Circular economy strategy draft: consultation analysis

Vision and Outcomes

The consultation document set out the vision for the Circular Economy Strategy as:

“By 2045 Scotland will be a net zero and nature positive nation helped directly by the significant progress in transitioning towards a circular economy. 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.”

It also identified a series of outcomes, based around four key themes:

• Economy - maximising economic value, security of supply chains and innovation;
• Environment - sustainable resource use and environmental impacts;
• International - environmental and social costs on global communities of consumption in Scotland; and
• Social - benefits to communities, fairness and behaviour change.

Support for the Vision and Outcomes

Q1. To what extent do you agree with the vision and outcomes for the strategy?

Respondents were asked to rate the extent to which they agreed or disagreed with the vision and outcomes for the strategy. Most (82%, n=139) either agreed or strongly agreed. Meanwhile, 11% (n=19) either disagreed or strongly disagreed, of which, over half (n=10) were third sector organisations.

Note: a further 19 respondents did not answer the closed question.

It should also be noted that, while the 1,273 campaign respondents did not answer the closed question, most indicated in their qualitative response that they disagreed with the vision and outcomes.

The Vision

Q2. Do you have any comments on the vision?

Both individuals and organisations tended to express their support for the introduction of a strategy, discussed the strategy more generally, and/or highlighted their support for the shift towards a circular economy, rather than discuss their support of any specific aspects of the vision itself. Organisations also often outlined the relevance of the circular economy to their own sector, their commitment to the development of the circular economy, and/or discussed how they could contribute. Several also called for greater recognition of, and consideration of the impacts on, their specific industry sector within the strategy. In many instances it was difficult or impossible to identify whether comments were specific to the vision or were intended to be more general for incorporation within the strategy more widely.

It should also be noted that many of the comments showed mixed views among respondents. Many who supported the vision and outcomes caveated their support, outlined issues, gaps, and concerns, or suggested additional areas for inclusion. Meanwhile, several of those who disagreed at the closed element of this question outlined aspects which they supported and areas which limited their support. Most of the issues were consistent across the differing levels of agreement/support.

Welcomed Aspects

Organisations described the vision as welcomed, commendable, positive, clear and ambitious. In particular, they welcomed the explicit link between net zero, nature positive goals, and circular economy principles. They also welcomed the recognition that a circular economy was essential to climate mitigation, resource security and long-term wellbeing. They appreciated that it prioritised resource efficiency, reduced environmental impacts, and long-term value creation, and placed an emphasis on keeping materials and products in use for as long as possible. The inclusion of social goals and benefits, as well as environmental and economic ones, was supported. The links to the wider policy landscape was also welcomed, including Circular Economy (Scotland) Act 2024; the Environment Strategy and Route Map; the Scottish Biodiversity Strategy; the Climate Change Plan; and Scotland’s National Strategy for Economic Transformation. The economy-wide focus, rather than being waste-specific, was also supported.

Some third sector organisations and individuals welcomed the acknowledgement of the impact that Scotland’s consumption has on global communities. However, a few felt that the vision or strategy was not ambitious enough in this respect, or that it did not adequately reflect Scotland’s global responsibility/impact.

Greater Strength and Clarity Needed

While most individuals and organisations agreed with the vision in principle, several wanted it to be more ambitious and inspirational, and to convey more urgency. It was suggested that the vision was “too generic”, “vague”, “unconvincing”, “limited”, and “unambitious”. A few others suggested that the vision was too “high level”, “idealistic” and “utopian”.

