Circular economy strategy draft: consultation analysis

Priority Sectors

The consultation document identified five priority sectors for action, based on their potential contribution to reaching net zero, to reduce consumption and whole-life carbon, to maximise value and their wider environmental impacts. These included:

• The Built Environment;
• Net Zero Energy Infrastructure;
• Textiles;
• Transport; and
• The Food System.

Support for the Priority Sectors

Q7. To what extent do you agree with the priority sectors identified?

Respondents were asked to rate the extent to which they agreed or disagreed with the priority sectors identified. Just under three quarters (71%, n=119) respondents either agreed or strongly agreed, while 11% (n=18) either disagreed or strongly disagreed.

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

General Comments on the Priority Sectors

Q8. Do you have any comments on the priority sectors identified?

Roadmap Development

Roadmaps were largely welcomed, along with the commitment for these to be available within one year. However, as with feedback at other sections, it was felt that these needed to include clearer delivery plans. This included the need to consider resourcing; actions; outcomes; infrastructure investment; timelines; measurable targets; interim review points; and clear roles and responsibilities. It was also suggested that the roadmaps should be developed in consultation with industry, local authorities, the third sector and communities:

“[Organisation name] supports the priority sectors identified but stresses the need to work in partnership with stakeholders when developing roadmaps to improve circularity. Early consulting with stakeholders is essential.” (Organisation: Representative/ Membership Body - Food & Drink)

There were also a few organisations that suggested the roadmaps should be overseen by a new cross-sector circular economy task force (rather than Zero Waste Scotland (ZWS)). They argued that this would provide industry expertise:

“…sector roadmaps should be overseen by a new cross-sector circular economy task force rather than ZWS alone. Industry expertise is essential to ensure roadmaps identify the mechanisms needed to stimulate investment, create jobs, increase resource efficiency, reduce emissions and align economic growth with clean energy.” (Organisation: Other)

Additional Priority Sectors

There was extensive desire to see a wide range of other sectors included in the priorities. Plastics and packaging was highlighted most often, with the omission of this sector considered to be a significant gap. Indeed the exclusion of plastics and packaging as a priority was cited by many who disagreed with the priority sectors. It was also the key issue highlighted by campaign respondents. Several provided extensive feedback about the merits of including plastics:

“Most notably, plastics are not addressed as a priority, despite being a large source of waste across multiple sectors, particularly food packaging and consumer goods. In fact, the word plastic is not used a single time across the full strategy, which is a glaring omission. On top of many types of plastic being single-use and non-recyclable, plastics have well-documented environmental and health impacts across their lifecycle, from fossil fuel extraction and production to pollution, microplastics and waste management. Only considering plastics indirectly risks diluted action and little accountability. A stronger, explicit focus on plastics as a material and on finding alternatives across sectors is needed.” (Organisation: Third Sector)

Other sectors which respondents also frequently advocated for inclusion were the electrical sector/waste electrical and electronic equipment (WEEE)/digital infrastructure, and the chemicals sectors. In addition, several other sectors were highlighted for inclusion, with those outlined by more than one respondent being:

• Healthcare;
• Third sector reuse and repair, community projects, and grassroots movements;
• Manufacturing;
• Waste disposal and resource management sector;
• Single use products;
• Bio-economy; and
• Water and wastewater.

Several respondents also called for there to be greater alignment with the priority sectors in the forthcoming UK Circular Economy Growth Plan and Circular Economy Taskforce. It was felt this would allow change to happen at scale, and make it easier and quicker for sectors to shift towards circular models.

Other Feedback

Several respondents suggested ways that this section could be strengthened. Mainly they called for the provision of a clearer assessment of economic, social, workforce, international and environmental impacts/benefits. More detail was also said to be needed on the health and equity implications, the links between priority sectors and social inequalities, and for greater consideration to be given to a just transition. A few respondents sought clarity around why the different sectors had been identified as priorities:

“We agree that some prioritisation is required in the CES [circular economy strategy] but it is unclear why these specific sectors were chosen and what (or if) critical materials within each of those sectors is a focus. Are these mapped against greatest need for Scotland, the greatest untapped opportunity for Scotland, or for where there is the greatest negative environmental impacts?” (Organisation: Representative/Membership Body - Other)

Several also highlighted the lack of recognition for cross-sector approaches, and interdependencies or cross-cutting areas of delivery/business practices. It was felt that this could create limitations or silos, with respondents suggesting that greater consideration of this was needed:

“My concern here is a lack of recognition for cross-sectoral approaches. A key benefit of establishing a circular economy is the potential to share resources (materials and facilities but also knowledge) between sectors to create a truly circular economy. It would be of huge benefit for policymakers to include cross sectoral approaches in the vision going forward as this offers the scope for a truly circular economy.” (Individual)

It was also highlighted that the priority sectors may need flexibility built in, as a one-size-fits-all solution would not work. In particular, plans would need to recognise the unique challenges and opportunities in rural and island contexts. The strategy should also remain adaptive to emerging opportunities in other sectors, it was felt.

