A Circular Economy Strategy for Scotland – Equality and Human Rights Impact Assessment (EQIA)

Equality Impact Assessment – Results

Title of Policy: A Circular Economy Strategy for Scotland

Directorate: Environment and Forestry Directorate

Division: Circular Economy Division

Team: Circular Economy Strategy Unit

Summary of aims and desired outcomes of Policy:

1. This Equality Impact Assessment has been prepared to accompany a publication of the Circular Economy Strategy for Scotland (‘the Strategy’) and has been updated following a public consultation and analysis of the consultation responses.

2. The Scottish Government is committed to transitioning to a circular economy as a means of addressing the climate and nature crises while delivering sustainable economic and social benefits. A circular economy keeps materials and products in use for as long as possible, thereby reducing demand for virgin resources, minimising waste, and maximising the value retained within the economy.

3. Around four-fifths of Scotland’s carbon footprint comes from the products and services we manufacture,^[1] use and throw away and 90% of global biodiversity loss and water stress is caused by extraction and processing of these products.^[2] The Scottish Government is committed to delivering a different approach to our economy, one where we move from a "take, make and dispose" model to one where we value materials and keep them in use for as long as possible.^[3]

4. The Scottish Government has set climate change ambitions to become a net zero greenhouse gas emitting nation by 2045.^[4] Sustainable resource use is key to tackling climate change and will be vital for our efforts to reduce Scotland’s global carbon footprint, and for other sectors to deliver their own net zero goals.

5. The Circular Economy (Scotland) Act 2024^[5] places a statutory duty on Scottish Ministers to publish or revise a Circular Economy Strategy every five years.^[6] The Strategy provides a high-level framework for Scotland’s transition to a circular economy, setting out a broad vision and outcomes as well as priorities across policy mechanisms, priority sectors, and product stewardship. It also sets out plans for monitoring and evaluation the impact of the Strategy via the Circular Economy Monitoring and Impact Framework

6. These priorities aim to support the Strategy “Vision” set out below:

“By 2045 Scotland will be a net zero and nature positive nation helped directly by the significant progress in transitioning towards a circular economy with sustainable levels of material use.

Scotland will have a thriving economy that meets societal needs and is based on circular economy principles, and we will have reduced the negative global impact of our production and consumption.

People, businesses and the public sector will have the skills and knowledge to benefit from opportunities arising from a circular economy and these will be fairly distributed across society.”

7. The Strategy builds on Scotland’s Circular Economy and Waste Route Map to 2030. While the Route Map focuses on sustainable resource use and reducing the carbon impact of our waste, the Strategy sets out the strategic direction for the future and how circularity will be embedded across the economy by looking at sectors, systems and products. Future interventions that relate to the Strategy’s priorities may include policy proposals, potential legislative measures, and supporting activity to drive systemic change across production, consumption and disposal of materials and products in Scotland

Executive summary

8. The publication of the Strategy in and of itself will not directly impact people or communities. However, there is potential as individual interventions related to the Strategy priorities are developed and implemented, for them to affect everyone in Scotland (including individuals, businesses, public sector and third sector organisations).

9. The priorities set out in the Strategy are intended to apply across Scotland and do not specifically target particular groups, geographical locations or sections of society. It is, however, important to consider that future interventions related to the Strategy priorities may impact people differently as they are developed and rolled out.

10. Across each of the priorities there may be potential for associated future actions to impact on individuals within protected characteristic groups.

11. At this stage, it is unlikely that there are potentially positive or negative impacts on protected characteristic groups however, it is possible that the following protected characteristic groups may be affected by interventions resulting from the priorities set out by the Strategy:

• Age
• Disability
• Sex
• Race
• Religion or belief
• Pregnancy and maternity.

12. Interventions resulting from the priorities set out in the Strategy may require individual assessments and consultation as and when they are developed. We do not anticipate every intervention will require individual assessments and consultations. Any future assessments will allow for more detailed consideration of issues and opportunities for specific activities, and for recommendations to be made about any amendments or mitigating measures needed.

