reuse experience for customers should include assessment of impacts across socio-economic groups and take into account finance and accessibility issues. This assessment can build on research undertaken via Revolve as the interventions are developed.^[30]

39. There are already examples of reuse projects targeted at improving life for those experiencing socio-economic disadvantage, for example through Circular Communities Scotland.^[31] The UK-wide Reuse Network, which works with members to reduce poverty, estimated that it helped 1.59 million households in the UK in 2023.^[32]

40. Available evidence identifies the existence of a ‘poverty premium’, where low-income consumers tend to overpay for goods and services. This can result in a lack of access to lower priced, better quality and more durable goods. This is noted especially for energy, communications and insurance, but also for food.^[33]

41. Within Scotland, 9% of households reportedly do not manage well on their incomes, with the proportion being higher for those on benefits (including the state pension). Levels of perceived financial difficulty were also higher in more deprived areas, as measured by the Scottish Index of Multiple Deprivation, with 17% of households not managing well in the most deprived decile.^[34] There are also connections to protected characteristics, with higher poverty rates for some groups.^[35]

42. Those living in remote rural areas of Scotland also experience higher costs to achieve the same standard of living when compared to those in urban areas.^[36] This may mean that those on an equivalent income in a remote rural area may be more likely to face financial difficulty.

43. Those on lower incomes often have to purchase lower cost products, that are potentially less durable. This may mean that low-income households face budget pressures if they are unable to avoid environmental charges (for example, by purchasing a reusable coffee cup) or if retailers respond to the introduction of restrictions on the disposal of unsold consumer goods and/or the promotion of business models that prolong product lifespans by moving away from stocking budget or basic products. Restrictions on the disposal of unsold consumer goods may also result in some new goods being available at reduced prices, potentially though charities or retailers. In addition, in a circular economy buying refurbished or second-hand items should be more accessible and could increase the availability of these items and the acceptability of them as an alternative to buying new.

44. Whether these issues occur will depend on the design of individual interventions and should be considered further during their development. In consultation responses it was suggested that measures may be needed to support households purchasing long-lasting goods that will be more cost effective in the longer term but are initially unaffordable. As such, interventions relating to sustainable consumption, prolonging product lifespan and behavioural change need to consider and assess their applicability to all socio-demographic audiences and how to overcome specific challenges and/or barriers – such as accessibility.

45. Further detailed FSDAs taking into account socio-economic considerations have already been undertaken with respect to single-use vapes and single-use disposable cups interventions. The latter can be built upon in any future assessment of other problematic products that may lend themselves to the use of environmental charges.

Food Waste

46. Food waste reduction measures must consider wider policy objectives that aim to reduce food insecurity, which is driven by insufficient and insecure household income. This includes aligning with the Scottish Government’s Cash-First: Towards ending the need for Food Banks in Scotland Plan,^[37] which outlines the actions being taken to improve the response to crisis by using a cash-first approach so that fewer people need to turn to food parcels and food banks. Actions in the Plan include providing up to £315,000 to FareShare in 2024/25 to redistribute high quality surplus food to community organisations with an emphasis on shared meals and wrap around support. These organisations often have an emphasis on community development and access to wider services, such as money advice, and therefore play an important role in mitigating the impacts of the cost of living crisis. This work has supported resilience at a local level through dignified provision of food to those in crisis. Therefore measures to help tackle food waste help support wider policy objectives and deliver greater benefits.

47. Responses to the first consultation suggested there may be opportunities to explore alternative ways to coordinate food redistribution and consumption rather than just to individual households. While no specific examples were highlighted there is an opportunity, as policies or interventions are further developed, for alternatives methods to be explored in more detail in future. The second consultation analysis included a request for caution in developing some interventions so that that the proposals do not inadvertently result in an unfair impact on those relying on surplus food.

Construction

48. Interventions set out in the CEWRM regarding construction waste include measures to develop a model for regional reuse hubs for construction materials and assets. The establishment of reuse hubs has the potential to influence market prices for materials used in the construction sector. These economic impacts may be uneven and could impact on households or socio-economic groups differently.