The Built Environment

Q8a. Do you have any comments on the plans and priorities for the built environment?

Many respondents set out their support for the inclusion of the built environment as a priority sector, and the commitment to engage with the sector to develop this. The commitment to regional reuse hubs was also widely supported:

“We strongly support the plans and priorities for the built environment, particularly the emphasis on reuse, refurbishment and retrofit, the recognition of buildings as long-term material stores, and the move towards circular design principles.” (Organisation: Private Sector - Manufacturing)

Some respondents felt that the plans for the built environment, however, would need to explore barriers (such as costs, supply chain limitations, and the skills gap), and develop mechanisms to tackle these. This would need to consider incentives and suitable tax regimes to support appropriate actions, as well as the provision of support for the industry. Specific measures which were suggested included the use of public procurement requirements; capital funding; guidance around building standards and sustainable construction, as well as whole-life carbon assessments; fast tracked planning and permitting for reuse hubs and other appropriate circular economy infrastructure; consideration of digital product passports; and the use of building regulations, and formal certified standards, benchmarks and product guarantees. In particular, it was suggested that support was required to build confidence in, and accelerate the use of, secondary and recycled materials across the construction sector, and to ensure change happened quickly and at scale:

“[Organisation name] emphasises the need for Scottish Government leadership to build confidence and accelerate the use of secondary and recycled materials across the construction sector. Stronger policy signals, clearer standards and streamlined planning processes will be essential to increase uptake at scale.” (Organisation: Other)

Another theme common across respondent types, was that the current draft focused too heavily on environmental impact, carbon metrics, and sustainability practices, and not enough on the design stage, circular behaviours and how these can be encouraged and supported. Respondents felt that there needed to be much clearer emphasis on durability and flexibility of use, remanufacturing, refurbishment, retrofitting and reuse of new builds or tear down and rebuild practices. Extending the life of existing buildings through repair, refurbishment and adaptive reuse should be key. Reuse also extended to both the reuse of buildings and materials.

It was also suggested that capacity building (and associated funding) would be needed across public bodies should new building standards be introduced. For example, to ensure staff had the required expertise in low-carbon materials, circular construction practices, material reuse, lifecycle assessments and embodied carbon calculations.

The use of whole-life assessments/carbon assessments was largely welcomed. However, several respondents also highlighted that this may have limitations in assessing the extent to which a building met circular requirements. It was noted that buildings can be low carbon but not circular in nature, while others that are more circular in nature may be higher carbon. This needed to be taken into account and appropriate strategies applied:

“The lifecycle assessments section brings in the reduction in embodied carbon benefits, but perhaps a point alongside this is the importance of designing for circularity; for longevity, flexibility, adaptability, repair and maintenance and also disassembly. A building can be designed and built to be low carbon but not be designed for circularity. Occasionally the two ambitions can be conflicting but they need to be considered systemically to deliver the best solution.” (Organisation: Representative/Membership Body - Built Environment)

Again, there were calls for greater details to be included around the application and delivery of the priorities. This included the need for specific actions, measurable targets, clarity of roles and responsibilities for different stakeholders, and how the different elements would operate in practice. Greater legislation and enforceable requirements were also said to be needed as voluntary actions would not be sufficient to drive change. However, a few were also concerned about the impacts of additional regulations and other changes which could result in increased costs within the house building sector, and could therefore exacerbate the housing shortage:

“The main way to ensure better circularity within construction is through legislation. For example, more stringent policies, oversight and accountability of reuse and recycling within the sector.” (Individual)

Other feedback provided by a few respondents each included:

• Learn from other parts of the UK, and ensure alignment and coordination across the UK;
• Desire for greater recognition and support for timber within construction, and inclusion/consideration of water/wastewater;
• The priorities, plans and roadmap should be designed in consultation with communities, workers and environmental groups, as well as industry, to ensure just transition principles are embedded;
• Provide a greater role for communities and the third sector in local planning and development;
• Consideration of home owners, including support to make homes more energy efficient, and tackling waste from household renovations;
• Need to more explicitly recognise rural resources and natural materials; and
• Give consideration to green space within the built environment.

