Circular economy strategy draft: consultation analysis

Monitoring and Indicator Framework

The draft strategy also set out the first national-level monitoring and indicator framework specifically for the circular economy. It set out how the Scottish Government would measure high level progress, taking into account a wide range of factors and influences.

General Changes or Additions

Q10. Are there any changes or additions that you would like to suggest in relation to the Circular Economy Monitoring and Indicator Framework to ensure it is fit for purpose?

Respondents were asked to indicate whether there were any changes or additions they would like/suggest in relation to the Circular Economy Monitoring and Indicator Framework to ensure it was fit for purpose. Of those who answered the closed element of this question, around three quarters (76%, n=110) said there was.

Q10. Are there any changes or additions that you would like to suggest in relation to the Circular Economy Monitoring and Indicator Framework to ensure it is fit for purpose?

	Number	Percentage
Yes	110	76%
No	34	24%
Total	144	100%

Note: a further 46 respondents did not answer the closed question.

In addition to the closed question, respondents were also asked to detail any comments they had about the monitoring and indicator framework in general, with subsequent questions focused on each of the outcomes in turn. These comments were not restricted to only those who stated above that they had suggestions about changes or additions to the indicators, with 151 respondents, plus 1,270 campaign respondents, providing comments across the nine questions asked in this section, with many responding to more than one question.

Additional Indicators Needed

Many (of the 151) respondents felt that there was a need to recognise and include a wider range of indicators.

In particular, it was suggested that the framework should include more societal measures and factors. These were wide ranging, but the most often cited elements included community engagement (with a few suggesting that ‘levels of engagement’ was preferable to ‘access to’ circular options); work by SMEs, charities and social enterprises; the longevity and sustainability of circular initiatives; life skills not linked to employment in the sector; education, training and skills programmes; workforce impacts; capacity building; place-based, regional and local contributions, as well as community wealth building; and monitoring of impacts such as fairness, inclusivity, inequalities/equalities, and on poverty and health. It was also suggested that qualitative methods may be required to effectively assess progress:

“…the Circular Economy Monitoring and Indicator Framework would be strengthened by placing greater emphasis on education, behaviour change and cultural transition alongside material and economic metrics. While measuring waste reduction, resource efficiency and sector performance is essential, we would suggest the addition of indicators that capture learning, awareness and stewardship outcomes - such as levels of circular economy understanding, participation in education and community programmes, and shifts in attitudes and behaviours over time. Including qualitative and social indicators would help ensure the framework reflects the reality that a circular economy is enabled by people as much as systems...” (Organisation: Third Sector)

Other indicators flagged for inclusion (by several to a few respondents) were: measures of material consumption/material footprint; carbon emissions/carbon footprint; durability, reuse, repair and remanufacturing rates; the production, use and disposal of plastic/ packaging; littering; expanding the focus beyond ‘circular start-ups’ to include existing organisations; sector specific indicators and measures (including additional sectors outlined in the chapters above); procurement; and learning, testing and progression. A few also stressed that rural economies needed to be included and reflected, and that data should allow suitable disaggregation to ensure progress in remote, rural and island locations can be tracked. Additional international measures were also said to be needed, both in terms of social, environmental and human rights impacts, and measures for international products:

“As currently framed, many proposed indicators appear weighted towards waste generation and recycling performance; while important, these are insufficient proxies for circularity and should be complemented by measures that capture upstream interventions and value retention.” (Individual)

Respondents also advised that indicators and reporting frameworks should align to other policy areas, plans and strategies. It was also important for these to align as far as possible across the UK, the EU, and internationally.

Concerns

Again, several respondents and most of the campaign respondents stressed the need for measurable goals, timebound (and in some cases, statutory) targets, and interim milestones. A few respondents were concern that, despite collecting lots of data, the framework would not effectively measure outcomes or change, while campaign respondents felt that the strategy would be ineffective without measurable goals:

“Without setting measurable goals, the strategy is empty words.” (Campaign Responses)

“The framework as it stands appears overly data-driven and detached from real-world performance. The danger is that it becomes another exercise in counting outputs rather than measuring outcomes. What matters is delivery, not documentation - yet the framework currently measures things that are easy to quantify (like recycling rates or resource use) rather than the quality of change happening on the ground.” (Individual)

Several respondents were also concerned that there was a disconnect between the indicators in this section and the rest of the strategy. In particular, it was felt that the indicators did not link to the policy mechanisms, meaning that either certain indicators were unlikely to be achieved, or that certain policies were unlikely to be prioritised. It was also considered to be difficult to determine whether the indicators would be appropriate in measuring change without details around the actions, delivery mechanisms and pathways that were perceived to be missing from the rest of the strategy.

