Circular economy strategy draft: consultation analysis

Executive Summary

Introduction

As required by the Circular Economy (Scotland) Act 2024, the Scottish Government developed a draft Circular Economy Strategy. This aims to provide a high-level framework for Scotland’s transition to a circular economy, and sets out the strategic direction to 2045, specifically looking at policy mechanisms, priority sectors, product stewardship, and setting out a monitoring and indicator framework. The draft strategy was subject to a public consultation between October 2025 and January 2026, where feedback was sought on the draft content.

The consultation asked 31 questions in total. This included 27 open questions (which invited free-text responses), and four closed questions (which required respondents to select a response from a list of options).

Overall, 190 responses were received via Citizen Space (the Scottish Government’s online consultation platform), by email and post, and were included in the analysis. Most of these responses were provided by organisations (78%, n=148), with 22% (n=42) provided by individuals.

In addition, 1,273 campaign responses were received. Of these, 92% (n=1,175) were identical in nature, while 8% (n=98) included edited, reduced or additional feedback. Campaign respondents did not answer any of the closed questions (i.e. which required respondents to select from a list of options).

Key Findings

Vision and Outcomes

Of those who answered the closed question at this section, most either agreed or strongly agreed (82%, n=139) with the vision and outcomes for the strategy. It should be noted, however, that while campaign respondents did not answer the closed question, most indicated as part of their qualitative comments that they disagreed with the vision and outcomes.

Across the open comments provided about the vision and outcomes, most respondents agreed with the vision and outcomes in principle, although several wanted these to be stronger, more ambitious, and to convey greater urgency.

Respondents welcomed the explicit link in the vision between net zero, nature positive goals, and circular economy principles. The inclusion of social goals and benefits, as well as environmental and economic ones, was also supported, as were the links to the wider policy landscape. The acknowledgement of the impact that Scotland’s consumption has on global communities was also supported, although this was one area flagged as lacking ambition or not adequately reflecting the impacts.

One of the main points raised in this section was the need for more detail on how the vision and outcomes would be delivered. There were calls for information on specific actions, measurable targets, regulatory changes, funding/investment, incentives and disincentives, timeline for delivery and interim milestones, progress monitoring, and accountability mechanisms and penalties.

Respondents also highlighted additional topics for inclusion. This included a range of materials/products/sectors; tackling overconsumption; to explicitly embed the waste hierarchy and focus on reuse, repair, and repurposing; more explicit recognition of regional diversity and rural and island issues, as well as the voluntary and third sector; education, skills and workforce development. Respondents also suggested that certain terminology could be open to different interpretation and needed to be stronger, tighter, and better defined.

Campaign respondents wanted the vision and outcomes to be refocused. To reduce consumption, to put people and nature first, to improve product durability, to reduce rubbish and pollution, and to ensure businesses act responsibly.

Policy Mechanisms

Again, most respondents (who answered the closed question) either agreed or strongly agreed (73%, n=121) with the policy mechanisms identified in the draft strategy, with the qualitative comments also showing general support in principle.

Respondents supported the range of measures being proposed, and felt they were comprehensive, reflected the key levers available, and provided a good framework.

However, some felt these relied too heavily on voluntary mechanisms, and they felt they needed to be stronger and include legally binding regulations, mandatory requirements, and enforcement measures in order to compel change.

In addition, respondents again suggested there was a lack of information about implementation, with calls for the strategy to include details on actions, funding, enabling infrastructure, fiscal levers, capacity building, targets, priorities and sequencing, timelines and interim milestones, reviews, monitoring and accountability. It was felt that this section would also benefit from consideration of collaboration and a cross-sector approach.

• Business support - respondents suggested this needed to include tangible and targeted support, and to consider different sectors and sizes of business.
• Behaviour change - this was perhaps the most contentious mechanism. Some saw this as critical, while others (including the campaign respondents) advocated for structural, systemic and business changes instead. Respondents felt that behaviour change would require an enabling environment, clear information, education, and national campaigns.
• Place-based approaches - respondents largely agreed with this mechanism, although a few were keen to avoid regional inconsistencies developing.
• Procurement - respondents generally supported this mechanism, although it was noted that change may be needed to current practices to allow focus to be given to circular priorities over other procurement factors (such as cost).
• Skills and education - this mechanism was largely welcomed, with respondents stressing that this should begin in school and be fully embedded throughout all levels of education.
• Circular economy data - respondents generally supported this mechanism, although they also suggested that data gaps needed to be addressed, requirements needed to be proportionate, and the data needed to go beyond waste to consider other aspects of the circular economy.
• Policy alignment and systems thinking - there was strong support for this mechanism, with respondents agreeing that circular economy principles needed to be embedded across policy areas, and include alignment with UK and EU measures.

Priority Sectors

Most respondents (who answered the closed question) again either agreed or strongly agreed (71%, n=119) with the priority sectors identified in the draft strategy. Respondents also outlined support for the development of roadmaps, and for the various sectors to be involved in their design.

However, consistent with earlier feedback, respondents also called for clear delivery/implementation plans. There was also a strong desire for plastics (highlighted by campaign respondents and others) and packaging to be included as a priority sector, followed by electricals and chemicals.

Respondents also suggested that this section should more clearly set out/assess a range of impacts/issues, including economic, social, workforce, environmental, health, inequalities, and international issues. Further, consideration was also said to be needed of interdependencies and cross-sector delivery/business practices.