Net Zero Energy Infrastructure

Q8b. Do you have any comments on the plans and priorities for the Net Zero Energy Infrastructure?

There was support for the net zero energy infrastructure roadmap to be designed in consultation with those in and representing the industry. Respondents suggested that this should seek to build upon existing work, to move beyond pilots, to incorporate wider engagement (with asset owners, supply chain members, cross-sector collaborations, communities, workers and environmental groups). It was felt that a clear business case and policy coherence with the UK and EU would be needed to ensure change happened at scale. Guidance and expectation setting from government would also be helpful. Respondents also felt it would be important to ensure that full lifetime considerations and circular principles were embedded in the design stage, and ran throughout the full lifespan of the infrastructure/materials:

“Circular economy principles should be embedded at every stage, from design and procurement to decommissioning, ensuring that materials stay in use as long as possible and that potential waste is minimised.” (Organisation: Third Sector)

However, there were concerns that the current draft risked large infrastructure projects becoming the focus, with smaller scale local projects being overlooked. It was suggested that more recognition was needed of micro-scale, community and place-based opportunities, and that support was needed for communities to become more energy self-sufficient:

“There is a significant opportunity to unlock local community energy projects, if the correct legislative, funding and support environment is created. There are currently significant obstacles in place for community energy projects and this should be addressed and supported here…” (Organisation: Private Sector - Other)

Several suggested that there was a need for a plan and recycling options for decommissioning infrastructure, components, and materials at the end of their lifespan. This was said to be particularly necessary for wind and tidal turbine blades and solar panels where reuse and recycling was currently problematic. It was also stressed that policy changes were necessary to support reuse and recycling within the wind sector as the current requirements and restrictions were prohibitive. It was felt this issue needed specific coverage within the strategy:

“While many turbine components are recyclable, wind turbine blades remain a significant challenge, and the logistical, technical, and economic implications associated with their collection, transport, processing, and recycling are substantial. These factors should be addressed explicitly within the plans and priorities to avoid burden shifting and to ensure that circular economy interventions in the energy sector deliver genuine, evidence-based benefits rather than assumed gains.” (Individual)

Again, there were several calls for clearer definitions; the use of standards, certification and regulatory requirements; the use of Environmental Product Declarations (EPD); funding/investment and incentives; timelines and measurable milestones; and the adoption of compulsory polluter pays principles to ensure consistency and accountability. A few also called for mapping of material flows and risks. In addition, some felt there was a need for greater emphasis on, promotion of, and support for repair, refurbishment, reuse, remanufacturing and recycling (not just decommissioning). To achieve this, it was suggested that support may be needed to improve market connectivity and link asset owners to reuse/ refurbishment suppliers:

“Clear standards, stronger end of life requirements and improved market connectivity will help maximise material value and retain economic benefits within Scotland.” (Organisation: Other)

Some respondents also wanted the strategy to prioritise and support Scottish/local supply chains covering all stages of the life cycle. This included initial production and installation, maintenance and repair, as well as end-of-life decommissioning, recovery, reprocessing and reuse infrastructure. It was argued that this would reduce transportation costs, support jobs, and benefit the economy:

“Scale domestic recovery and reprocessing: Support investment in facilities capable of reclaiming high-value materials from decommissioned assets, including wind turbine components. The strategy should move beyond ”recycling” and prioritise “repurposing”.” (Organisation: Representative/Membership Body - Utilities)

Other issues discussed included the need to:

• Consider links to education and training/skills for workers, as well as building links between industry, government and research institutions to progress R&D, innovation and new solutions;
• Support decommissioning, recovery, reuse and repurposing of the infrastructure from the oil and gas industry within the strategy;
• Consider the sectors demand for electronics and digital technologies, and include mechanisms for dealing with WEEE; and
• To consider water resource use.

A small number of concerns were also raised by a few respondents each. These included the potential for changes to result in higher energy costs, a lack of education and trust among the general public, and the potential for green washing. The lack of consideration of international impacts of Scotland’s energy sector and infrastructure was also considered to be a gap that should be addressed.

Many respondents also discussed net zero/green/renewable energy production and use, a just transition in the energy sector, and energy efficiency more generally, rather than circular principles within the infrastructure.

