Circular economy strategy draft: consultation analysis

Policy Mechanisms

Building on the recent Circular Economy and Waste Route Map, the policy levers outlined in the draft strategy, which would be used to create a circular economy included:

• Business support;
• Behaviour change;
• Place-based approaches;
• Procurement;
• Skills and education;
• Circular economy data; and
• Policy alignment and systems thinking.

Support for the Policy Mechanisms

Q4. To what extent do you agree with the policy mechanisms identified?

Respondents were asked to rate the extent to which they agreed or disagreed with the policy mechanisms identified. Around three quarters (73%, n=121) of respondents either agreed or strongly agreed, while 13% (n=22) either disagreed or strongly disagreed (over half of which were again third sector organisations (n=13)).

Note: a further 24 respondents did not answer the closed question.

Policy Mechanisms, Plans and Priorities

Q5. Do you have any comments on the policy mechanisms identified?

Q6. Do you have any comments on the associated plans and priorities?

Most feedback across Q5 and Q6 was consistent, and so the topics and issues have been collated below to avoid duplication. It should also be noted that, at Q6, some respondents provided feedback about the priority sectors which were outlined at the next section of the consultation rather than the policy mechanisms. All such feedback has been considered in the following chapter.

Reasons for Support

Again, most respondents largely agreed with the policy mechanisms in principle. On this occasion, however, fewer respondents indicated their reasons for support and often focused their qualitative responses on discussing specific mechanisms or providing suggestions to strengthen these.

Where respondents did outline their support (often briefly), this was because they agreed either with specific mechanisms, or with the range of measures being proposed. It was felt that the proposed policy mechanisms were “strong”, “broadly appropriate”, “comprehensive”, reflected a “systemic approach” and were the “main levers” or “key levers” available. They were also said to provide “a solid foundation”, an “appropriate framework” and a “necessary toolkit”. Taken together, it was felt they would be effective in driving change:

“[Organisation name] strongly agrees with the policy mechanisms identified in the strategy and considers their scope to be broadly well-aligned with the complexity of the challenge. The selection of mechanisms reflects a recognition that material efficiency must be supported by enabling conditions that extend beyond infrastructure to include capability building, mindsets, and incentives.” (Organisation: Academic)

Gaps and Reasons for Lack of Support

Despite the overall support, several issues were highlighted that were consistent across all mechanisms. These largely focused on perceived gaps that respondents felt needed to be addressed. These gaps were also the main reasons given for not supporting the policy mechanisms.

Some respondents felt that the strategy and policy mechanisms were not strong enough, relying too heavily on voluntary actions and guidance. Instead, they wanted to see the inclusion of enforcement measures, tighter and legally binding regulations, and mandatory/statutory requirements to compel meaningful and consistent change. It was perceived that relying on voluntary actions was not robust enough, and had not been a successful driver for change in the past:

“…the effectiveness of these mechanisms will depend on the extent to which they are underpinned by clear regulation, statutory requirements and enforcement, rather than relying predominantly on voluntary uptake and engagement. Evidence from climate and public health policy shows that behaviour change and market transformation occur most effectively when supported by strong legislative signals and economic incentives.” (Organisation: Other)

Other respondents went further, and suggested that the policy mechanisms would be insufficient to deliver the vision. Several organisations felt that the policy mechanisms were too vague, general and high-level, and lacked the level of ambition, commitment and clarity needed. It was also suggested that the policy mechanisms appeared to be statements of intent rather than true policy levers:

“The policy mechanisms identified in the draft strategy are not capable of delivering the vision or outcomes set out and rely excessively on voluntary action, encouragement and behavioural change. As drafted, they fall well short of the level of accountability and system change required to transition from a linear to a genuinely circular economy.” (Organisation: Third Sector)

“Most of the policy mechanisms as currently described in the draft read as intentions not mechanisms…these are principles to inform policy mechanisms not mechanisms in themselves in that they are not tools to achieve policy outcomes or instruments that directly alter incentives, reduce risk, or enable coordination.” (Organisation: Academic)

A few organisations also felt that the policy mechanisms raised questions about whether they were deliverable and how these would work in practice.

