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Scotland's Zero Waste Plan: Consultation


03 Zero Waste - Recycling and composting

Our vision is of a Scotland which:

  • Has high levels of recycling at home, at work and in public places.
  • Has more recyclate reprocessed in Scotland.
  • Has businesses and householders recycling a wider range of materials and dramatically reducing the amount sent to landfill.
  • Produces high quality recyclate with sustainable end-use markets.
  • Has businesses and householders using recyclate, or products containing recycled content, on a regular basis.

3.1 Introduction

The revised Waste Framework Directive ( WFD) provides a definition of recycling:


"Recycling" means any recovery operation by which waste materials are reprocessed into products, materials or substances whether for the original or other purposes. It includes the reprocessing of organic material but does not include energy recovery and the reprocessing into materials that are to be used as fuels or for backfilling operations.

To succeed in recycling and composting, three elements must be in place:

Infrastructure. There has to be an accessible, efficient and effective collection system, at the kerbside (or at the location of the business receiving the collection) and at appropriate designated centres and points. Infrastructure to sort and reprocess the recyclate is also required.

Information. Clear, accurate, accessible and up to date information and support has to be provided to those using the collection system (including to those who could use the system but do not or do so only to a limited degree). This ensures increased levels of participation; high "capture" rates ( i.e. that the vast majority of the materials which householders and businesses can recycle are recycled) and low levels of contamination.

Markets. The material collected has to be turned into new products, through reprocessing. The better the quality of the recyclate, the more demand there will be for the material. This is further emphasised in the revised WFD (eg. Article 11) which refers to the need for high quality recycling.

Recyclate must be of good quality to obtain a market.

Government will take further steps to promote sustainable procurement, through a forthcoming Sustainable Procurement Action Plan, including specifying recyclate in contracts to assist with stimulating market demand for recyclate.

3.2 EU revised Waste Framework Directive requirement - separate waste collection

Article 11(1) of the revised WFD requires Member States to…

"take measures to promote high quality recycling and, to this end, shall set up separate collections of waste where technically, environmentally and economically practicable and appropriate to meet the necessary quality standards for the relevant recycling sectors" and to set up separate collections "for at least the following: paper, metal, plastic and glass" by 2015.

This requirement is subject to Article 10 (2) which provides that "waste should be collected separately if technically, environmentally and economically practicable".

These requirements apply to all wastes and not just municipal waste. To ensure that recycling continues to increase, Government considers that Scotland should aim to meet the Article 11 requirements for all waste.

3.3 Municipal waste - recycling and composting rates and targets

Figure 4 shows Scotland's municipal waste recycling and composting rate over the last 5 years. There have been considerable increases in performance.

Figure 4 Municipal Waste Recycling and Composting in Scotland

Figure 4 Municipal Waste Recycling and Composting in Scotland

Financial Year

Percentage of Total MSW Arisings
























Percentages are correct to one decimal place, any differences are due to rounding.

Sources: SEPA Local Authority Waste Arisings Survey ( LAWAS) 2003/04-2005/06 and WasteDataFlow 2006/07-2007/08

Government has set challenging targets in relation to the recycling and composting of municipal waste, to maximise environmental, social and economic opportunities for Scotland. The targets for recycling and composting are:











Annex A provides greater information on targets.

photo3.4 Municipal waste - improving recycling and composting performance

A series of workshops took place in 2006 and 2007 to discuss how Scotland's recycling performance could be improved to meet the 2010 target. These workshops concentrated largely on the collection systems and on ensuring that householders were able to participate fully in the systems. Details of the recommendations and actions are at Annex H.

Looking ahead, key actions to improve municipal recycling and composting rates are:

Optimise existing and new collection services

Extend roll-out of kerbside collections

Increase the number of materials collected at kerbside

Increase volume of recycling bins/containers

Consider frequency of collections (this is entirely a matter for local authorities)

Increase access for SMEs to kerbside collections and recycling centres, ensuring that costs are fully recovered

Recover value from bulky and special uplifts

Continue work with retailers on the recycling facilities they provide and on the recyclability of packaging

Enforce policies on the presentation of waste

Improvements to recycling points and centres

Ensure producer responsibility works effectively

Improve the capture rate by in-depth intervention at a local level

On-going public campaigns at a local level across all 32 authorities

Use sustainable procurement to specify recycled content, including use of the provision in the Climate Change (Scotland) Act, if required

Increase reprocessing capacity, in areas such as food waste and plastics

Analyse demand for recycled materials

Develop end of waste criteria for recyclate, to ensure recyclate can be regarded as a product

Obtain better information on flows of recyclate

Maintain information on prices paid for recyclate

Advice and support to recycling and composting companies

End the Quality Meat Scotland moratorium on using compost derived from food waste and Anaerobic Digestion digestate on agricultural land

The publication of an annual report on the state of recycling markets

3.5 Municipal waste - charging and incentives

Local authorities in Scotland are empowered to charge in certain circumstances. More details are at Annex H. In brief, authorities must charge for the collection and disposal of industrial waste and are empowered to charge for the collection and disposal of commercial waste.