One of the main issues for both individuals and organisations was the need for more detail on how the vision would be delivered and achieved. This included calls for information on specific actions, goals and targets; any regulatory or legislative changes needed; investment and funding streams that would be made available; outcomes and measurable indicators; a timeline for delivery as well as time-bound milestones; progress monitoring and robust governance and oversight; incentives to engage with and participate in the circular economy and disincentives for the use of linear models; as well as accountability mechanisms and penalties:

“Vision is essential, but without effective delivery mechanisms, clear timelines, funding and sustained commitment, the strategy risks repeating past patterns (stagnating household recycling rates, limited uptake of food waste collections and repeated postponements of the landfill ban). The importance of robust implementation cannot be overstated otherwise the strategy will be nothing more than warm words, which Scotland’s economy would not benefit from.” (Organisation: Representative/Membership Body - Waste)

Several organisations also called for greater clarity or definitions to be included for certain terms as they may not be well understood or could be open to interpretation. Of these, most highlighted ‘circular economy’/‘circular economy principles’, while a few also flagged ‘net zero’, ‘nature positive’, and ‘fair distribution’/‘fairly distributed across society’ as being unclear.

In addition, there were calls for more context information to be included in the strategy. One organisation suggested that the document would benefit from a more complete background section, outlining different conflicting schools of thought about the benefits of the circular economy. Two others suggested that an introduction section would be useful to provide greater context to those less familiar with the subject, without the need to cross-reference different documents.

Additional Areas to Consider

Another concern for respondents (including individuals and organisations across different sectors), was that a range of issues were considered to be missing. This included plastic production and waste; water, wastewater and water pollution; food security and food waste; litter and pollution; wood; tobacco control; resource intensive digital infrastructure; specific reference to materials, such as those that are toxic or environmentally harmful, or where there are gaps in self-sufficiency; and the restoration of natural cycles. Other aspects felt to be missing were the consideration of jobs; local and global supply chains; imports/exports; and fair trade.

Both individuals and organisations recommended including a focus on reusing, repairing, repurposing and retrofitting, including multi-sectoral approaches where materials can be shared between sectors. The need to tackle overconsumption, reduce (raw) material consumption, and Scotland’s materials footprint was considered to be vitally important and not adequately prioritised in the draft vision/strategy. Respondents advocated for the vision/strategy to explicitly embed the waste hierarchy, and focus more on the top levels of this. Other areas flagged for consideration by fewer respondents included issues of affordability and accessibility of opportunities; explicit commitment to nature-based solutions and enhanced biodiversity; social justice; wellbeing; democracy and environmental resilience.

Several organisations recommended more explicit recognition of regional diversity, rural economies and communities, and rural challenges. It was suggested that a stronger focus was needed on place-based delivery to ensure meaningful inclusion and impacts in rural and island areas. It was felt that more emphasis was needed on making the circular economy work in peripheral places, and that any monitoring and success measures needed to be disaggregated for rural and island areas.

Several organisations suggested that consideration needed to be given to the challenges and barriers likely to be faced in achieving the vision, particularly in the face of previously unmet net zero targets and the financial pressures on the public sector. Local authorities and representative bodies in particular were nervous about funding and the public sector’s ability to deliver the necessary changes without increased resources:

“…the vision should also include a commitment of support for local authorities and businesses through sustained funding, infrastructure and economic incentives…For local authorities, making any change to a service with ever decreasing budgets means having to cut services elsewhere but with many local authorities already having reduced services and potentially providing essential services only, there is no budget available to introduce and sustain any new services/statutory duties required to deliver the strategy.” Organisation: Public Body - Local Authority)

Both individuals and organisations identified the need to consider and include skills and workforce development to support a move to a circular economy. This included the need to support existing workers to retrain/transition.

Several organisations felt that the voluntary and third sector needed to be included and recognised within the vision/strategy. A few also suggested that links were needed to just transition principles. One also advised that consideration of the UK Internal Market Act 2021 (UKIMA) was needed to provide clarity on if/how any requirements implemented in Scotland would be compliant.

A few organisations also thought that the vision should set out the nature and scale of the expected changes that individuals, communities, businesses and government would need to make, as well as outline the challenges in achieving such changes and any actions to overcome these.