Another concern was the lack of detail around implementation and deliverable pathways. Many suggested that such information was needed to give confidence in the policy mechanisms (as well as the strategy more generally). Consistent with feedback at earlier questions, respondents called for information about actions; funding; enabling infrastructure; specific intentions, commitments and targets; clear governance arrangements; defined roles and responsibilities; clear priorities and sequencing; timelines, interim milestones and reviews; monitoring and measuring success; and accountability. Respondents also wanted information on how a coordinated and cross-sector approach and collaboration would be achieved to avoid silos forming, fragmented (and often short-term) projects becoming the focus, and to stop duplication of effort or small sectors falling through any gaps. Respondents suggested that strong frameworks, standards, guidance, and peer-learning would be needed to support organisations to deliver.

In addition, support, funding, resourcing and capacity building would be needed for delivery partners, including public bodies, as well as businesses, the third sector and community organisations. Several respondents also suggested that taxation (including VAT), funding decisions, and other economic/fiscal levers should be included as a core policy mechanism. These could be utilised as both incentives and disincentives.

Other elements considered to be missing from the policy mechanisms included:

• Just transition principles - these needed to be more strongly highlighted and embedded throughout all the policy mechanisms;
• Human rights and environmental due diligence - these should be added, both as a standalone mechanism and embedded throughout the other mechanisms;
• Repair and reuse, including targets and programmes - these needed greater focus and recognition throughout;
• The role of electrical products, plastic and packaging, and chemical sectors - these needed to be considered and included; and
• Engaging young people in the transition - including being meaningfully involved in shaping and reviewing implementation, awareness and education about the circular economy, and information provision about career pathways available within the circular economy.

Several also outlined unique and highly specific suggestions that were related to their industry sector, or detailed specific types of incentives and schemes that could be implemented to support the policy mechanisms. These comments were only provided by one respondent each, with no consistency in the sector being discussed.

In addition to the general comments, some respondents also provided feedback about the specific policy mechanisms. These have been detailed below.

Business Support

It was generally felt that this policy mechanism needed to involve tangible and targeted support. In particular, respondents identified the following requirements: funding/investment; incentives; the development of sector specific pathways; ongoing sector specific support; training, skills development and capacity building; practical toolkits; levers to create market demand; engagement at the local level; and support for collaborations, joint working, networking, and the sharing of learning and best practice. It was also argued that monitoring, reporting, regulation and penalties were required to ensure compliance and meaningful change:

“…relying on influence alone will not deliver the transformation Scotland needs within the available timeframe. The Scottish Government has a clear responsibility to deploy effective policy and fiscal mechanisms that set fair, enforceable standards - ensuring responsible practices are the norm, not an option. This is how we unlock innovation, create certainty, and accelerate change at scale.” (Organisation: Representative/Membership Body - Food & Drink)

Respondents also flagged the need to consider different sectors and different sized businesses. Several respondents wanted specific consideration to be given to the third and charity sector, social enterprise organisations, SMEs and micro-businesses, and community led initiatives. It was also suggested that support was needed to develop regional and local hubs, and that more needed to be done to support and mainstream repair and reuse business models.

A few also highlighted the need for business support to consider any potential costs of transitioning to the circular economy in the context of other issues which may have impacted specific sectors and industries in recent years.

Behaviour Change

The behaviour change policy mechanism was largely seen as critical. However, a few respondents explicitly stated that they felt this section was weak and required much more detail about how this would be achieved. Others stressed that achieving behaviour change at the individual level would require more systemic changes (to be made by business and policy). These changes would need to be implemented first to ensure there was an enabling environment to support consumers and the public to make the required change. Respondents argued that individuals could only make sustainable and green choices within the constraints of what was available and affordable, and that currently, their choices were largely constrained:

“…meaningful behaviour change will only occur if circular options such as repair, reuse and material recovery are both affordable and convenient. Capability and motivation alone are not sufficient if practical and financial barriers remain.” (Organisation: Academic)

This view was reiterated by campaign respondents, with most explicitly disagreeing that behaviour change should be one of the priority mechanisms. Rather they argued that system and business practices needed to be addressed:

“I disagree that ‘behavioural change’ should be a priority - it is unfair and ineffective to ask people to change when it's the system itself that is broken. Policy mechanisms should consider how to drive responsible business practices.” (Campaign Responses)

In addition, many suggested that clear communication (and consumer information), education, incentives and disincentives would be needed, as well as system enablers to make the circular economy easy and cost effective to engage with:

“Making the ‘right’ choice the cheapest and easiest choice is the only way behaviour change for circular economy will work.” (Individual)

Several highlighted the need for national consistency, while also recognising rural realities and taking individual circumstances into account (for example, socio-economic situations, demographics, and other factors such as digital inclusion). National level campaigns were considered necessary, which included myth busting elements, in order to build public awareness, understanding and drive participation. A few respondents suggested that the commercial advertising and marketing sector needed to be tackled to address overconsumption. Consistent terminology was also considered to be required to minimise the risk of ‘green washing’ and to ensure that consumers understand the meaning of relevant credentials.