Respondents largely supported the inclusion of each of the priority sectors, and outlined specific mechanisms and support which they perceived would be needed to drive change in each sector. Other sector specific issues included:

• The built environment - respondents wanted more focus on the design stage, as well as on durability, reuse, repair and refurbishment.
• Net zero energy infrastructure - again, respondents felt that the design stage and the full lifespan of infrastructure/materials needed to be considered. It was also suggested that smaller scale and community projects needed to be considered, as well as recycling options for decommissioning.
• Textiles - the key focus of responses was on fast-fashion and low-quality textiles. Again, respondents advocated for greater focus higher up the waste hierarchy, specifically on overconsumption, durability, reuse and repair. Greater consideration was also needed of social and environmental harms, and international issues.
• Transport - responses were mixed, with some discussing a net zero transition in transport. There was support for the proposed measures, but also suggestions that greater focus was needed on demand reduction measures, and improving maintenance, repair, reuse repurposing and remanufacturing.
• The food system - respondents advocated for clearly embedding the food waste hierarchy, tackling overconsumption, considering redistribution, and to explicitly include composting. There was support for behaviour change, but also calls for mandatory rather than voluntary measures. Respondents also wanted consideration of sub-sectors, as well as packaging, and other issues such as chemicals, water use and soil quality. Mixed views were provided over rural kerbside collection exemptions and business reporting requirements.

Product Stewardship

Most respondents supported the principle of product stewardship, and welcomed the inclusion of the products identified in the strategy, as well as alignment across the UK and EU where possible.

There were, again, several ways in which respondents suggested that this section could be strengthened. These included:

• That mandatory rather than voluntary measures would be preferrable (this was suggested by campaign respondents and others).
• Include measures to hold producers accountable for the full life cycle and the impacts of their products.
• A stronger emphasis should be placed on waste prevention measures (e.g. durability, repair, repurpose, reuse, and resale).
• Support for key measures, including Extended Producer Responsibility (EPR) programmes, deposit return and takeback schemes, and procurement reform.
• Consideration/inclusion of a wider range of products (with plastics, lithium-ion batteries, persistent organic pollutants (POPs), and construction mentioned most frequently).

Monitoring and Indicator Framework

Of those who answered the closed question at this section, around three quarters (76%, n=110) said there were changes or additions they would like/suggest in relation to the Circular Economy Monitoring and Indicator Framework to ensure it was fit for purpose. In addition, respondents were asked to detail any comments they had about the monitoring and indicator framework in general, as well as for the indicators proposed for each of the outcomes in turn.

Respondents largely felt that a wider range of indicators would be needed, both in general and for each of the specific outcomes. These included societal factors, such as engagement levels; workforce; skills/educational; and equality related factors. Other suggested indicators included material consumption/footprint; lifetime carbon footprint; consideration of durability, reuse, repair and remanufacturing; consideration of plastic use; littering; sector specific measures; and procurement measures. Additional international measures were also said to be needed, both in terms of social, environmental and human rights impacts, and measures for international products.

Across the different outcomes, there were also calls for the data to be gathered/recorded in such a way that allowed for disaggregation by region, by urban/rural/island locations, by different socio-economic or demographic factors, by different sectors, and by different sizes and types of organisations. Consideration would also be needed of informal changes and those delivered by the third sector, community initiatives, social enterprises, etc. It was also noted that data and reporting requirements needed to align with UK, EU and international requirements, be proportional, consider cost and administrative burdens, may require capacity building, and that roles and responsibilities needed to be made clear.

Most of the campaign respondents and several others stressed the need for measurable goals. It was argued that, without measurable goals the strategy would be ineffective. Several respondents also called for timebound (and in some cases, statutory) targets and interim milestones. Further, there were concerns over the comparability of data, as well as the validity of a few specific indicators. It was also suggested that there was a disconnect between the indicators and the rest of the strategy, which could result in implementation challenges.

Impact Assessments

Respondents were asked to provide feedback on a range of different impact assessments that had been developed to support the strategy. Low numbers responded at each of these.

• Equality Impact Assessment (EQIA) - rather than focusing on protected characteristics, many respondents discussed wider impacts, often related to socio-economic, employment and training, and/or rural/island related issues.
• Fairer Scotland Assessment - the main considerations were affordability and whether cost would be a barrier to low-income households; supporting shorter supply chains and local providers; supporting value retention within local areas; fair work/pay; the impact of education, skills and lifelong learning in the circular economy; and the impact of procurement practices.
• Island Community Impact Assessment - it was felt that this needed to consider the uniqueness of island situations, including challenges related to cost, accessibility of services and infrastructure, as well as logistical and practical limitations to service provision. Locally suitable solutions would be needed. It was also suggested that this assessment should be extended to consider environmental harms to island communities, as well as consideration of remote rural mainland areas.
• Business and Regulatory Impact Assessment - respondents were concerned about the impacts, costs and resource capacity that may be imposed upon organisations to transition, and the potential for these to be disproportionate for SMEs, micro-businesses, community enterprises and public bodies.
• Consumer Duty Impact Assessment - respondents questioned the assumption that circular products/services would be cheaper, and were concerned about the potential for cost increases and affordability issues. Clearer product information and consumer awareness raising was said to be required.
• Child Rights and Wellbeing Impact Assessment - respondents suggested that this assessment should more fully consider how proposed measures would protect children’s rights to education, health, a safe environment, and an adequate standard of living. Children and young people should also be pro-actively engaged in the strategy development.
• Environmental Impacts - respondents advocated for this assessment to consider a range of additional issues, with the main ones being plastics and packaging. Also, it was suggested that this should consider both international impacts, and possible positive environmental impacts.

Conclusion

Overall, the consultation elicited a significant level of feedback, highlighting overall support for the creation of a strategy and much of the draft content. It also identified perceived gaps and provided suggestions on how to strengthen the proposals.