Circular economy strategy draft: consultation analysis
External consultation analysis report following 12 week consultation period on the draft circular economy strategy.
Consultation
Discussion and Conclusion
Key Recurring Themes
Overall, there was general support for the strategy and the draft content. The quantitative results (based on those who answered the questions) showed that:
- 82% either agreed or strongly agreed with the vision and outcomes;
- 73% either agreed or strongly agreed with the policy mechanisms; and
- 71% either agreed or strongly agreed with the priority sectors.
Support was also strong across the qualitative feedback. Even where respondents disagreed at the closed questions, much of the qualitative feedback showed that they did not object to the proposals per se, rather they were concerned about gaps or they wanted the strategy to be stronger, more urgent, and to go further.
Respondents largely welcomed the strategy’s explicit link 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 supported, as were the links to the wider policy landscape. The need to embed circular economy principles throughout Scottish policy areas was considered important, along with alignment with UK and EU policy/requirements. In addition to supporting the vision and outcomes, the policy mechanisms, and the priority sectors (as outlined above), respondents also largely supported the proposals for product stewardship, although there were calls for this to include enforcement and accountability. Similarly, respondents welcomed the use of a monitoring and indicator framework, although there were a few indicators which were flagged as potentially limited/problematic and many additional indicators were suggested for consideration.
Across the feedback, several suggestions were made to strengthen the strategy and the individual proposals.
Respondents suggested that the strategy could/should provide greater focus on reducing material use and consumption levels, rather than dealing with waste. Tackling overconsumption was considered to be a key issue, but it was largely perceived to be missing from the draft proposals.
There were also repeated calls for the strategy to more explicitly consider the waste hierarchy, placing more emphasis on the top end of this, and on durability, reuse, repair, and repurposing in particular, rather than the focus being on recycling. It was stressed that the waste hierarchy should be embedded throughout the strategy.
Another theme raised across the consultation, was the need for greater consideration of international issues. This included the international (both environmental and social) impacts of Scotland’s consumption; the potential limitations of the strategy due to reliance on international markets/products/imports, and foreign owned businesses; and consideration of how to tackle these issues. The draft content focused on international issues was generally supported, but was not considered to be extensive or strong enough to effectively deal with the issues.
Several issues/sectors were also considered to be missing, with respondents urging the Scottish Government to explicitly include them within and across the strategy. The main issue was plastics and packaging, where the lack of coverage was considered to be a significant gap. Other issues mentioned by fewer respondents, but often backed by strong arguments for inclusion, were chemicals and electronics/WEEE. Finally, water and wastewater were also were also flagged for consideration and inclusion.
Respondents also wanted the strategy, and the various elements within it, to be stronger, more ambitious, and to cover more sectors. Respondents advocated for more legally binding requirements and targets, rather than relying on voluntary actions, which they perceived would not be enough to drive the required changes.
Similarly, there were repeated calls for more detail to be included regarding the tangible actions and implementation plans that would be put in place to support the strategy and deliver the required changes. This request was repeated by different respondent groups, both within and across the consultation questions. It was felt that the strategy would benefit from actions, timelines, measurable targets, interim milestones, reporting requirements, and measures to provide real accountability.
In addition, respondents identified a range of measures which they considered necessary to deliver the strategy and achieve the vision and outcomes. These included funding and investment, improved infrastructure, capacity building, awareness raising, education and training to develop skills, mandatory/statutory regulations, and reforms to procurement.
The campaign responses largely advocated for the strategy to focus on reducing consumption and the related environmental impacts, to hold businesses to account for their harms rather than focusing on consumers, to tackle plastic pollution, and to “put people and nature before profits”. Other respondents wanted the strategy to be strong, bold, and an exemplar for others.
Several organisations outlined steps already taken within their sector or geographic area which may provide good practice examples that could be included in or supported by the strategy. In addition, several organisations indicated that they were keen to be involved in the development of roadmaps, or any further engagement related to the design or delivery of strategy, and extended offers of help.
Conclusion
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. All feedback will be considered by the Scottish Government in taking forward the strategy to the next stage.
Contact
Email: circulareconomy@gov.scot