Concerns were also raised over the consistency and comparability of the data. For example, the use of definitions that were open to interpretation, or that the definitions and possible measures of a circular economy may change over time, making it difficult to consistently track and compare progress. However, several respondents also recommended that the indicators, measures and datasets should be reviewed and updated periodically to ensure the most up-to-date and relevant aspects were included. Some respondents advised that the framework should be designed in consultation with industry, local authorities, the third sector and other stakeholders to ensure the indicators were practical, appropriate, and meaningful.

There was a desire among some for publicly available progress reporting to be a requirement. This included support for Scottish Government level reporting as well as more regional/local level reporting. However, some organisations were concerned about the additional burdens that may be placed on them/their sector to collect and report on the required data (particular concerns were expressed for impacts on SMEs). It was noted that such requirements could mean that new administrative and reporting systems would be needed, resulting in capacity and cost issues. As such, these respondents called for engagement with the relevant sectors to ensure any data/reporting responsibilities would be manageable and proportionate, the streamlining of requirements, and/or the provision of additional support and resources for those responsible.

A few respondents (including individuals and organisations) felt this section was too high level, too technical, and too difficult to understand. There were concerns that it would be difficult to provide an informed response, and that there would be a lack of engagement (and therefore impact) as a result.

The following sections set out the feedback provided at the eight questions which focused on the indicators for each of the outcomes in turn. It should be noted that lower numbers of respondents answered each of these eight questions compared to those above. This ranged from a maximum of 86 respondents at Q10c to a minimum of 59 respondents at Q10f.

Economy Outcomes

The economic value derived from material use is maximised without increasing our environmental impacts

Q10a. Do you have any comments in relation to the indicators proposed for outcome “The economic value derived from material use is maximised without increasing our environmental impacts”?

The draft strategy proposed the following indicators for this outcome:

• GVA of circular economy sectors;
• Resource Productivity and Material Intensity; and
• Labour productivity of CE jobs.

Respondents suggested a large number of additional indicators, or topics that they felt the indicators should focus on to monitor progress at this outcome.

It was felt that the indicators needed to consider all aspects of the circular economy and track the extent of and value generated through reuse, repair, sharing, refurbishment, and remanufacturing. There were also several suggestions for indicators which considered total material use, however, there was a desire for this to be nuanced and to distinguish between desirable and undesirable economic activity. It was said to be important to differentiate secondary materials, regeneratively grown, and virgin materials, and to recognise by-product value. Other suggested indicators mentioned by more than one respondent included: production levels (noting that productivity improvements may result in increased production which may not be desirable); levels of local materials, imports and exports; public procurement measures; measures which consider the whole life cycle or use a ‘cradle-to-grave' rather than ‘cradle-to-gate' matrix; and over production and overall consumption levels (with a drive to reduce these).

Several suggestions also related to monitoring and tracking work related factors. This included the number of start-ups, scale-ups and new companies in the circular economy sector; capturing investment flows and innovation; job and voluntary position creation; fair work outcomes; and the growth of community owned or social enterprises in circular sectors.

In addition, it was felt that indicators were also needed to capture more local, place-based and smaller scale circular economy impacts. Suggestions included monitoring resource inputs; local material loops; local environmental gains; the diversification and resilience of the regional economy; community participation; affordability and local resilience; and community wealth building. It was suggested that case studies and qualitative data may also be useful in assessing small-scale and local impacts.

It was also suggested that certain key sectors should be explicitly considered. These included each of the priority sectors (and their relevant sub-sectors), as well as plastic, litter, chemicals, land-based sectors, data centres, and by activity type (e.g. reduction, reuse, repair versus recycling and waste management).

There was concern that the proposed indicators did not tackle the second part of the outcome, i.e. how to measure any changes in environmental impacts:

“…it is not yet sufficiently clear how the proposed indicator set tests the condition “without increasing our environmental impacts.” In practice, increases in material productivity or economic value can coincide with stable or rising environmental pressures if absolute material throughput grows, if impacts are displaced through imports, or if value growth is driven by more resource-intensive activities.” (Individual)

As such, respondents felt there was a need to include indicators to consider absolute material footprint; absolute lifecycle greenhouse gas emissions/carbon footprint; material throughput; and total waste generation. It would also be important to consider and measure any rebound, leakage and displacement. Respondents also advocated for environmental impacts to be considered on a global level, and not restricted to those within Scotland. There were suggestions for indicators focused on social and human rights impacts, labour conditions, impacts in global supply chains, the use of ethical and Fair Trade practices, and responsible procurement. One organisation suggested tracking the ‘economic value-to-environmental cost ratio’ for specific, harmful products, as well as the ‘cost of harm’, including environmental and health related harms.