Several respondents also suggested that the Scottish Government should undertake large scale consumer research and consider the impacts of previous campaigns in order to identify interventions that will be truly impactful.

A few respondents noted that the focus in this section was largely on households, and proposed that greater consideration needed to be given to behaviour change in businesses. They suggested that practical guidance and data would be needed to support this, as well as economic incentives and regulation. It was also argued that this policy mechanism needed to recognise and take account of the full regulatory and supply chain, as well as customer demand - it should not focus solely on end providers.

Similarly, there was concern that this section focused too much on consumption habits and did not include repair and reuse, donation, recycling and disposal habits.

Place-Based Approaches

Most respondents who discussed this mechanism, were largely supportive of its inclusion:

“Strongly agree with place-based approaches as a policy mechanism. There is huge value and opportunity to progress initiatives at a regional, community level through collaboration, co-design, co-development and cognisance of local circumstances. Places have the agility to change things rapidly and unlock co-benefits for communities.” (Individual)

It was suggested, however, that the policy mechanism should more clearly differentiate between urban and rural, and consider the challenges faced in rural and island areas. Respondents noted that place-based approaches would need to focus on and/or provide support to the different types and sizes of business and industries relevant within locations. It was also highlighted that community and social enterprises would be important stakeholders in some areas, and that tailored support for local circular hubs could be highlighted. Respondents also stressed the need to ensure that remote, rural and island communities would not be disadvantaged by a circular economy.

Only a few organisations indicated reticence or opposition to the place-based mechanism. This was due to the perception that it could create different approaches, rules, funding streams and priorities in different areas, introducing inconsistency and making it more challenging for national organisations to provide a coordinated approach. It was considered important for national coherence which allowed for flexibility at the local level.

Procurement

Some respondents were positive about the procurement policy mechanism, perceiving it to have the potential to influence markets and supply chains (both domestic and international), and embed circular economy principles as well as fair trade, ethical and environmentally friendly production. Others, however, highlighted the current limitations of public sector procurement processes which may present barriers to the prioritisation of sustainable procurement. This included a lack of resources and the system being heavily weighted towards the lowest cost option, among other things. It was felt that these issues would need to be addressed, and additional levers introduced (such as heavier weighting given to options that support circular economy practices), if circular economy principles were to form a more significant part of tendering exercises:

“Recognition that buying better quality, reusable items, can cost more which could be a barrier with tight budgets in LAs [local authorities]. Under current procurement legislation there is no mechanism for awarding locally (potential additional emissions).” (Organisation: Public Sector - Local Authority)

A few also felt that too much focus was given to recycling at this policy mechanism, and advocated for more emphasis to be placed on other aspects of the circular economy, such as reuse and repair.

In addition, a few respondents suggested that clear implementation timescales, guidance and capacity building may be needed for smaller suppliers to meet any new requirements. It would also be important to ensure that procurement processes were accessible to smaller providers and do not unintentionally favour larger suppliers.

Skills and Education

The skills and education policy mechanism was welcomed by most respondents. It was stressed that education on the circular economy should start in school, and be prevalent through all levels of education (including community based and life-long learning). Respondents wanted to see the circular economy and environmental issues embedded throughout the curriculum, as well as the provision of dedicated courses within further and higher education. The importance of education was highlighted, both in relation to driving behaviour change, and to develop the skills and workforce needed for a circular economy. However, a few organisations felt that greater emphasis was needed on the education element at this policy mechanism, specifically mentioning and focusing on children and young people, and the importance of education to embed knowledge among consumers, rather than simply aiming to develop skills for jobs in the sector. It was stressed that circular economy principles must be fully integrated into education and not treated as an add on:

“Sustainability should be positioned as an integrated element of curriculum rather than an add-on, with clear connections to learners’ personal and professional lives.” (Organisation: Academic)

Respondents also stressed the importance of other education and training environments, both formal and informal, which could develop skills for work and relevant life-skills. A few highlighted the need to create partnerships and support for employers to provide training, upskilling, and career development. Meanwhile, several called for greater recognition of community-based skills and training, as well as life-skills related to the circular economy (e.g. making repairs) and promotion of the ‘right to repair’:

“This is a welcome addition. It would be good to see recognition of green skills which are outside of the typical employability green skills agenda e.g. community-based skills and training which enables people to enact the circular economy in their everyday lives.” (Individual)

Several respondents also felt that the policy mechanism needed to explicitly mention jobs, the nature of ‘green’ or circular economy jobs, priority areas, and support for workers to retrain in sectors that experience change (in keeping with a just transition).