The Controlled Waste Regulations 1992 allow local authorities to charge for the collection of specified categories of household waste (eg for bulky uplifts and green waste). The Government is currently reviewing these Regulations.

However, Government has no current intention of introducing direct variable charging for household waste ( i.e. with the amount paid by householders varying depending on the amount of waste put out for collection).

There are examples of incentives to encourage recycling. Examples include: rewards (eg money off coupons) when people use reverse vending machines; entering people into a lottery for prizes when they participate in recycling; donations to charity when recycling rates improve and reducing the size of bins taking residual waste.

Question 11

On improving municipal recycling rates:

a) Do you agree with the key actions needed to improve municipal recycling rates? Yes/No. If no, what else should be done?

b) Should most (eg. 80%) of the recycling targets be met through collections of recyclate at kerbside and through recycling centres and points? Yes/No.

c) Do you consider that local authorities need more in-depth support to
help improve municipal recycling performance. Yes/No. If yes, what should be done?

d) Do you consider that there could be a greater role for incentives to improve recycling performance. Yes/No. If yes, what type of incentives?

e) Should any changes be made to the categories of household waste where local authorities can charge for collection? Yes/No. If yes, what changes should be made?

photo3.6 Recycling in public places

There are provisions in the Climate Change (Scotland) Act for the Scottish Ministers to make regulations requiring recycling facilities to be provided outwith the home and at events. There would be full consultation on any such proposed regulations.

Waste Aware Scotland is currently developing signage for on-street and public space recycling facilities with local authorities and other bodies.

Government intends to hold a round-table meeting to explore further work in this area.
The aim is to ensure that recycling zones for the public are available right across Scotland.

Case Study:

Waste Aware Events - Perth & Kinross Council

Waste Aware Events is a service provided by Perth & Kinross Council's Waste team to help event organisers deal with waste and encourage recycling during their events.

The service offers help and guidance on waste and recycling collections, awareness, planning and locating waste facilities at the event to encourage participation in recycling, as well as monitoring results and motivating staff and vendors.

Waste Aware Events is relevant to all, ensuring that small or very large events can take responsibility for the waste and dealing with it in a sustainable way by preventing waste from going to landfill.

With the Climate Change (Scotland) Act 2009 specifically mentioning waste from events, event organisers should look closely at how their waste is dealt with.

For more information please contact the Perth & Kinross Council Customer Service Centre on 01738 476476 or email recycle@pkc.gov.uk

Question 12

What more should be done to encourage recycling in public places?

3.7 Non-municipal waste - recycling performance

The graphs below show current estimated recycling and composting rates for waste other than municipal waste. These figures should be treated with caution as indicated in section 1.5.

Figure 5: Non-municipal waste - recycling and Composting Rates in Scotland

Figure 5: Non-municipal waste - recycling and Composting Rates in Scotland


Recycling and Composting Rate (% of sector arisings)

Commercial and Industrial * †

Construction and Demolition













* Excluding construction and demolition.

† The variability in the C&I recycling percentage from year to year is mainly due to changes in the amount of waste recycled at exempt sites. This is particularly noticeable in 2006 as this year has the largest tonnages of waste recycled but the lowest total C&I waste arisings.

Sources: SEPA returns and surveys, for further details see Tables 5 and 6, Annex B.

3.8 Construction and demolition waste - improving recycling performance

Construction and demolition waste is the largest waste stream in Scotland ( SEPA estimate that around 9.5 million tonnes were managed by waste facilities in Scotland in 2007).

Article 11 of the revised Waste Framework Directive lays down a new target in relation to construction and demolition waste:

photo"by 2020, the preparing for re-use, recycling and other material recovery, including backfilling operations using waste to substitute other materials, of non-hazardous construction and demolition waste excluding naturally occurring material defined in category 17 05 04 in the list of waste shall be increased to a minimum of 70% by weight".

There is already a high level of recycling in the construction industry, through, for example, the crushing of material to use as aggregates so we are already close to meeting the target.

Scottish Environment Protection Agency ( SEPA) will obtain improved data on construction and demolition waste to measure our performance in relation to the target.

Case Study:

WRAP are taking steps to improve recycling performance in construction. Working with Envirowise, they have an agreement with industry to halve the amount of construction waste going to landfill by 2012: http://www.wrap.org.uk/construction/index.html. The Scottish Government has signed this commitment.