A few organisations outlined perceived limitations with the proposed indicators. The ‘labour productivity of circular economy jobs’ was flagged as problematic as it was currently very difficult to identify which jobs would be in scope. A few were also unclear how this metric linked to the measurement of economic value. It was also highlighted that the informal nature of certain reuse markets meant it would be almost impossible to measure/quantify the economic value and reuse rates.

In addition, a few organisations were against the objective of maximising economic value and argued that the focus should be on maximising social value instead. A few third sector organisations also wanted the outcome to be more ambitious and reference reduced environmental impact rather than not increasing the impacts.

A few organisations also had concerns over the cost and administrative burden of collecting the required data, and how the indicators would be translated into greater understanding and action. In addition, a few organisations felt that this section provided only very high-level information and suggested that greater clarity and detail was required to determine whether the indicators were fit for purpose:

“At present, there is insufficient detail on what will be measured, how indicators will be defined, and how they will collectively demonstrate progress against both the economic and environmental dimensions of the outcome. Without clearer explanation of the intended metrics, baselines, methodologies and links to policy interventions, it is difficult to determine whether the indicators will accurately capture changes in material productivity, value creation and environmental impact.” (Organisation: Public Body - Local Authority)

Other comments offered by a few respondents each included:

• Monitor who benefits from the maximised economic value created by the circular economy;
• Monitor how much of the economic value is retained in Scotland or regionally;
• In the early and transition stages the circular economy may be more expensive than linear models, with performance improving over time; and
• Caution was needed as there would always be some environmental impact.

The Scottish economy is more resilient to disruptions in global supply of materials, including critical raw materials

Q10b. Do you have any comments in relation to the indicators proposed for outcome “The Scottish economy is more resilient to disruptions in global supply of materials, including critical raw materials”?

The draft strategy proposed the following indicators for this outcome:

• Resource resilience ratio;
• Material intensity of trade flows (trade value indicator); and
• Resource resilience ratio of critical raw materials.

Individuals largely outlined either their support or disagreement with the outcome, rather than commenting on the monitoring and indicator framework to support it. Several individuals and organisations also commented on the perceived achievability of the outcome and practical support needed to achieve delivery.

Respondents largely felt that the proposals focused on external vulnerabilities but did not give sufficient consideration to domestic capacity and local level resilience. As such, many advocated for the inclusion of indicators which considered local, regional and domestic supply chains, including locally grown/sourced materials, and local/domestic production, manufacturing, processing and reprocessing capacity. They also advocated for consideration and tracking of the use of raw, regenerative, and secondary/reclaimed materials (i.e. reused, repaired, refurbished, remanufactured, and recycled) sourced locally/regionally/domestically. Key elements/indicators which could be useful in this respect included: the development and growth of local supply chains; the diversity, flexibility and adaptive capacity of local supply chains; reuse, repair, and remanufacturing capacity and diversity of activity; domestic substitution rate; locally available resources and skills; fair work outcomes; local economic retention; number of community owned or social enterprises in circular sectors; and the number of 20 minute neighbourhoods:

“Indicators should move beyond mapping supply risks to measuring actual reductions in vulnerability, for example through increased reuse, repair, remanufacturing and substitution of critical materials. Tracking absolute reductions in reliance on virgin and imported critical raw materials, alongside growth in secondary material use, would provide a clearer measure of resilience.” (Organisation: Other)

A few organisations recommended that the indicators should also specifically track rural and island exposure and resilience, by monitoring local sourcing, reuse, and remanufacturing capacity in rural and island areas.

Several other specific indicators were also identified, often by one or two respondents each. These included: dependency ratios on imported materials or foodstuffs; speed and scalability of circular solutions; cost avoidance through reuse of materials; growth and distribution of employment; export potential and actual export levels; the proportion of raw materials replaced by recycled inputs; identification of critical raw materials; financial resilience; critical material recovery capacity; explicit “import material footprint” indicator; participation of SMEs and social enterprises in secondary material flows; factors to monitor durability and reduced dependency on repeated material supply; and considerations around climate change risks.