Textiles

Q8c. Do you have any comments on the plans and priorities for textiles?

Again, many respondents supported the inclusion of textiles as a priority sector, both due to its impact in Scotland and in the global south through manufacturing practices and second hand/waste clothing disposal. While there was support for the roadmap being designed in consultation with the sector, it was recommended that this needed to include a wide range of stakeholders, and not just industry/retailers. It was felt that some of the key issues (such as the need to reduce consumption, the development of a repair and reuse sector, and international impacts) were unlikely to be sufficiently considered otherwise:

“…we strongly encourage the Scottish Government to develop this roadmap in dialogue with communities, workers, environmental groups and international organisations. The circular economy strategy must take a just transition approach and this cannot be done if only business is involved.” (Organisation: Third Sector)

Most respondents discussed the need to tackle fast-fashion, and low-quality textiles, as a top priority. Key mechanisms for this, identified and supported by respondents, included: introducing legislation and product standards; reducing imports; introducing an import or carbon impact related tax; through consumer education/awareness raising; driving behaviour change; developing an enabling environment for repair and reuse; reducing/ending overconsumption; and adopting polluter pays principles, including product stewardship, the introduction of a dedicated EPR scheme, product passports, and takeback schemes. It was also suggested that the strategy needed to consider how to remove barriers to higher-quality and more sustainable textile options, such as cost and availability:

“Including textiles as a priority sector is sensible, but the current approach feels disconnected from the root cause - the rise of ultra-low-price, throwaway fashion. Scotland cannot achieve a circular textile economy while fast fashion remains so cheap, so accessible, and so poorly regulated.” (Individual)

However, a few respondents noted that it was difficult to define fast-fashion. A few others suggested that the global nature of the textile/fast-fashion industry meant that the strategy would be unlikely to have much impact.

Some respondents felt that there was too much focus on efficiency and recycling, and wanted greater emphasis and support to be placed higher up the waste hierarchy, for example, in relation to durability, rental and sharing, reuse and repair. Desired mechanisms to support these aspects included: the introduction of right to repair legislation; increased teaching of repair skills; clearer labelling (to include fibre content, environmental impact information, recyclability information and repair instructions); the development of reuse hubs and repair network; and for products to be designed to be more easily repairable.

Mixed views were provided about collection services for textiles. Individuals were generally supportive of this proposal. However, organisations across different sectors outlined problems and limitations with this approach. There was concern that collection services could encourage disposal rather than repair and reuse, and that consumption patterns would continue unchanged as the public would assume this collected material was being recycled. It was noted that items could get wet or contaminated during collection, and that reusable items were often included. It was also felt that such an approach could impact negatively on the charity shop sector by diverting reusable/resalable items away from them:

“Kerb side collection would have significant consequences for reuse ambitions and the third sector who deliver much of the current reuse of textiles within Scotland. In our experience of reuse organisations, there is a higher risk of contamination of reuseable textiles with kerbside/drop-off point donations; and the reuse market is already flooded with low quality discarded materials which can be conveniently and guiltlessly donated creating space for additional purchases.” (Organisation: Academic)

Several respondents also wanted to see greater consideration of the range of social and environmental harms, as well as international issues, such as human rights, labour conditions, unethical practices, pollution and other environmental impacts. There were also several calls to reduce/stop exporting recycling/waste overseas.

Respondents identified a need for investment in domestic infrastructure and markets to develop a textile industry which could accommodate the full lifecycle. This included the design and production process, repair and reuse facilities, and sorting and recycling facilities/markets. It was felt this would help local workers, local economies, and keep the value of materials in Scotland by not exporting waste/recycling materials overseas.

Several respondents suggested that a clearer definition of ‘textile’ was needed, and around what would be included. It was noted that different interpretations were used at various points throughout the strategy document, leading to confusion. There was also disappointment that the priority sector appeared to focus on clothing alone, with there being a desire for other textiles to be considered. In particular, respondents wanted carpets, curtains, bedding, etc. to be included, and links identified to other sectors, such as construction and the built environment.

Finally, other comments included:

• Support for alignment with UK and EU regulations, frameworks, strategies, EPR schemes, digital passports, etc.;
• A desire for guidance and refocused procurement across the public sector, health institutions, and educational institutions to deliver textile circularity;
• Need to consider uniforms and Personal Protective Equipment (PPE), which are currently difficult to recycle;
• Promotion of natural fibres and materials (e.g. wool, fleece, hemp, etc.); and
• Consider and tackle microplastics in textiles, chemicals and persistent organic pollutants.