13. Key considerations in future EQIAs are likely to be for interventions resulting from the Strategy priorities which may affect:

• Goods people purchase and how they are purchased
• Access to food
• Access to personal transport
• Access to skills, training and jobs
• Building fabric and energy efficiency
• Knowledge/understanding of circular economy opportunities

14. As an example, there is potential that skills and job opportunities are increased through the transition to a circular economy. While this will be across all society, it may provide additional opportunities for individuals with physical or mental health conditions. It may also offer opportunities for young adults, and equally for older individuals who remain in the workforce. There is clearly also potential for negative impacts that may not be immediately obvious until the detailed content of specific interventions is determined. However, as the Strategy itself sets out broad outcomes, it is not clear at this time how any specific interventions will affect these groups.

15. Another example is that a more circular economy may create the potential for increased access to lower cost, high quality goods for some products - as a result of changed behaviours by consumers, businesses and organisations. This could benefit protected characteristic groups and may especially be relevant for disabled or older individuals (Age), or for families with children (of all ages). There may also be disbenefits if a future intervention reduces access or increases costs for other product types. As such, understanding and setting out the potential impacts of priorities will require assessment of associated interventions once they are in their own planning and development phase.

16. Due to the strategic nature of the Strategy, we have undertaken an initial screening to assess potential impacts on people with protected characteristics. It is anticipated that subsequent EQIA requirements will be further assessed as the interventions resulting from the priorities set out in the Strategy are designed, developed and implemented.

Background

17. The development of the Strategy will align, as far as practicable, with key Scottish Government commitments, as set out below. The Strategy also reflects international commitments such as the UN Sustainable Development Goals,^[7] the EU Circular Economy Action Plan,^[8] and the Paris Agreement.^[9]

18. The Scottish Government will also develop proposals for the introduction of circular economy targets following the publication of the Strategy and associated monitoring and indicator framework. This is also a requirement of the Circular Economy (Scotland) Act 2024.

19. The Strategy is already supported by, and will be connected to, a wide range of existing and planned circular economy policies, interventions and activities. These include investment in reuse and recycling infrastructure resulting from our Recycling Improvement Fund, or product stewardship initiatives such as the packaging Extended Producer Responsibility scheme, the Deposit Return Scheme, or measures on other product types. The Strategy builds on existing and planned activities to set a clear direction for Scotland for the systemic change required to transition to a circular economy

The Scope of the EQIA

20. Whilst the nature of the Strategy means that it will not have a direct impact on those with protected characteristics, it has been considered important to complete an EQIA nevertheless. This EQIA does not offer full insight into all potential issues that will come from the development of interventions linked to the priorities set out in the Strategy, however we can identify and consider broader issues. Doing so will assist further investigation prior to development and implementation of individual interventions, as required.

21. A high-level framing exercise has been carried out to determine whether an EQIA was required, and to identify relevant areas for investigation.

22. An initial assessment of potential impacts on those with protected characteristics has been undertaken. This involved systematically assessing the Strategy priorities and considering impacts on protected characteristics based on EQIA guidance. This process looked at the theme of the priorities and anticipated the nature of activity it may demand.

23. As a result, many priorities were discounted from this analysis because it was not immediately clear how they might have an equalities-related impact. Only those priorities that could be reasonably predicted to link to future impacts on protected characteristic groups are included.

24. This EQIA acknowledges and assesses some generic activities that may result from pursuing interventions linked to stated priorities. This will enable an element of impact assessment at this stage and highlight areas for fuller assessment in future. These generic activities are:

• Research activity
• Policy development activity
• Communications activity

25. This EQIA has also been informed by the 2024 Circular Economy and Waste Route Map EQIA.^[10] The Strategy was a priority intervention within the ‘Strengthening the Circular Economy’ Strategic Theme of the Route Map. A number of Route Map interventions interact with Strategy priorities – either explicitly or due to their respective purpose or approach to specific themes or areas of the circular economy.

26. The analysis was also updated to take into account responses to the public consultation on the draft Strategy which ran from 21st October 2025 to 13th January 2026.