Several respondents also wanted international factors and dependencies to be explicitly recognised. This included tracking where critical materials were sourced, processed, and refined, as well as considerations of geopolitical and trade exposure. Third sector organisations also argued for this section to give greater consideration to the international impacts of Scottish consumption. They argued for measures to reduce consumption in order to protect ecosystems and avoid shifting harms to other regions. It was felt that consideration also needed to be given to the social and environmental impacts of sourcing materials internationally, consideration of labour conditions and human rights, environmental impacts, ethical procurement and Fair Trade practices.

A few again suggested that the focus should be on priority sectors (particularly on food, construction, and renewables/energy), with sector specific indicators provided - although one organisation did note that this may limit understanding of dependencies in some areas/sectors. A few third sector organisations also suggested that mineral specific indicators would be needed, to include transition minerals and problem materials.

Several respondents also outlined perceived challenges or limitations at this section. A few felt that the issues would be difficult to measure and assess with accuracy, and that the indicators could present challenges for those responsible for collecting the required data. Several cautioned that, realistically, Scotland (and the UK) could never be fully self-sufficient and would need to continue to rely on some imports. It was also suggested that this section could be strengthen by the provision of clearer definitions, clarity around scope, greater context, and information around how the indicators would be benchmarked:

“It is not clear in this statement where we are most vulnerable and whether the priority sectors are aligned and match against those vulnerabilities? How realistic is it to be ‘self-sufficient’ - what volumes are needed? Is there sufficient scale? Where can circularity have the biggest impact? Where can it reduce reliance on imports and use of problematic materials?” (Organisation: Representative/ Membership Body - Other)

Business and entrepreneurs have opportunities to develop circular economy innovations

Q10c. Do you have any comments in relation to the indicators proposed for outcome “Business and entrepreneurs have opportunities to develop circular economy innovations”?

The draft strategy proposed the following indicators for this outcome:

• Number of CE patents (technology, product design); and
• Number of circular startups.

Again, several respondents focused on the support that would be required to deliver the outcome, rather than providing feedback on the indicators.

The two draft indicators, while considered useful, were also largely considered to be limited. It was noted that patents would not capture the full range of innovations, typically excluding service, process, organisational, and business-model innovation, as well as open source innovations. In addition, patents were unlikely to capture innovations by SMEs. In relation to counting the number of start-ups, respondents noted that this would exclude progress, changes or innovation made by existing businesses, as well as those in the third sector, social enterprises and community organisations. Simply counting the number of start-ups would also not consider the longer-term performance or viability/survival rates of these start-ups, with respondents noting the low rate of start-up survival beyond three years. The focus on innovation and start-ups was also considered to prioritise the wrong aspects. Instead, it was noted that large scale transition to a circular economy was more likely to be achieved through mainstream adoption of circular practices among existing businesses, and therefore, this area should be the main focus of indicators and measures. Ultimately, most respondents recommended that a broader set of indicators were required.

Several other issues were also highlighted. It was suggested that indicators needed to be designed to ensure different sectors, regions and sizes of businesses were visible, including reflecting rural and island areas. There was also a need to consider the role of education and skills in driving innovation. Further, it was suggested that the focus on innovation needed to prioritise applied innovation which made an impactful difference and could deliver change at scale.

A wide range of other potential indicators were suggested. Several of these focused on measures that would capture how existing businesses (including but not limited to SMEs, social enterprises, and community businesses) were adapting their operations and business models to embed circular principles and practices. Several also wanted consideration of the formation, growth and viability of reuse, repair, sharing, remanufacturing and reprocessing services. A few also called for consideration of:

• Business expenditure on R&D related to circular economy activity;
• Employment levels, job creation and skills generated by circular business development, as well as levels of participation in training, support and advisory programmes; inclusion of demonstrator projects;
• Growth (e.g. turnover) across existing and new companies;
• Business impact, including economic returns, survival rates, and the ability of innovations to scale and remain viable over time; and
• Collaboration and cross-sector partnerships, including between business and research institutes.

Other indicators, typically mentioned by one respondent each, included: the number of SMEs supplying public bodies through circular or sustainable contracts; substitution of virgin inputs; workflow redesign; the scale of market uptake for circular products; reduction in business waste; whether circular ideas were being adopted and sustained locally; and to track innovations that reduce environmental and social harm across the full lifecycle of products, including overseas.

In addition to the indicators above, some respondents also suggested that there should be consideration and measurement of the support provided to transition to circular models and/or to innovate. Many of these respondents suggested measures related to the financial support provided, such as the amount of public and private sector funding or grants made available (including but not limited to research grants and R&D funding). Both the extent of the financial support provided, and the number and nature of those it was awarded to should be monitored. In addition, it was suggested that indicators should also monitor procurement, considering both the removal of procurement barriers and the share of public procurement which supported circular products/services. Other indicators focused on the provision of support, mentioned by just one respondent each, included: support for scaling and replication; access to testing environments and pilot pathways; the availability and uptake of business support and skills development; and support provided by public bodies like Zero Waste Scotland.

