Circular economy strategy draft: consultation analysis

Impact Assessments

While the consultation document noted that the publication of the strategy itself would not result in direct impacts, it was expected that specific priorities may have an impact if they were introduced. As such, the consultation sought feedback on any potential overarching impacts for sectors or themes.

It should be noted that the number of respondents who provided feedback across this section were low. This ranged from 42 respondents who commented on the Equalities Impact Assessment (at Q11), to just 23 respondents who provided feedback about the Child Rights and Wellbeing Impact Assessment (at Q16).

Equalities Impact Assessment

Q11. Please provide any further information or evidence that should be considered in the accompanying Equalities Impact Assessment (EQIA)

While respondents were asked to comment on the Equality Impact Assessment (EQIA), which focused on the impact of the strategy on those with protected characteristics, several respondents provided wider feedback covering socio-economic and island issues. While these topics were perhaps more suited to later questions, this feedback has been included below due to the intersectional nature of many of the issues, and the difficulty in separating feedback which was often relevant to more than one assessment.

Among individuals, responses to this question were mainly linked to new and changing employment opportunities presented by a circular economy. Views included that the circular economy transition must actively consider the impact on lower-paid workers and those in rural or shift-based employment, especially within sectors such as hospitality, catering, and agriculture, to make sure they are not negatively affected by change. If the circular economy was to be fair, it was also suggested that equal access to contracts and participation (i.e. between larger and smaller suppliers/providers) must be embedded as a measurable outcome.

Other individuals stressed the need to consider not only the creation of jobs in isolation, but to also consider: job quality; job displacement; job accessibility for under-represented groups; and skills development.

It was suggested that including data on training needs for women, ethnic minorities, and disabled people in circular economy sectors would strengthen the EQIA. Another individual stressed the need more generally for support for workforce retraining and skills development in emerging circular sectors to help reduce inequalities.

Reduced food waste/food reduction was also a focus for some individuals, and it was stressed that this could have significant benefits for low income households, if they had increased access to surplus food through community programmes. The need to ensure that protections remained around food safety regulations was, however, also stressed, i.e. any changes to regulations should maintain high standards while reducing unnecessary waste.

Others simply reiterated their wider support for the principles of developing a circular economy and stressed that they hoped all individuals and businesses would be invested. Others urged that continuing to hear voices of under-represented groups (including representative organisations such as disability advocacy groups, minority ethnic organisations, rural community bodies, and SMEs) was important in taking the plans forward and would further ensure inclusivity. Similarly, others stressed the need to be cognisant of the diversity of the Scottish population during any implementation and transition:

“We recommend that the Equalities Impact Assessment (EQIA) carefully consider accessibility, inclusion, and cultural diversity. Scotland’s residents are not homogenous, and cultural attitudes toward circular practices can vary widely. Some communities may have circular practices deeply embedded, while others may be more hesitant to adopt them.” (Individual)

To ensure the strategy is inclusive and equitable, one individual urged that the EQIA should include evidence on how circular economy measures may generate uneven costs and benefits across protected characteristics and socio-economic groups, and assess distributional impacts alongside headline environmental benefits. In particular, they noted that the assessment should consider: affordability and access to circular options; geographical accessibility; digital inclusion/ exclusion; time poverty and caring responsibilities; and how circular principles can reduce household costs, while identifying safeguards against unintended negative impacts.

Among organisations, there was a perceived need to ensure that low-income households, and those living in island, rural and semi-rural communities were protected in particular (especially the distributional effects of circular economy investments in island communities, where incomes are lower, costs are higher and populations are more exposed to climate and nature risks). It was suggested that this may be achieved via targeted support for such communities to mitigate disproportionate regulatory or cost impacts and help avoid unintended social or economic impacts.

Several organisations specifically focussed on access to ‘hubs’ and stressed that logistical challenges must be addressed for certain communities. It was important to ensure access to reuse and repair services across rural and island communities was considered.

Strategies to address the risk of unequal access to services were also needed in more general terms, it was felt, i.e. rather than to assume that everyone has storage space, private gardens, or easy access to recycling points:

“Equality considerations should include how circular opportunities are accessed in practice, who is able to participate, and who benefits. Supporting local, hands-on and community-based approaches can help reduce these barriers and ensure circular activity is not limited to those already well connected or resourced.” (Organisation: Private Sector - Food & Drink)

A small number of organisations stressed that the EQIA could or should more fully reflect evidence that environmental harm, climate impacts and resource inefficiency disproportionately affect disadvantaged groups, contributing directly to health inequalities. It should explore how to reduce environmental harm without increasing inequality, and consider how the circular economy strategy could address the fact that environmental degradation disproportionately affects marginalised communities:

“Circular economy policies have significant potential to reduce these inequalities through improved housing quality, reduced pollution and better access to affordable, durable goods, but only if they avoid cost-shifting and reliance on individual capacity to act.” (Organisation: Other)