Transport

Q8d. Do you have any comments on the plans and priorities for transport?

There appeared to be some misunderstanding around the intentions at this section, and/or conflation with modal shift and wider net zero transition ambitions. In particular, some respondents discussed the transport sector and transport provision/availability more generally, while others focused on the transition to greener/more sustainable transport options (discussing both measures to encourage this and barriers), rather than the circularity of the sector. There was also a perception that this section focused on electric cars, rather than electric vehicles (EVs) more broadly.

Those who did comment on the proposals generally expressed support for increasing EV battery repurposing, recycling and material reprocessing, and for alignment with both UK and EU regulations.

Some, however, felt that more emphasis was needed on demand reduction in order to reduce the number of vehicles being produced (i.e. to reduce material consumption). In particular, it was felt that the strategy should encourage modal shift to both public transport and active travel options; encourage vehicle sharing, such as car clubs, ride-sharing, and lift-sharing schemes; and workplace travel schemes. It was also suggested that the strategy should aim to achieve an overall reduction in total travel miles. It was stressed, however, that modal shift aspirations would require consideration of and improvements in the existing infrastructure, particularly (but not exclusively) in rural areas where a lack of public transport and active travel options was prohibitive:

“…there is limited consideration of demand reduction and shared transport as core circular strategies. While EVs are necessary for decarbonisation, a circular transport system must also prioritise reducing total vehicle numbers through better public transport, car sharing, active travel and goods transport. Without this, material demand for vehicles and batteries will continue to rise, undermining circular economy objectives even if recycling improves.” (Organisation: Third Sector)

In addition, respondents advocated for greater emphasis on improving maintenance and repair, reuse, repurposing and remanufacturing, as well as high-quality recycling of vehicles and components.

It was also noted that the strategy focused heavily on EVs, while respondents wanted a broader approach. In particular, it was felt the strategy needed to consider (and prioritise) public transport, including buses, trains, and ferries; hydrogen vehicles and other alternative fuel-based vehicles; aviation/planes; small boats; and community transport schemes.

There were calls for investment in Scottish/regional based infrastructure and facilities capable of transport related material recovery and recycling. This would reduce the need for long-distance transport and reliance on exports, and create local jobs. However, it would also require standards on the safe handling of EV batteries.

Several respondents suggested that the plans for EV batteries should be extended to incorporate other lithium-ion battery products. Respondents also expressed both support for, and the need for caution, in relation to repurposing EV batteries. It was said this could create safety risks and would require the ability to assess performance and remaining capacity:

“[Organisation name] have significant concerns regarding battery repurposing. When a battery is discarded, it is often because it has reached the end of its useful life for that application or because it is faulty. Distinguishing between the two can be extremely difficult. As a result, repurposing carries inherent risks: a reused battery may function as intended, or it may present a serious safety hazard.” (Organisation: Representative/Membership Body - Waste)

A few other issues were highlighted, with these being mentioned by just a few respondents each, including the need to:

• Consider the growth of electronics within vehicles, and therefore increased WEEE;
• Integrate circular principles within local transport plans and strategies;
• Clarify roles and responsibilities for product stewardship; and
• Consider impacts and potential unintended consequences on rural areas and rural businesses.

Finally, several respondents suggested that the strategy should consider how the transport sector intersects with, and could support circular efforts in other sectors, for example, the built environment, the food sector, etc. It was stressed that the transport sector could support a reduction in the carbon footprint of products by minimising transport requirements, while other sectors also impact on the type and level of transport that is necessary.

The Food System

Q8e. Do you have any comments on the plans and priorities for the food system?

Respondents were largely supportive of the identification of this sector as a priority. Several provided information about the range of actions already being taken within their business sector/sub-sector, or outlined highly detailed (and sometimes sub-sector specific) suggestions for additional actions that could/should be taken.

While there was support for the inclusion of the bioeconomy and the development of an associated roadmap, a few caveats were also outlined. It was stressed that the roadmap must clearly embed the food waste hierarchy, and that the roadmap should extend beyond considerations of the bioeconomy in order to drive circular change right across the food and drink sector. In addition, it was noted that progressive policy mechanisms would be required to deal with and prioritise competing land uses, e.g. between bioenergy, afforestation, peatland restoration, agricultural and food production, flood protection, nature restoration, etc.