A few respondents also suggested it was important for the indicators to consider where businesses were located/owned, where the profits would flow to, what the direct benefit would be for Scotland. It was important to support inward investment to Scotland. Several also advocated for the data to be robust enough that it could be disaggregated by organisation sector, size, type and region ensure all groups were being recognised, and that opportunities were fairly distributed.

A few also advised that a clearer scope and definitions would be needed to ensure the data collected against the indicators was comparable and in-scope.

Environment Outcomes

Non-renewable resource extraction is minimised and renewable resource use is sustainable

Q10d. Do you have any comments in relation to the indicators proposed for outcome “Non-renewable resource extraction is minimised and renewable resource use is sustainable”?

The draft strategy proposed the following indicators for this outcome:

• Raw Material Consumption (RMC);
• Raw Material Inputs (RMI);
• Circular Material Use Rate (CMUr);
• Recycling rate (Sub-indicators); and
• Natural resources index.

Several respondents felt that the indicators for this outcome would benefit from greater clarity and rigour to ensure they reflected the quality and appropriateness of resource use, as well as absolute reductions, and not relative efficiency gains or substitutions. It was suggested that the indicators needed to clearly distinguish between renewable and non-renewable resources, take account of their impact and realistic circular potential. Without such clarity, there was a risk that circularity would be assumed rather than achieved:

“In practice, sustainability depends on how renewable resources are sourced, processed and returned to the system. Simply replacing non-renewables with renewables does not guarantee positive outcomes if it increases pressure elsewhere or removes materials from local cycles. Indicators that recognise regenerative use, local sourcing, reduced inputs such as water and energy, and materials designed to return safely to natural systems would better reflect sustainable circular practice.” (Organisation: Private Sector - Food & Drink)

There was also a perception among some respondents that the indicators focused too heavily on material extraction, and not enough on other circular principles. It was suggested that additional indicators were needed to provide consideration of refill, repair, reuse, repurpose, refurbish and remanufacture, as well as demand reduction/reduction in resource/material use. It was also perceived that the proposals focused primarily on industrial materials and did not adequately reflect (local) renewable resources.

A few respondents wanted separate indicators for each material, product, or sector. It was felt this level of monitoring would be helpful in determining where targeted improvements could be made:

“Given the extreme diversity of raw materials used in the economy, each of which have their own economic role and environmental impact, as well as the difference in scope for increasing the recycling rate for different raw materials, raw material consumption and inputs, as well as the recycling rate and circular material use rate, should be calculated separately for each material.” (Organisation: Representative/Membership Body - Other)

Many respondents set out additional indicators which they wanted to see included. These were highly varied and often unique. General themes, or indicators mentioned by more than one respondent are outlined below:

• The food system and plastics;
• Add an “avoided virgin extraction” metric for C&D recycling;
• Measure composting/use of compostable alternatives;
• Integrate wider impacts and outcomes, such as community, social and health;
• International indicators;
• Biodiversity impacts, natural world protection and regeneration;
• Reflect the rural supply chain, including recognition of local renewable resources, agriculture and land-based sectors, and natural materials; and
• Reflect whole-life assessments.

A few respondents questioned the terminology and felt that clearer and unambiguous definitions were needed. For example, what would be considered ‘sustainable’ and ‘minimised’, what would constitute a ‘non-renewable resource’, and how would circularity be understood and measured? Others queried whether the objective was measurable, whether/how specific indicators would be measured, and how available and accurate the required data would be. A few also sought clarity over the data and reporting requirements, in particular roles and responsibilities for collecting the necessary data, the extent of reporting requirements, and reassurance that data would allow regional/local disaggregation.

Again, respondents advocated for the indicators to be supported by clear thresholds, targets, timelines, milestones, reporting and accountability to allow scrutiny, progress monitoring, and adjustment where required. Respondents wanted the indicators to drive change towards a more sustainable or circular future, however, a few felt the current proposals did not achieve this.

The negative environmental impact of our production, consumption and disposal is minimised

Q10e. Do you have any comments in relation to the indicators proposed for outcome “The negative environmental impact of our production, consumption and disposal is minimised”?

The draft strategy proposed the following indicators for this outcome:

• Total waste (Sub-indicators);
• Emissions from waste;
• Carbon Intensity of Materials; and
• Global biodiversity impact.