Success Factors

Individuals felt that success would rely on consumer demand for reusable and remanufactured goods. In addition, both individuals and organisations suggested that greater education of the public would be needed regarding the short- and long-term benefits. It was also suggested that the opportunities and benefits should be set out in the vision to ensure maximum awareness, as it was felt than most members of the public would be unlikely to read the strategy document in full. Both individuals and organisations advocated for community engagement to encourage local ownership. A few organisations recommended that community wealth building principles be embedded in the vision, to include local ownership of assets and democratic control. A few others suggested that the vision should explicitly support community-led, social enterprise and youth-driven approaches.

Organisations also stressed that strong partnerships would be needed between industry, academia, and government. It was highlighted that meaningful engagement and collaboration with all sectors and businesses would be crucial for the success of the strategy. It was felt that the commercial/business case for adoption of the circular economy would need to be set out to support uptake and success, with particular support needed for SMEs who may encounter barriers to transitioning to the circular economy. This would need to be factored into both the strategy and any supportive offerings.

It was also suggested that the strategy needed to avoid becoming a standalone document. Maximum impact would be achieved by ensuring the circular economy became the standard, with this approach being incorporated throughout other areas and plans:

“…the vision would be strengthened by explicitly positioning the Circular Economy Strategy as a delivery pathway for Scotland’s wider environmental and economic ambitions, including the draft Environment Strategy, the Climate Change Plan, the Scottish Biodiversity Strategy to 2045 and the National Strategy for Economic Transformation which are all listed in the consultation document. Making this role explicit would help ensure circular economy actions are prioritised as core contributors to climate mitigation, pollution reduction, nature recovery and economic resilience, rather than as parallel or supporting measures.” (Organisation: Representative/Membership Body - Other)

Several organisations stressed that infrastructure, funding, frameworks, standards and enabling systems would be needed to ensure the circular economy could be adopted at scale:

“Governments need to create an enabling environment where it is easier for consumers to make the changes which are being asked of them.” (Organisation: Public Body - Other)

Both individuals and organisations suggested that there was a need for more education in schools, as well as within further and higher education, to engage the younger generation, inform behaviour change, and train the future workforce:

“…embedding circular economy principles across all disciplines, not only within environmental or technical programmes, but also in business, social sciences, arts and professional practice, is essential for equipping graduates with the systems thinking skills required for a circular economy.” (Organisation: Academic)

Challenges of the Vision and Reasons for Lack of Support

Most of the 1,273 respondents who submitted campaign responses, explicitly disagreed with the vision and outcomes for the following reasons:

“I disagree with the vision and outcomes of this strategy, which must aim to reduce consumption of materials and put people and nature first. I want products that last for longer, less rubbish and pollution. Businesses should serve their local communities and treat people in their supply chains fairly.” (Campaign Responses)

Similarly, other respondents who disagreed typically did so because they felt the vision was not strong or ambitious enough, failed to include key aspects, or was not focused enough on reducing consumption and material use. Finally, a few of those who disagreed with the vision wanted it to be revised to prioritise people and nature rather than economic growth and profits:

“We urge the Scottish Government to revise the vision so that people and nature are put before profit, ecological limits are treated as non-negotiable, and reducing plastic production and consumption is recognised as central to delivering climate, biodiversity and environmental justice commitments.” (Organisation: Third Sector)

More generally, a few organisations and one individual cautioned that circularity did not equal net zero or necessarily help with climate change. They noted that recycling and upcycling often involved the use of other resources (e.g. energy, water, etc.). One of these organisations argued that clearer separation of the circular economy and net zero targets was needed. Another cautioned that a circular economy may compromise growth and/or encourage more consumption, and felt there was a lack of clarity around how circular economy concepts would lead to greater social equity. A few other organisations (largely from the third sector) and individuals were against the perpetual desire for economic growth, which they felt was ultimately incompatible with sustainable resource management. Instead, they preferred measures of prosperity and wellbeing.