Circular Economy Data

Most respondents who discussed the data policy mechanism were supportive of it. However, the lack of robust data sources and data gaps needed to be addressed, with respondents also highlighting the need to tackle the levels of distrust in official statistics. It was stressed that good data needed to be collected and used to underpin the development of the circular economy, and that consistent and comparable data would be needed across sectors:

“Improved data availability is vital. We encourage collaboration with regional stakeholders to ensure data reflects rural contexts and supports local decision-making.” (Organisation: Public Body - Other)

Several also stressed that any data requirements needed to be proportionate, avoid duplication of effort, and consider cost implications:

“Improved data can support efficiency and investment, but reporting must be proportionate and avoid duplication with existing regulatory regimes.” (Organisation: Representative/Membership Body - Manufacturing)

In addition, several respondents highlighted that the policy mechanism only outlined data related to waste, which they perceived to have limited use. Rather, they advocated for the consideration of data related to other aspects of the circular economy. This included reuse and repair data; data on unsold goods; behaviour change data; skills data; carbon data; product level data; health impact data; and qualitative data. Several also called for benchmarking to be undertaken to measure Scotland’s progress against other countries:

“The current text…appears to focus on measurement of ‘waste’. Since the circular economy is about so much more than ‘waste’ we need to develop/adopt metrics which reflect the full spectrum of CE [circular economy] activity.” (Organisation: Private Sector - Other)

Mixed views were expressed about the packaging Extended Producer Responsibility (pEPR) scheme. Several respondents were supportive of this and felt it would bring improvements. However, others felt the current version was not ambitious enough and wanted the Scottish Government to expand this scheme beyond waste. A few described the current scheme as complex, confusing, and challenging, and noted that it had created additional costs for organisations. One respondent also felt that the financial benefits for Scotland were not clear (as this is a UK scheme).

Where digital product passports were discussed, most respondents were generally supportive. However, it was also stressed that these needed to be developed collaboratively with the waste and resource management sector, and that they would need to align with international standards (to avoid duplication and costs).

Policy Alignment and Systems Thinking

Most respondents who discussed the policy alignment and systems thinking policy mechanism strongly supported it:

“The Resource and Waste Management Sector is unique in that it touches every other key sector in Scotland. There is a significant opportunity to improve understanding, awareness, and practical action across different sectors by sharing communications more effectively, which can drive consumer and institutional change.” (Organisation: Representative/Membership Body - Waste)

Respondents wanted the strategy to stress the overarching significance of this. They felt that this approach would ensure that the circular economy was placed at the heart of all Scottish Government policies, and would be embedded across all policy sectors. It was important to ensure that it was not restricted to environmental policies alone. Alignment was also said to be needed between national and local government to ensure a common focus. In addition, alignment with UK, EU and international strategies and standards was also welcomed, as any deviation could result in complexity, duplication and additional costs:

“We welcome this policy direction and urge the Scottish Government to align Scotland’s circular economy plans with the UK Government and the EU wherever possible. Regulatory coherence reduces friction, enables investment, and accelerates adoption - strengthening Scotland’s leadership while ensuring compatibility across markets and supply chains.” (Organisation: Representative/Membership Body - Food & Drink)

However, a few organisations also cautioned that working together with the UK government should not be an excuse to delay or limit progress within Scotland where devolved powers allow.

Some organisations also expressed explicit support for a high-level, cross-sectoral Commission to oversee circular economy delivery and infrastructure planning.

Several respondents also wanted to ensure that this policy mechanism would mean that Scotland would not only align with other countries, but would also consider and learn from approaches in other countries:

“It makes absolute sense to align this strategy with other policy. I would also like to see the government looking to other nations to consider the circular approaches they are taking and learn from the systems they have created. This needs to be a global movement so joined up systems thinking is essential in ensuring that producers’ responsibilities are increased.” (Individual)

Several also stressed, however, that in certain sectors, existing regulations and safety standards could make adherence to a circular economy difficult or limited.