Overall, respondents were largely supportive of the indicators proposed at this outcome, but many wanted much wider consideration of the issues. This included consideration of wider environmental, biodiversity/natural environment, and health related impacts, as well as greater consideration of other parts of the waste hierarchy, and wider international impacts/considerations.

Respondents suggested that the indicators should consider and track both raw waste and residual waste, and disaggregate between what waste could have been avoidable/recycled and the element of waste/ emissions that is not avoidable. Respondents also advocated for the indicators to focus on absolute reductions in environmental harm rather than relative improvements or per unit of output. There was also support for whole-life environmental and carbon indicators. Other suggested indicators (mentioned by just one or two respondents each) included: focusing on waste prevention and reduction rates; procurement choices; contamination rate, capture rate, and residual waste per household; and proportion of waste managed within Scotland.

Some respondents wanted the indicators to go beyond carbon and biodiversity measures and include a much wider range of indicators to understand the full environmental impacts. The suggestions were varied by those mentioned most often included:

• Water related indicators such as water use, water stress, water pollution, and water-based ecosystems;
• Air-pollution/air quality;
• Toxicity-related indicators, including hazardous waste generation and treatment, and exposure to hazardous substances;
• Litter, fly tipping and spillages;
• Health related indicators; and
• The natural world and regeneration, such as measures of greenspace per capita, the use of a “nature pressure/nature positivity” proxy indicator, and consideration of land use change;

A few respondents also suggested that the indicators should include a focus on the positive environmental impacts of circular practices.

Several respondents felt that the indicators needed to include more focus on preventative measures higher up the waste hierarchy. This included indicators to encourage and track reduced levels of disposal; waste prevention, reuse, and repair rates; consideration of modular, higher quality, repairable designs; and measures related to the transport of recovered materials:

“Indicators that focus only on waste management risk missing opportunities earlier in the system, such as redesigning products, rethinking how materials are used, and supporting circular practices that reduce inputs like water, energy and transport in the first place.” (Organisation: Private Sector - Food & Drink)

Again, respondents called for greater consideration and monitoring of environmental and social harms occurring outside Scotland. Suggestions included consideration of the global footprint; ecosystem degradation; deforestation; habitat loss; biodiversity loss; water stress; labour exploitation and unfair trade practices.

Consistent with several of the outcomes above, several respondents again called for the indicators (or sub-indicators) to include sector specific considerations. Those highlighted for consideration were the food system and food waste; chemicals (including PFAS); plastics and microplastics; textiles/clothing; construction; transport; agriculture; and electronics.

Respondents also wanted data to be captured in a way that allowed it to be disaggregated at different levels. For example, local, regional and national levels; by geography and deprivation; and by sector.

Concerns were also raised by a few respondents that the indicators appeared to promote ‘business as usual’ but with a less negative environmental impact. They felt they would not drive change towards a more circular system. A few were also concerned over the likely/expected data accuracy. There were suggestions that the indicators would need to be supported by standardised systems and data, as well as stronger, more practical tools for accurate measurement and comparison. Baseline data was also said to be required. Again, a few noted that the indicators would need to be supported by clear targets, timelines, transparent reporting, and accountability.

International Outcome

The negative impacts experienced internationally from production, consumption and disposal are reduced

Q10f. Do you have any comments in relation to the indicators proposed for outcome “The negative impacts experienced internationally from production, consumption and disposal are reduced”?

The draft strategy proposed the following indicators for this outcome:

• Carbon footprint of managing Scotland’s waste outside of Scotland;
• Overseas emissions ratio; and
• Proportion of Scottish waste managed within Scotland.

While most respondents were highly supportive of this objective, several were concerned that international markets could impact on deliverability of the strategy. For example, reuse and recycling processes may take place overseas, international markets/standards may impact the use of renewables, or make it difficult to tackle issues in certain sectors, e.g. the import of fast fashion. As such, a few suggested that the international impacts and indicators would need to be highly sector specific. A few were also doubtful about the extent of change that Scotland could make to international impacts due to the disparity in Scottish versus global consumption.

Many respondents suggested additional indicators which they thought should be included. In general, respondents wanted the indicators to reflect production, consumption and displacement impacts, not just waste disposal. Many of the suggested indicators were identified by just one respondent each, but those mentioned more often included:

• Food specific metrics;
• Material footprint;
• Waste displacement;
• Consumption emissions and the carbon footprint of imported goods;
• Levels of material exports;
• Supply chain metrics (particularly recognising shorter/local supply chains, greater self-sufficiency, exposure to high-risk supply chains, and traceability of imported and exported goods);
• Imported quarry products share;
• Embedded biodiversity risk index for imported materials; and
• Metrics to measure export of waste and reuse levels.