In addition, WRAP has run capital grant competitions to support the provision of infrastructure to recycle and reprocess construction waste. Waste Aware Scotland have established a colour coding scheme for signage on construction sites to help improve information on recycling facilities http://www.wasteawareconstruction.org.uk/

photos and logos

The Climate Change (Scotland) Act contains a provision on waste prevention and management plans. This allows the Scottish Ministers to make regulations requiring that plans be prepared in relation to the prevention, reduction, management, recycling, use and disposal of waste.

One option might be statutory site waste management plans, as in England. There would be full consultation on any proposed regulations. In the meantime, Government encourages the construction industry to draw up site waste management plans on a voluntary basis. Such plans save money and reduce the amount of waste to landfill.

3.9 Commercial and industrial waste (excluding construction and demolition waste) - improving recycling performance

How much is there?

SEPA estimate that around 8.2 million tonnes of commercial and industrial waste was produced in Scotland in 2007. SEPA will obtain improved data on commercial and industrial waste, looking in particular at total amount produced; total amounts recycled and the composition.

Who is responsible?

Responsibility for commercial and industrial waste rests with the producer. Recital 26 in the revised WFD says:

"the polluter-pays principle is a guiding principle at European and international levels. The waste producer and the waste holder should manage the waste in a way that guarantees a high level of protection of the environment and human health."

Article 14 then says

"1. In accordance with the polluter-pays principle, the costs of waste management shall be borne by the original waste producer or by the current or previous waste holders.

2. Member States may decide that the costs of waste management are to be borne partly or wholly by the producer of the product from which the waste came and that the distributors of such product may share these costs."

Companies producing waste have responsibilities under Duty of Care: http://www.netregs.gov.uk/netregs/63197.aspx Running a publicity campaign to remind companies on their responsibilities under Duty of Care may be a way of emphasising the need for sustainable waste management.

Question 13

Should a campaign be run reminding companies of their responsibilities under Duty of Care? Yes/No.

photoGovernment responsibilities (including SEPA)

These include:

  • Collecting and publishing accurate data
  • Establishing an effective and responsive land-use planning system
  • Establishing a proportionate and enabling regulatory system
  • Providing support and advice to companies to help them meet Zero Waste objectives
  • Legislation, when required, to comply with International/ EU/Domestic objectives.

In 2007, Government and SEPA produced a Business Waste Framework www.scotland.gov.uk/zerowaste/business. This Plan will replace the Business Waste Framework.


Existing work

There are existing and planned programmes of work and policy levers to increase the recycling rate for commercial and industrial waste, including:

Potential further action

Government intends to develop tailored programmes of work, in accordance with Zero Waste principles of waste prevention, minimisation, re-use and recycling, for key priority materials and sectors for the final version of this Plan. This work could be carried out by Government itself, by SEPA, by waste delivery bodies or by others, such as waste producers.

To help inform future work, Government is commissioning an analysis of existing recycling activity by SMEs and by larger companies. This research will concentrate on commercial waste, given that good information is already available on municipal waste.

Further work could include:

  • Improving data
  • Analysing any issues relating to specific sectors
  • Support to increase collections
  • Increasing awareness of existing recycling collections
  • Voluntary Agreements with industry
  • Legislation
  • Better Regulation and end of waste criteria
  • Increasing demand for recyclate, including enhanced sustainable procurement

Priority areas for action - materials and sectors

Article 11(1) of the WFD mentions some specific priority materials:

  • Paper
  • Metal
  • Plastic
  • Glass

In addition, food waste is a priority given its significant tonnage, impact on climate change and current reliance on landfill. Article 22 (a) of the revised WFD requires Member States to take measures as appropriate to encourage the separate collection of bio-waste with a view to the composting and digestion of bio-waste. 5 There is currently a lack of infrastructure to treat food waste although Government is giving financial support for work by WRAP to increase the amount of in-vessel composting and Anaerobic Digestion plants in Scotland. In addition, Anaerobic Digestion plants are now eligible for double Renewable Obligation Certificates, as outlined in section 4.6.

Waste oils are another priority material. Article 21(1)(a) of the revised WFD lays down that Member States shall take the necessary measures to ensure that waste oils are collected separately, where this is technically feasible.

Major sectors in the Scottish economy, as outlined below, tend to create significant amounts of waste and so are priority sectors when considering action on waste:

  • Public
  • Finance
  • Retail and wholesale
  • Food and Drink, including food processing industry
  • Hotels and restaurants, including cafes
  • Chemicals
  • Small and Medium Enterprises
  • Transport
  • Energy

Question 14

a) Do you agree that these are the priority materials and sectors for which tailored programmes of work should be developed? Yes/No.

b) If no, what should be included?