49. The specific design and location of these hubs have potential to disadvantage some people (e.g. harder to access potentially cheaper materials) – while offering benefits to others (e.g. employment opportunities, access to potentially cheaper materials). These impacts will require assessment during feasibility research, and any future design and implementation phases.

B. Modernise Recycling

Household recycling

50. Local authority recycling rates are variable across Scotland, and are influenced by geography, housing type, levels of deprivation as well as service design, waste awareness and prevention activity and investment in infrastructure. In particular, 2023 data indicated that the percentage of household waste recycled was below 35% in three council areas: Glasgow City, Orkney and Shetland – and over 55% in four local authorities: East Renfrewshire, North Ayrshire, Moray and Scottish Borders.^[38]

51. Households living in flats, maisonettes or apartments are reported as having a lower rate of recycling for all materials, with the difference most marked for glass, based on 2017 data. Recycling rates also show correlation with the Scottish Index of Multiple Deprivation, with recycling rates for all materials being below average in the 20% most deprived areas, and above average in less deprived areas, based on 2017 data.^[39] The data does not show whether recycling rates vary by household income.

52. It is not yet possible to determine if these differences would mean that those experiencing socio-economic disadvantage are affected by changes to household recycling differently from those who are not disadvantaged, either in terms of the materials collected or the way that services are delivered or funded (e.g. garden waste collections). However, co-design of household services is specifically intended to implement high-performing systems that take account of geography and socio-demographics to best serve householders while maximising capture and quality of material.

53. It will be important that interventions focused on making changes to household recycling services are designed to ensure all communities have equitable access to recycling. Interventions include a recycling co-design project with input from households, local government and other stakeholders, statutory guidance on recycling service standards, local performance targets and new powers for local authorities to support household recycling and reduce contamination. As some of these measures are designed and developed additional FSDA assessments will be required.

54. All of the groups with high poverty levels have the potential to be particularly impacted positively or adversely if the charges related to household waste services change as a result of the review of waste and recycling service charging, or for example if they receive a Fixed Penalty Notice under enhanced duty of care provisions. These issues could be amplified as a result of any new requirements for high performing household recycling and reuse services and local performance targets. There is potential for changes to make recycling services simpler and improve engagement with householders. It is not yet possible to assess the likelihood or extent of any impact on those experiencing socio-economic disadvantage, as this would depend on how interventions are designed - and if powers are required and implemented at the secondary legislation stage.

55. The priority intervention to revise household recycling services is being driven via a co-design process. This will ensure socio-economic considerations and impacts are considered as the first intervention is developed – this will also provide information and context to assist in the development of subsequent interventions within this objective.

56. Care will be needed to ensure that any changes to the way in which household waste collections (for example, garden waste) are charged for or incentivised and therefore do not have an adverse impact on those experiencing socio-economic disadvantage and take account of any stigma around means testing in cost reduction for low-income groups.

57. For example, low-income households may currently qualify for reduced, or at no cost, household waste collections for chargeable waste streams. When developing any intervention changes in the way household collections are paid for or incentivised, the potential impacts on those experiencing socio-economic disadvantage must be considered. Any review of waste service charging should involve an assessment of any negative or positive socio-economic impacts and there is potential to build on, and borrow from, existing assessments undertaken in relation to the Circular Economy (Scotland) Act 2024. While this review would not itself require legislation, the outcome of the intervention may see changes to charges, or new charges added for other materials. These potential future changes would necessitate new legislation and a future Fairer Scotland Duty Assessment.

58. As individual interventions are designed, it will be important that changes to household recycling services are designed to ensure that they are appropriate and accessible for households regardless of geographical location, housing type or the level of deprivation of a community. For example, this will be particularly critical if the duty of care on households to recycle is strengthened, or additional measures to incentivise positive behaviours (e.g. waste reduction or increased recycling) are identified. The co-design process is a key enabler to involve households and communities in the design of future services.

59. Respondents to the second consultation highlighted the need to be aware of potential socio-economic impact of some proposals on remote, rural and island communities - given the additional costs and challenges relating to circularity and waste disposal in these areas.