In addition, while there was support for the ‘overseas emissions ratio’, it was also suggested that the indicators needed to consider other environmental impacts beyond carbon. Further, some respondents suggested a much wider range of indicators were required. Key areas to focus on included environmental due diligence; social, economic, health, and human rights impacts; labour conditions; ethical trade practices; and educational factors. A few also highlighted the need to accurately track recycling exports (such as textiles and tyres) to the global south to understand (and reduce) the volume that becomes waste upon arrival.

Again, a few respondents outlined the practical elements that they perceived would be required to support the outcome. This included investment and infrastructure, greater reuse levels, the use of clear targets, and regular reporting, transparency and accountability.

Social Outcomes

People and communities engage in and benefit from circular activities in a fair and inclusive way

Q10g. Do you have any comments in relation to the indicators proposed for outcome “People and communities engage in and benefit from circular activities in a fair and inclusive way”?

The draft strategy proposed the following indicators for this outcome:

• Jobs in CE sectors: total; and
• Population with access to circularity options (e.g. reuse/repair services).

While most respondents supported the outcome and proposed indicators in principle, and several expressed explicit support for the draft indicators, there was a strong sense among respondents that these needed to be strengthened and expanded.

One of the main suggestions was for the indicator on access to circular options to be expanded to consider levels of engagement and participation with the circular sector. It was argued that having access to such options was not the same as uptake, and that the indicator as drafted would not provide any understanding of the impact of circular options:

“Having access to activities is not a measure of whether they engage with them and whether they drive behaviour change and offer benefits socially.” (Individual)

“…we believe the proposed indicators should more clearly reflect lived experience, access and local benefit. We recommend that indicators go beyond participation numbers to capture who is benefiting from circular activities and how. This should include measures of access to repair, reuse, sharing and recycling services, particularly for low-income households and marginalised groups.” (Organisation: Third Sector)

A wide range of additional indicators and measures were suggested to support the widening of this aspect. Mainly, these sought to focus on the accessibility, affordability and convenience of circular goods and services. It was suggested that tracking the growth in the reuse, sharing, maintenance and repair sectors would be valuable, as well as measures focused on uptake, such as volume or household spend. Respondents also advocated for the use of indicators focused on community wealth building, community asset transfer, and social value within this section, as well as recognition of community-led and voluntary sector activity.

A few respondents advocated for indicators which focused specifically on the food sector. Suggestions included: number of community food growing spaces and participation rates; as well as access to and numbers using food redistribution programmes, community food initiatives, food banks and community fridges.

When considering the indicator focused on jobs in the circular economy, respondents again suggested that a wider set of indicators would be required to provide meaningful measures that could be linked back to whether this was fair and inclusive. They recommended consideration of wages, working conditions, job security, skill level, and fair work principles. A few also flagged the importance of including volunteers working within the circular economy. One third sector organisation also suggested monitoring the ratio of men to women working in the circular economy (paid and unpaid). In addition, it was suggested that the indicators should also track the number of jobs displaced or lost elsewhere as a result of the circular economy transition.

A few respondents also highlighted limitations of the proposed jobs related indicator. It was noted that it was currently very difficult to identify the circular economy sector/relevant businesses, and therefore it would be difficult to ensure accuracy around the number of jobs within the sector. It was also felt that some workers would not be easily identifiable, e.g. those who work in sectors not typically considered part of the circular economy but who adhere to circular practices.

In addition to considering jobs in the circular economy, several respondents also recommended that the indicators should consider education, training and skills opportunities. This could include the number of people engaging/benefiting from these, as well as their impact. It was also suggested that this gather data on the diversity of learners engaged with such education/training, as well as workers and those in organisation governance structures.

Further to the considerations above, it was also suggested that the indicators needed to be expanded to assess whether the circular economy provided benefits in a ‘fair and inclusive way’. Indicators should consider whether circular economy initiatives had reduced living costs; reduced inequalities or poverty; brought improvements in diversity, equality and inclusion; improved housing quality or brought buildings brought back into use; supported cleaner local environments; and delivered health and wellbeing impacts. One individual also recommended monitoring income streams from community ownership or part-ownership, and the percentage of profits which remained in the local community and within Scotland.