A few individuals were also unclear/unconvinced that the circular economy would lead to lower costs or greater efficiency. One described the vision as a “wish list” which they felt was likely to undermine existing industries and increase costs. Meanwhile, another felt that the circular economy was based on a “false science that is not proven”, and was concerned that it would lead to negative financial impacts for the economy and individuals experiencing poverty.

The Outcomes

Q3. Do you have any comments on the outcomes?

Organisations tended to support the outcomes as they perceived that they aligned well either with wider sustainability objectives, to their sector, or to their own priorities. Organisations described the outcomes as comprehensive, clear and concise, wide ranging, inclusive, and encouraging. Several also flagged their support for the emphasis on fairness and just transition principles. Most organisations also commented on areas they felt were missing or could be clarified or expanded upon. Similarly, while most individuals that answered the closed question tended to agree with the outcomes, many did not indicate why they agreed or which specific elements they agreed with. Rather they suggested areas to be expanded or additional issues to be considered.

While some were supportive of the outcomes in principle, they noted that their success would depend very much on how effectively they were communicated, implemented and measured/monitored.

It should also be noted that, most of those who disagreed/strongly disagreed at the closed question did not appear to disagree with the objectives in principle. They largely felt they were not strong or urgent enough, or they noted gaps or areas for additional consideration, consistent with other respondents.

General Comments Relevant to All Outcomes

Consistent with feedback about the vision, one of the main issues raised in relation to the outcomes was the lack of, or need for, measurable targets, indicators and metrics. Respondents again wanted to see a clear and robust delivery plan, which included incentives and mechanisms which would be implemented to support/encourage change, time-bound milestones, and regional as well as national monitoring and reporting. It was felt that an outcome should be included on the measurement of progress and the transition to a circular economy:

“…these outcomes would benefit from being more clearly linked to measurable indicators, delivery mechanisms and timelines, to ensure accountability and momentum. Without this, there is a risk that progress remains uneven and dependent on voluntary uptake, which can exacerbate social and geographic inequalities.” (Organisation: Other)

In addition, several respondents called for the outcomes to recognise the various relevant stakeholders, delivery partners, enabling conditions and barriers to change at each outcome. In particular, it was felt there needed to be acknowledgement and efforts to address gaps in the existing infrastructure that would be needed to deliver the outcomes.

Again, a few outlined specific issues which they thought should be explicitly tackled in the outcomes. These included food production, retail and waste; plastic and packaging waste; water and wastewater; hazardous materials and PFAS (i.e. those that do not easily break down in the environment, or ‘forever chemicals’); and the built environment. A few also wanted to see their particular industry sector reflected and recognised in the outcomes.

Several respondents (including both individuals and a range of organisation types) advocated for the development of close working relationships, coordination, and alignment between Scotland and the other UK nations. One individual also suggested there was a need to highlight and overcome the implications of the Internal Market Act:

“It will also be important that Scotland’s approach aligns, where possible, with wider UK policy frameworks, ensuring consistency for businesses operating across borders and maximising the overall impact of transition efforts.” (Organisation: Representative/ Membership Body - Food & Drink)

Again, a few wanted the outcomes to explicitly prioritise the waste management/ circular economy hierarchy with reduction, reuse and repair placed above recycling and recovery. There were also repeated calls for greater recognition of and support for the third sector. Further, it was suggested that help was needed to work at scale and support public bodies.

Those who submitted campaign response outlined their priorities for inclusion within the outcomes, as follows:

“The outcomes must include a commitment to use less materials, reduce environmental (whole lifecycle carbon) impacts, and for businesses to act responsibly. The indicators should reflect this and include a carbon footprint for Scotland.” (Campaign Responses)

In addition, other general suggestions about the outcomes were also provided, with those mentioned by more than one respondent outlined below:

• Highlight the inter-connected nature of the outcomes, and specifically, more clearly link economy and environment outcomes;
• Outcomes should focus on whole-life costs and performance rather than short-term, immediate or local aspects; and
• Consider unintended consequences.