27. Additional evidence sources were suggested and incorporated into the analysis and have been recorded for use in any future EQIA for activities resulting from the Strategy’s priorities. These included additional equalities and human rights evidence in relation to existing inequalities and potential impacts relating to skills and education - and their potential impact on employment outcomes.^[11] Also, the need to utilise new insights regarding food surplus and food insecurity and the relationship between these issues and the Scottish Government “Cash-First - towards ending the need for food banks in Scotland” plan.^[12]

28. Consultation responses tended to state generic issues or considerations regarding the implementation of any circular economy policies or initiatives resulting from the Strategy – rather than offering specific suggestions for amending this EQIA. For example, comments that the voices of those with disabilities should be heard and prioritised – and that cultural diversity should be recognised; that food waste reduction and redistribution activities can have equality implications; and that developments within the circular economy need to consider the impact of harmful chemicals and their disproportionate impact on those who are pregnant. While none of these relates directly to priorities set out in the Strategy these issues should be accounted for during the development of any actions resulting from the Strategy, where appropriate.

29. Consultation respondents reiterated the need to ensure training, retraining and skills development initiatives are designed for inclusivity. Circular economy education and life-long learning opportunities were also highlighted as means to overcome structural disadvantages for those with protected characteristics, if planned appropriately.

30. Consultation responses also highlighted that circular economy policies may positively impact on health inequalities because of potential benefits relating to reduced pollution and access to affordable and/or durable goods. Understanding the potential benefits regarding health outcomes should be explored in any subsequent EQIA relating to activities resulting from the Strategy.

31. Consultations responses also suggested that evidence regarding training needs for those with protected characteristics is limited and that better data on this would help to identify and alleviate any future impacts. Also highlighted was the need to engage with representative organisations to further ensure inclusivity, explore place-based approaches and to address any impacts proactively in the development of circular initiatives. Economic modelling was also deemed vital to understand any cumulative impacts of circular economy activities resulting from the Strategy on people with protected characteristics with low incomes.

32. The responses highlighted additional potential impacts, for those with protected characteristics, including those associated with:

• Digital inclusivity.
• Access to private transport.
• Access to jobs.
• Costs/affordability and access to circular options.
• Caring responsibilities and time poverty.
• Disproportionate impacts on certain groups because of job displacement.
• Just Transition.

33. The Strategy is focused on setting out clear priorities within a number of policy mechanisms, priority sectors and for a product stewardship approach. Specific policy detail for any associated interventions is not defined at this stage. As such publication of the Strategy itself will not result in impacts on protected characteristic groups. However, it is possible that some of the interventions developed as a result of the Strategy priorities may have an impact. These impacts will need to be taken into consideration as their proposal, plans and actions are designed and implemented.

34. Other factors investigated in relation to the additional protected characteristics do not appear, at this stage, to raise significant equality-related issues. This may be due to a lack of available published information and the individual circumstances of those impacted. Direct engagement with equality groups and individuals may identify further impacts as and when individual interventions resulting from Strategy priorities are taken forward.

35. This EQIA can be used to help determine the level of further evidence gathering or external engagement that may be required as associated interventions are designed and taken forward.

36. Further EQIAs will be carried out, where needed, as and when any specific interventions linked to the published priorities are developed and progressed. This will allow for more detailed consideration of any issues specific to future measures, and for specific recommendations to be made about any amendments or mitigating measures.

Key Findings

37. The Scottish Government does not believe there to be sufficient evidence to amend the contents of the Strategy at this time based on the framing exercise and analysis of the consultation responses. Individual interventions resulting from the Strategy’s priorities will require a period of design and development. Where required this process will need to include consideration of the need for a separate suite of impact assessments, including any required intervention-specific EQIAs.

38. No positive or negative impacts have been identified that will result from the publication of the Strategy itself.

39. However, it is possible that, depending on their design, some of the interventions that result from Strategy priorities may have both positive and negative impacts on the following protected characteristics: age, disability, sex, race, religion or belief and pregnancy and maternity.

40. These include, but are not limited to, the following examples set out below. In addition to the impacts considered, it is important to note that the protected characteristics considered within this EQIA are not independent of each other. Some people may have to deal with complex and interconnected issues.

The Strategy as a whole

41. The Strategy and priorities will necessitate actions that are taken to reduce carbon emissions, achieve our net-zero ambitions and in doing so mitigate climate change.