As at other questions, a few respondents advocated for:

• The disaggregation of data by priority sectors; geography, including urban, rural, remote and island areas; level of deprivation (e.g. SIMD); and income;
• The inclusion of international indicators to consider global supply chains and waste flows. Specific suggestions included fair work and non-exploitative practices; ethical and Fair Trade supply chains; and awareness and adoption of socially responsible consumption behaviours;
• Clarity around data collection and reporting roles and responsibilities; and
• Clear definitions.

A few also stressed the need to consider rural and island situations, challenges and barriers to participation when determining definitions and measures/indicators, particularly in relation to “access to circularity options”:

“[Organisation name] recommends ensuring that the indicators also reflect the unique challenges and opportunities facing rural and island communities, including access to repair and reuse services and the important role played by social enterprises.” (Organisation: Public Body - Other)

Circular behaviours are the norm across business and society

Q10h. Do you have any comments in relation to the indicators proposed for outcome “Circular behaviours are the norm across business and society”?

The draft strategy proposed the following indicators for this outcome:

• Household spending on product repair, maintenance and reuse services;
• Societal behaviours for a Circular Economy; and
• Business behaviours for a circular economy.

Again, several respondents outlined their support or disagreement with this outcome, or proposed enabling factors or support which they considered necessary to deliver this outcome, rather than commenting on the indicator framework. A few respondents also felt that this objective overlapped with the one above, and that the indicators would be relevant in both instances.

In relation to the indicator for ‘business behaviours for a circular economy’, a number of considerations or indicators were suggested. These largely focused on the number or proportion of organisations operating circular practices, those offering circular services, such as reuse, repair, takeback, etc., and indicators for resource reduction, substitution and reparability of products. Several also suggested consideration of circular procurement practices and compliance rates (particularly in public sector procurement), as well as monitoring the level of public-sector leadership and behaviour modelling. Other business-related indicators suggested less often included investment in circular economy activities, and circular economy training interventions.

In relation to the indicator for ‘societal behaviours for a circular economy’, respondents again wanted a focus on household participation and spending levels in the circular economy, considering engagement with reuse, repair, sharing and recycling principles. Other factors that were suggested included: consumer education; household food waste levels; and household consumption and purchasing behaviours.

In many instances, it was felt that indicators would be relevant to both businesses and society. The main issues included:

• Measuring overall resource use, consumption levels and waste generation;
• The availability, affordability and participation/uptake of repair, reuse, refill, sharing, redistribution, recycling and composting;
• Access to lifelong learning, skills development, training, education, and awareness-raising; and
• Longer term-behaviour change.

Other indicators/issues which were relevant to both areas, but mentioned less often, included: levels of recycled content in products; carbon footprint; and measuring grassroots initiatives and engagement.

Several respondents acknowledged that the indicators for both business and society were still under development and so not fully outlined in the draft strategy. It was, however, suggested that the lack of detail in this respect made it difficult to comment on these. More information would be welcomed in due course.

In relation to the indicator on ‘household spending on product repair, maintenance and reuse services’, mixed views were expressed. While some respondents were supportive of this indicator, and two organisations suggested it could be usefully extended to businesses, several highlighted it as being problematic. These respondents felt that this indicator needed careful consideration, otherwise it could provide misleading results. In particular, several respondents noted that, for certain products, recycling may deliver greater environmental benefit than repair. In addition, a few suggested that more durable products may require less repair while high repair spending may reflect poor quality products or maintenance; that the cost of repair would not always equal the value or impact of the repair; and that rising repair costs could result in increased household spend without any real increase in repair activity. A few also highlighted that this measure would also overlook free repair services delivered by the voluntary and social sector, and repairs or maintenance undertaken by individuals themselves.

Several respondents also suggested that the indicators should reflect system change and structural drivers. This included: regulations; standards; mandatory product stewardship; right-to-repair provisions; procurement requirements; and access to funding opportunities.

Again, several respondents advocated for sector specific indicators or sub-sector indicators. These included indicators related to: textiles; the food system; construction/the built environment; rural, agricultural and marine sector behaviours; and offshore energy specific measures. Also consistent with comments at earlier outcomes, respondents suggested data needed to be able to be disaggregated regionally, and to identify rural and island areas.

Several respondents also discussed how the data required to evidence the indicators would be gathered. While there was some support for public and business surveys, others preferred a focus on actual behaviours, and accurately measured and verifiable data rather than stated attitude or reported behaviours.

Again, respondents identified the need for clearer definitions and scope to ensure consistency in understanding and measurement. For example, respondents questioned which behaviours would be considered as ‘circular behaviours’, and what would be defined as ‘the norm’.