Several organisations also outlined how they thought the outcomes could be delivered. This included offers of help from respondents, and partnerships with the Scottish Government to implement changes. There were also calls for collaboration, joint working (both within and between sectors) and sharing of best practice among different stakeholders. Others suggested that particular mechanisms, frameworks, standards/standardisation, supportive regulation, and policy and legislation would be required. Several also noted the need for funding to support sectors to deliver the changes.

In addition to these more general comments, some respondents provided feedback linked to each outcome. These are considered below.

Economic Outcomes

One of the main issues discussed in relation to economic outcomes was the need for explicit consideration of labour market impacts, and promoting high value jobs (although it should be noted that these issues were also discussed in relation to the social outcomes):

“The outcomes would also be strengthened by a more explicit treatment of labour-market impacts. While circular economy policies can create new employment opportunities, they may also displace jobs in incumbent sectors. The strategy should therefore indicate how potential job losses will be anticipated and managed, and how net employment impacts - alongside job quality, skills requirements, and regional distribution - will be addressed as part of a just transition.” (Individual)

“Skills and education is mentioned elsewhere in the strategy as a mechanism but I think re-skilling and job creation is also an important outcome of the transition to a circular economy in that, as jobs are lost in fossil fuel based sectors and potentially other high carbon/high polluting part of industry, the circular economy has a requirement for 'new' (including re-skilling in old skills!) skills in - for example - designing for circularity, triage, repair, remanufacturing, deconstruction and reuse.” (Organisation: Representative/ Membership Body - Built Environment)

Whilst several other aspects of the economic outcomes were highlighted, these were typically only discussed by a few respondents each, as follows:

• More focus on mainstreaming repair and reuse, and explicitly set out how resilience will be achieved, for example, through repair, reuse, remanufacture and the development of local and regional supply chains;
• Ensure the economic benefits are for Scotland, and stop profits being taken out of the country, including developing local recycling infrastructure to avoid sending materials and waste out of the country;
• Emphasise that the focus is on the common good and not how to further enrich a small minority;
• Need to consider public sector affordability/funding; and
• Provide sector specific requirements and transition plans/roadmaps.

Environmental Outcomes

A few respondents felt that the environmental outcomes should include a strong focus on significantly reducing material consumption. A few others wanted the strategy to include an outcome focused on nature and environment positive aspects, such as regenerating nature and tackling biodiversity loss.

Other suggestions and feedback related to these outcomes are outlined below, although it should be noted that these were only mentioned by a few respondents each:

• Ethical and sustainable sourcing should be supported;
• Include a focus on the development of local supply chains to reduce reliance on global resources;
• Expand the outcomes to consider the cumulative effects of transport and refining, production, manufacturing, etc. and not just on the ‘extraction’ of virgin materials;
• Consider the required renewable infrastructure, including the costs, environmental impacts and changes to natural habitats involved in developing this; and
• Include a clear outcome on Scotland’s use of critical raw materials.

International Outcomes

In general, it was felt that this section needed to be expanded and made more robust. Specific feedback included that it should:

• Refer explicitly to human rights, as per the Circular Economy (Scotland) Act 2024;
• Specify that Scotland will learn from other countries/places, become an exemplar for other countries, promote the circular economy globally;
• Explicitly support fair trade and ethical sourcing;
• Commit that no waste will be sent outwith Scotland, including both into England/other UK countries, or overseas;
• Build in legally binding requirements and compliance mechanisms to ensure meaningful change from businesses across their entire supply chains (as voluntary measures may allow businesses to avoid real accountability); and
• Consider trade boundaries so that a domestic circular economy is not undermined by cheaper imports from countries operating linear models.

Social Outcomes

One of the main aspects highlighted by respondents in relation to social outcomes was the need for training, skills development and workforce issues (as noted above). Related to this were calls for greater focus on education and training, both in schools and across society more broadly. It was felt that this should be reflected in the outcomes specifically. In addition, respondents wanted much greater recognition of local initiatives, as well as community-based and life-long learning skills and opportunities. It was suggested that these were often overlooked but contributed greatly to supporting a circular economy.