Other criteria apart from current EU requirements and waste tonnage could be used to prioritise programmes of work. For example, criteria outlined in the table below could be used.

Potential Criteria to Analyse Commercial and Industrial Waste Streams

1. Hazardous Content

Hazardous content, more of a risk to the environment, more need to take action.

2. "Difficult" waste streams

It may be difficult to find non-landfill alternatives for some waste streams (eg sludges) and so action may be required.

3. Recovery/Recycling Value

High value wastes. (In which case, there is greater economic value and there may be more need to take action, if such waste is still being landfilled).

4. Biodegradable

If the waste is biodegradable, it will emit greenhouse gas emissions in landfill and so there is a greater case for action.

5. EU requirements

If Directive forthcoming, preparatory action may be required. (However, action may be needed even if there are no specific EU requirements on the horizon).

3.10 Commercial and industrial waste (excluding construction and demolition waste) - targets

Government wishes to continue to demonstrate its commitment to Zero Waste. Section 2.3 seeks views on waste prevention targets. Given the current lack of robust data on waste arisings and on amounts recycled, there is an argument that the only national target which could be confidently measured now is a reduction in the amount of commercial and industrial waste going to landfill.

Government considers that a potential target would be to reduce the amount of commercial and industrial waste sent to landfill by 150,000 tonnes a year, in line with the fall from 2006 to 2007. The aim of such a target would be to encourage resource efficiency, waste prevention, recycling and composting.

Figure 6: Commercial and Industrial Waste Landfilled

Figure 6: Commercial and Industrial Waste Landfilled


Waste Landfilled (tonnes)

Commercial and Industrial









† The tonnage of C&I waste landfilled in 2004 is an estimate. For further details see Table 9, Annex B.

Source: SEPA, for further details see Table 9, Annex B

Question 15

a) Should Government set a target on reducing the amount of commercial and industrial waste sent to landfill by 150,000 tonnes a year? Yes/No.

b) Should Government set targets by specific sectors, companies or materials? Yes/No. If yes, which sectors, companies or materials, and why?

3.11 Producer responsibility

The European Union has brought forward producer responsibility measures in relation to a number of materials:

  • Packaging
  • End of Life Vehicles
  • Batteries
  • Waste Electrical and Electronic Equipment

Article 8 of the revised WFD lays down that:

"to strengthen the re-use and the prevention, recycling and other recovery of waste, Member States may take legislative or non-legislative measures to ensure that any natural or legal person who professionally develops, manufactures, processes, treats, sells or imports products (producer of the product) has extended producer responsibility."

The EU producer responsibility measures have been implemented on a Great Britain basis. In general, there has been little integration between the producer responsibility requirements and the funding provided to improve household recycling collections. In essence, producer responsibility places obligations on the producers of the waste (regarded as those putting it on the market in the first place) to collect a proportion of the waste for recycling and recovery. Producers have the option of meeting this obligation by paying a third party to recycle and recover the waste for them.

The Zero Waste Think Tank has noted that producer responsibility in other jurisdictions, such as Ontario, involve a transparent payment from the producer to the local authority to collect the waste: http://www.stewardshipontario.ca/bluebox/index.htm

The Zero Waste Think Tank has also noted there could be scope to extend producer responsibility to other materials, such as paints, solvents, household furniture and mattresses. There is also the possibility of more voluntary producer responsibility. For example, Tetrapak are already taking active steps to support recycling collections: http://www.tetrapaksustainability.co.uk /

The Scottish Government, along with the other administrations in the UK, has recently produced a Packaging Strategy. http://www.defra.gov.uk/environment/waste/topics/packaging/strategy.htm Details are at Annex N. Any comments on the Packaging Strategy should be provided through this Plan's consultation process.

Question 16

a) Should Government explore further the merits of different forms of producer responsibility, which might more directly support household recycling collections? Yes/No.

b) Should Government explore further whether extended producer responsibility as outlined in Article 8 of the revised Waste Framework Directive should be introduced? Yes/No. If yes, what materials?

c) Should Government or other bodies do more to extend the concept of voluntary producer responsibility? Yes/No. If yes, what?

3.12 Summary of key recycling and composting actions

A summary of proposed actions on recycling and composting is below. A full action plan is attached at Annex T.

Planned recycling activities

Extending kerbside collections for householders

Maintain directory of recycling services for businesses

Continued work with retailers

Improve recycling in public places

Improvements to recycling centres and points

Analysis of potential for extending and changing producer responsibility

Continued provision of information on recycling services at a local level

Support Eco Schools

Increased emphasis on sustainable procurement

More facilities to treat green and food waste locally

Production of a Market Development Plan

Developing work programmes for recycling in relation to priority waste streams and business sectors

Research on existing recycling activities by small and large businesses