Consistent with feedback at many other areas of the strategy, respondents suggested that many food waste measures would need to be mandatory rather than voluntary in order to have a meaningful impact. These would also need to be supported by investment and economic or other incentives to encourage engagement. Respondents suggested that any new measures should be co-designed with industry, be proportionate, and supported by practical guidance and funding. It was also argued that tackling food waste should extend beyond households to include education establishments, health care providers, workplaces, supermarkets/retailers, businesses, etc., as well as on-the-go food systems.

A key issue for respondents was for the strategy to have a greater focus on the circular treatment of unavoidable food waste. It was argued that there should be specific focus on composting, anaerobic digestion, and collection and processing to deliver “circular nutrients”. Measures would also be needed to reduce contamination of food waste in order to support effective recycling and composting.

Again, it was argued that the strategy needed to tackle overconsumption and emphasise demand reduction, not simply deal with waste. Respondents wanted consideration of and support for mechanisms that allow food to be reused or redirected rather than becoming waste, (for example, the redistribution of surplus food through food banks, community initiatives, too-good-to-go schemes, etc). There were also calls to consider ways that by-products could be valorised and used. In addition, several respondents suggested that supportive procurement frameworks, whole institution food strategies, menu design, and portion control measures would be helpful.

In addition to the food itself, respondents (particularly, although not exclusively, third sector organisations and individuals) wanted consideration of packaging within this section. This included measures to reduce or eliminate single use items, to move towards more sustainable packaging materials, and to encourage refill, return and reuse models. There was support for an enhanced EPR scheme in this respect. In addition, respondents also advocated for the consideration of other existing elements in the food system, including chemicals (in fertilisers, food production and packaging), water use, soils and soil quality, and the nitrogen cycle.

Mixed views were expressed regarding the exemption for rural food waste collection. Some supported a review or the removal of this exemption, while others supported a flexible approach noting distinct challenges of kerbside collection in certain areas, including that the environmental impacts of collection may outweigh any benefits, or that funding made rural collections prohibitive.

There were also mixed views about the proposal for mandatory reporting requirements for businesses’ food waste and surplus. It was argued that reporting requirements should align with established international frameworks to avoid duplication and stakeholder fatigue. There were also concerns around the proportionality of this, as well as the cost, resource and administrative burdens that such a requirement would bring. Several also felt that narrow reporting requirements would not drive change on its own, but that additional actions and a collaborative approach would be required. Others, however, were in favour of mandatory reporting, with a few suggesting this needed to be more robust. For example, it was argued that this should cover the full supply chain, including the agricultural sector, suppliers, etc., or could include a requirement to include a mandatory food waste prevention plan.

Respondents largely supported the need for consumer level behaviour change. Several argued that a circular food system and food waste issues needed to be embedded within education and training systems to encourage behaviour change, normalise circular behaviours, and produce an appropriately skilled workforce. Other suggested approaches to tackle behaviour change included national research, communications and awareness raising campaigns; the provision of clearer household guidance on the best food storage and disposal approaches; and education on how to tell if food was safe to consume beyond ‘use by’ and ‘best before’ dates. It would also be important to address barriers, including cost and encouraging loose item selling. In addition, a few respondents also suggested introducing more rigorous bin checks and training for collection crews to identify contamination, and penalties for improper disposal.

A few respondents felt there would be a need to deliver targeted support for SMEs, both to implement circular practices, and in terms of capacity building and resourcing any reporting requirements.

Local or place-based approaches were also supported. Respondents advocated for local supply chains and processing facilities to avoid transporting over large distances, and for local and regenerative food growing initiatives. It was felt this could provide an opportunity for upskilling local communities and workers, while focusing on large scale food systems risked undermining place-based approaches.

Several respondents suggested that the strategy should also consider wider issues. This included ensuring any changes tackled, rather than reinforced, food insecurity and inequalities. They also felt that it should explicitly consider the international impacts of Scotland’s food consumption, support for Fair Trade practices for both domestic and international products, and include health outcomes.

A few respondents called for more specific consideration of sub-sectors. This included marine, aquaculture and fisheries; agriculture and livestock farming; pub, distilleries and brewing; and commercial food processing. Others thought the strategy should be sub-divided by the different stages, including production, processing, distribution, retail, hospitality, consumption, and waste management.

There were also calls for the strategy to recognise existing work within the sector so as not to duplicate or undermine this. It was stressed there was a need for supportive regulations to deliver innovation and change, as well as UK wide alignment wherever possible.