42. This issue is viewed differently by different age groups and as such the impact and/or understanding of interventions may be different across age groups.

43. There is a recognition that disabled people may be impacted more severely by climate change^[13] as they are often left out of policy making processes. Inclusion of disabled people in decision making processes is critical to understanding impacts, and potential impacts, based on their lived experiences.

Policy Mechanisms

44. Interventions resulting from Strategy priorities, such as empowering consumers and organisations to adopt circular behaviours and supporting businesses to increase circularity and uptake of circular business models may have an effect on the availability and/or price of specific goods in future.

45. On average, disabled people face extra costs. In 2024/25 disabled households needed on average, an additional £1,095 a month to have the same standard of living as non-disabled households.^[14] This may mean that any increase in cost of living is more challenging to manage and should be carefully considered when relevant measures are developed. In addition, the suitability of alternatives for disabled people will need to be considered if measures are taken forward which shift markets to alternative goods.

46. Changes to the price of goods may impact women disproportionately. In 2017 it was estimated that 67% of all UK household consumption is controlled or influenced by women.^[15] In 2020 a higher proportion of women reported being mainly responsible for household budgeting (37% vs 22% of men) and taking charge of spending decisions for the house (38% vs 28% of men).^[16] Women are more likely to be the “household bookkeeper” and will take day-to-day spending decisions on household products all or most of the time (56% vs 15% of men).

47. This means women will have a strong influence on household purchasing of goods and waste production.

48. Behaviour change is central to enabling a circular economy and one area related to maternity is nappy reuse - there remains a preference/default position across all parents in Scotland to use disposable nappies for their young children. ^[17] For parents, the primary barriers include initial higher costs. Where this group intersects with the Disability characteristic group similar issues may also be a barrier, or act to compound barrier to uptake of reusable options.

49. Expanding the application of a place-based approach to the circular economy has the potential to improve accessibility of circular economy products/practices.

50. Increasing the uptake of circular practices through improved skills and education opportunities should include opportunities for those with protected characteristics.

Priority sectors

Built environment:

51. Built Environment sector-specific priorities may lead to interventions that impact on protected characteristics as a result of energy efficiency and building fabric related issues.

52. Future interventions that may improve energy efficiency should consider older people who are less likely to live in the most energy efficient homes, and as a group may be more positively impacted by such changes. Older households are also less likely than families and other household types to report that their heating system doesn’t always keep them warm in winter: 12%, compared to 16% of families and 21% of other households.^[18]

Textiles:

53. Improving management of post-consumer textiles may result in an impact on some protected characteristics if this management requires additional household collection requirements.

54. Due to physical changes that become more common with age, mobility may be limited in older adults, restricting their autonomy and ability to manage additional tasks to separate different materials for recycling. Additionally, older individuals (often with health conditions associated to their age) can struggle with the separation of recycling.

55. To make sure any kerbside collections are accessible this will need to be communicated to elderly or disabled people who receive an assisted uplift from their local authority. Responsibility for this would lie with the local authority.

56. These priorities may result in an impact on recycling behaviours of different age groups. Both younger and older people are likely to want to fully participate in any new recycling services that follow on from the Strategy priorities. Inclusive communication is critical. Older adults may not be aware of the proposed changes to the same extent as other groups if communication about the proposal is restricted to digital means.

57. Additional household collection requirements may result in an impact on recycling behaviours of disabled people – and their engagement and use of services. In 2018 people with a long-term illness or disability were less likely to view climate change as an immediate and urgent problem as people without (60% compared to 67%).^[19]

Transport

58. Improving circularity of passenger and light goods vehicles should consider issues this would raise for those with protected characteristics who are more reliant on personal transport.

The Food System

59. Work on household food waste reduction behaviour, improving circularity in the supply chain and work with stakeholders to support food waste reduction by businesses may impact on some protected characteristics.

60. For example, future interventions may influence the redistribution of surplus edible products. Evidence suggests a higher proportion of those reporting food insecurity eat no fruit or vegetables or are struggling to afford healthy food. Food insecurity and nutritional disparities affect different groups in society more acutely. As such future activities should consider the need for sufficient access to nutritional foods at redistribution outlets.