Another issue highlighted by respondents was the need to consider and provide consideration of/focus on rural areas and rural equity. This included the provision of targeted training and support for rural areas. Related to this, some respondents discussed the need to embed community wealth building throughout the outcomes (and wider strategy document). In addition, respondents advocated for an increased focus on place-based approaches, strengthening local supply chains, community resilience, and the development of local hubs. While many of these issues were highlighted as being particularly important for rural communities, they were also said to have wider applicability:

“…emphasise local circular hubs that create entry-level green jobs and affordable materials for community projects; this aligns with place-based delivery. It is important that these jobs are available at all levels and suit school leavers, people moving between sectors and reskilling, graduates and existing waste managers wishing to expand their skill set in line with the direction of policy.” (Organisation: Representative/Membership Body - Waste)

Other issues mentioned by fewer respondents included the need to:

• More explicitly recognise the social benefits, and include the co-benefits of social equity, poverty alleviation and community cohesion;
• Explicitly recognise health, health equity and reducing health inequalities as core outcomes;
• Outline the behaviour changes required to achieve the outcomes, and provide targeted support (particularly for vulnerable groups and those living in poverty) as well as an enabling environment; and
• Focus on a just transition or just transition principles.

Challenges and Reasons for Disagreement

A few respondents felt that the outcomes required greater clarity and precision in order to ensure consistent interpretation and implementation, and to enable meaningful monitoring and evaluation of progress. Certain terminology was considered vague and open to interpretation. In particular, respondents raised questions over what was meant by certain terms, how they should be interpreted, and who would be responsible for assigning meaning. Key terms highlighted included: ‘resilient Scottish economy’; ‘sustainable’; ‘value’; ‘extraction is required’; ‘the most circular way possible’; ‘internal impact’; ‘sustainable employment’; ‘in a fair and inclusive way’; ‘norm’; and ‘the most circular way possible’.

Similarly, it was felt that the terminology used could be stronger, convey greater urgency, and prioritise environmental benefits rather than focusing on minimising harms:

“Across the outcomes, there is a recurring reliance on language such as “minimised”, “limited” and “reduced”, which risks understating ambition and appears out of step with the strategy’s commitment to a net zero and nature positive future. In several places, outcomes focus on limiting harm rather than actively restoring, enhancing or designing out negative impacts. Strengthening this language would better reflect the urgency and opportunity of the transition.” (Organisation: Public Body - Local Authority)

Again, a few respondents questioned the assumptions that circular approaches would result in “lower costs” or “drive sustainable growth”, and questioned the inclusion of “reduced littering” (although one respondent explicitly supported the inclusion of litter). In particular, it was said that the focus on “lower cost goods” could reinforce consumption led models and over consumption, while it was asserted that circular economies could not grow GDP more than linear models:

“It is feasible that the cost of goods will increase as more "work" is required to repurpose materials, things are made to a higher standard, made modular to last longer, made by fairly paid/local companies…Consumers need to adjust their expectations about consumption and value what they purchase, this does not come from cheaper pricing.” (Organisation: Private Sector - Consultancy)

In addition, a few organisations questioned the scale of the impact which might be possible. It was noted that Scotland is reliant on other countries for many materials, with these other countries having control over how these are extracted/sourced. In addition, Scotland was not perceived to have sufficient infrastructure to develop a fully circular economy, and would therefore need to rely on UK capacity. Further, as the economy would still be driven by private industries, it would be difficult to ensure engagement and benefits would be felt in a fair and inclusive way. Also, it was suggested that current regulations in certain sectors could make achieving some of the outcomes difficult. One individual also felt that the outcomes were not realistic or practical, with them equating this to issues they perceived existed within the oil and gas industry, i.e. shutting down the north sea oil fields due to green transition principles and this resulting in higher prices and a higher reliance on imports.