C. Decarbonise Disposal

60. Given the nature of interventions within this strategic aim it is unlikely that any will have a significant impact on different socio-economic groups or cause inequalities. No significant concerns regarding these measures were raised during the consultation responses in relation to the draft FSDA impact assessments. It is possible that the Residual Waste Plan and actions regarding energy from waste may indirectly impact collection services in specific localities but would be factored into the co-design process and resulting statutory guidance.

61. In general, landfills tend to be located in areas of higher social deprivation. Actions to move waste away from landfill could, therefore, reduce impacts from the management of residual waste on these communities. However, it is essential that any impacts on the environment and local communities continue to be mitigated and monitored post-closure of landfills. The development and delivery of the Residual Waste Plan may support considerations for how landfill operators can ensure they remain compliant with their permit conditions and minimise these impacts.

62. Currently, the distribution of incineration facilities does not show the same trend as landfills, in regard to the social deprivation of the area.^[40]

63. In addition, we know that, due to locations, typically rural and island communities need to move waste further to manage their waste due to the location of residual waste treatment infrastructure. This can lead to limited options for the management of waste and potentially higher costs of managing waste as a result. The Residual Waste Plan could highlight opportunities and consider alternative treatment technologies to support residual waste treatment where lower tonnages of waste are generated.

64. The independent review of incineration noted that it received evidence that the standard of community engagement by both public and private entities varied greatly and it is clear that the general level should be improved.^[41] The Scottish Government accepted its recommendation to facilitate the co-production of guidance on community engagement. This could help ensure that all communities are engaged to the high-standards the deserve.

D. Strengthening the Circular Economy

Green Skills, Training and development

65. Developments in the green economy have the potential to have an impact on socio-demographic disadvantage. The introduction of some interventions to provide training and skills development as well as job opportunities is an opportunity to address this issue. This may impact positively those in precarious or low-paid jobs with demand for more high-skilled local labour.

66. Similarly there are opportunities for upskilling and training for those with limited or no qualifications to take advantage of opportunities of work in green sectors, including circular economy roles, which could specifically be targeted for support.^[42] When the relevant interventions are developed, there is a need to consider re-skilling to access new jobs and access of disadvantaged groups to opportunities. The Circular Economy (Scotland) Act 2024 requires that the circular economy strategy must have regard to public education and skills.

Procurement

67. There are also opportunities for circular procurement practices to have positive impacts on communities. Creating market conditions that promote the growth of sustainable local businesses may result in these businesses offering a route to affordable, potentially refurbished high quality, products to low-income households.

Research

68. Strengthening the circular economy requires greater understanding of waste prevention, behaviour change, fiscal incentives and material-specific priorities that may in turn lead to benefits or disbenefits for certain socio-demographic groups. Developing a programme of research will necessarily involve assessments of inequalities and economic barriers.

Summary of assessment findings

69. On present evidence, we do not believe that the publication of the CEWRM itself will directly impact on those experiencing socio-economic disadvantage.

70. However, it is likely that a significant number of the individual measures may have a range of both negative and positive impacts across socio-economic groups.

71. It is recommended that as individual interventions and their actions are being developed, they are subject to the impact assessment process ranging from screening to full assessments as required.

72. It is recommended that stakeholder engagement with relevant representative groups and those with lived experience is undertaken as measures are developed.

73. It is recommended that findings and evidence gathered from this and other related FSDAs are maintained and updated as necessary to support future related CEWRM action impact assessments - as per single-use vapes and cups interventions outlined earlier.

74. It is recommended that where appropriate, CEWRM related research should ensure evidence is gathered of potential impacts to different socio-economic groups.

75. The Scottish Government will consider an appropriate and proportionate monitoring approach to the CEWRM outputs. This will include the overarching circular economy monitoring and indicator framework that the Scottish Government is developing, alongside monitoring approaches developed for each individual intervention where appropriate.

76. Progress of the CEWRM will also be tracked by the relevant Scottish Government Programme Board to ensure measures are being implemented in line with the timeframes provided in the CEWRM.

FSDA completed by (name) : Jon Havens

Position: Team Leader, Circular Economy Strategy Team

Signature and date: Jon Havens 13/01/2025 (electronic signature)

FSDA authorised by (we recommend DD level): David McPhee

Position: Deputy Director, Circular Economy Division

Signature and date: David McPhee 13/01/2025 (electronic signature)