61. The prevalence of food insecurity among children was higher than among adults: around 11% of children lived in food insecure households in 2016. According to a study conducted by the Trussell Trust in 2019,^[20] redistribution of edible food surplus is becoming part of an accepted non-emergency response to alleviating and mitigating food insecurity in the UK.

62. The Trussell Trust found that levels of food insecurity were greater in households with people affected by ill health and disability.^[21] Adults living in food insecure households are more likely to experience poorer mental health and chronic health conditions, such as diabetes, hypertension, arthritis and heart disease.

63. The Trussell Trust identified that women living in a couple with children tend to be more food insecure, on average, than men living in such couples, consistent with key ‘informants’ suggestions that mothers are particularly likely to skip meals or cut down portion sizes so that children have enough to eat.^[22]

64. According to the Scottish Health Survey 2018,^[23] a quarter (25%) of single parents (predominantly single mothers) reported that they had been worried they would run out of food in the previous 12 months due to a lack of resources. Over three-quarters of these single parents (21%) reported having eaten less than they should, and around half of them (13% of all single parents) said they had run out of food due to a lack of resources.

65. Analysis by ONS shows that there are statistically significant differences in wealth by ethnicity of UK households, even after adjustment for a range of household characteristics including age and household composition^[24] - this can exacerbate food insecurity.

66. There is also a lack of evidence on the availability of culturally appropriate food through redistribution and community food providers. The design of measures to influence redistribution of surplus edible products should ensure sufficient access to culturally appropriate nutritious food at redistribution outlets.^[25]

67. The future design and implementation of interventions related to this priority which influence redistribution of surplus edible products should consider those who disproportionately experience food insecurity and are dependent upon food assistance.

68. Consultation responses highlighted a need to utilise new insights regarding food surplus and food insecurity and the relationship between these issues and the Scottish Government “Cash-First - towards ending the need for food banks in Scotland” plan.

69. The Scottish Government remains committed to ensuring that household incomes prevent food insecurity.

Product stewardship

70. Adopting a product stewardship approach to priority products based on evidence-driven criteria may include actions resulting from this priority that impact on those with protected characteristics. It is not possible to assess at this stage where any impacts will occur but all subsequent activities should encourage inclusivity and diversity to avoid bias and generalisations. It should be accessible and ensure perspectives, and experiences represent the breadth of Scottish society.

Research activity, policy development activity and communications activity

71. It is not possible to assess at this stage where any impacts will occur due to research methodologies resulting from Strategy priorities. However, future research activity must encourage inclusivity and diversity to avoid bias and generalisations. It should be accessible and ensure perspectives and experiences represent the breadth of Scottish society.

72. It is not possible to assess at this stage where any impacts will occur due to policy implementation following research resulting from Strategy priorities. However, future research activity should require a methodology that includes perspectives, and experiences of those with protected characteristics

73. It is not possible to assess at this stage where any impacts will occur due to policy development resulting for Strategy priorities. However, future policy development activity must encourage inclusivity and diversity to avoid bias and generalisations. It should include voices from organisations that represent those with protected characteristics.

74. It is not possible to assess at this stage where any impacts will occur due to communications activity resulting for Strategy priorities. However, future communications activity must be inclusive and suitable for non-English speakers. Large print/braille options will be required – and should meet all required accessibility standards.

Recommendations and Conclusion

75. On present evidence, we do not believe that the Strategy itself is directly or indirectly discriminatory. However, individual interventions resulting from the Strategy priorities may have a range of both negative and positive impacts across protected characteristic groups.

76. It is recommended that, as individual interventions relating to the Strategy priorities are being developed, they are subject to the impact assessment process ranging from screening to full assessments as required.

77. It is recommended that stakeholder engagement with relevant representative groups and those with lived experience is undertaken as interventions relating to Strategy priorities are developed.

78. It is recommended that findings and evidence gathered from this and other related EQIAs are maintained and updated as necessary to support future impact assessments related to the Strategy priorities.

79. It is recommended that where appropriate, future research, policy development activity and communications activity related to the Strategy priorities should take cognisance of gathering evidence of potential impacts to protected characteristic groups.