Some organisations also echoed views of individuals regarding the need to ensure that any training and progression pathways introduced as a consequence of the circular economy were designed for inclusivity. This included ensuring support for disability in the workplace, gender equality and offering ‘second chance’ employment for any jobs created by the circular economy. One organisation stressed that fair access to new jobs arising from the change to a circular/net zero economy would require embedding skills required from school onwards and up-skilling/re-skilling of employees in traditional sectors. They also suggested that the pay gap between ‘green’ jobs and oil/gas/offshore may be a barrier to transition. Another simply expressed that the strategy could be more explicit and more developed in terms of explaining how increasing the uptake of circular practices through improved skills and education opportunities for those with protected characteristics would be implemented:

“…there is an opportunity to strengthen the Equalities Impact Assessment by more explicitly considering the role of education, lifelong learning and access to circular economy skills in addressing inequality.” (Organisation: Third Sector)

Other comments from organisations were very sector specific and included calls to reflect tobacco and nicotine-related inequalities; to consider job creation and workforce transition from oil and gas into other energy sectors; to consider the impacts of chemicals on those who are pregnant, children, and women who are particularly vulnerable to exposure; and to consider the benefits of circular‑economy jobs linked to marine‑litter work.

One organisation urged the need to ensure that circular economy initiatives be designed and evaluated for their impact on social equity, poverty reduction, and inclusion, with specific metrics and reporting which align with wider Council priorities, and strengthen the case for local investment. Close working with local authorities in taking forward the strategy was also encouraged:

“Careful consideration needs to be given to the impact that this may place on local authorities in terms of budget and resources available for local authorities taking on additional requirements in terms of managing and mitigating any equalities impacts, and if local authorities are impacted then funding needs to be provided to manage and mitigate such equality impacts if they are foreseen to arise.” (Organisation: Public Body - Local Authority)

A few organisations highlighted the need for robust modelling and measurement of impacts to be set out:

“The Scottish Government should undertake robust modelling and analysis of the impact of these measures on consumers. This will be especially necessary where high volumes of consumers must undergo a process of change in a short timeframe and where these changes will have associated costs…This modelling and analysis should pay particular attention to the needs of consumers in vulnerable circumstances or on low incomes. The impact on consumers should be considered for individual measures, however it is important that impact assessments also take into account the cumulative impact of multiple circular economy measures on consumers.” (Organisation: Public Body - Other)

“The assessment should adopt a stronger intersectional approach, considering impacts by income, disability, age, ethnicity, geography (including rural and island communities), and linking these to health outcomes. Greater use of disaggregated data and lived experience would strengthen understanding of distributional impacts and help ensure that circular economy measures actively reduce, rather than inadvertently reinforce, existing inequalities.” (Organisation: Other)

One organisation, who welcomed that the strategy would be updated following consultation, also stressed that Scottish ministers must adhere to regulation 5 of the Scottish specific duties in its entirety by:

• Updating the EQIA as appropriate over the entire policy development cycle;
• Defining a review process so the actual impact can be measured; and
• Arranging to review and, where necessary, revise policies and practices.

Overall, both individuals and organisations agreed that circular economy measures could play a significant role in reducing inequality if designed inclusively. A range of considerations were needed, including geographical equity, socio-economic diversity, gender, age and disability inclusion, affordability, cultural heritage, infrastructure and digital accessibility.

Fairer Scotland Assessment

Q12. Please provide any further information or evidence that should be considered in the accompanying Fairer Scotland Assessment

There was very little feedback from individuals in response to this question and the main points included:

• The need to protect low-income households who are affected by upfront affordability and access to repair services (and, as such, the need to include evidence on household expenditure patterns and affordability of circular products in the assessment);
• The need for prioritisation of shorter supply chains, fair pay, and transparent local procurement models in the assessment; and
• The need to explicitly address food poverty in any assessment.

One respondent wanted to know “the cost of all this to the general public”, and another indicated that they felt there should be a wealth tax. One individual commented that it was not clear from the information provided in the consultation paper what the assessment was assessing or what it was about.

There was also little feedback from organisations, with many simply reiterating the same points made in response to Q11 around ensuring that the strategy and any assessments were cognisant of the unique needs of diverse communities, especially rural and island communities. Again, views were stressed that circular economy measures must avoid unintended consequences that exacerbate inequalities between urban and rural communities.

Among those who gave ‘new’ substantive answers, the main points were:

• To support local reprocessing, which would deliver significant economic and social value by retaining material benefits within communities; reduce cost and strengthen local resilience by shortening supply chains; support community wealth building; and stabilise prices for SMEs;
• To consider socio-economic barriers that may limit participation in the circular economy, including affordability of reuse and repair services, access for rural and island communities, and digital exclusion. It should also assess how proposed interventions - such as procurement practices, funding mechanisms, and infrastructure investment - can reduce inequalities by creating local jobs, improving service accessibility, and supporting low-income households through targeted measures;
• To design circular economy activities around everyday realities. To support fairness, circular strategies should actively invest in local capacity, recognise informal and practitioner-led routes, and ensure that benefits are felt at a community level rather than concentrating value elsewhere;
• For policies to avoid shifting costs or responsibilities onto households least able to absorb them and for caution to be heeded around increasing costs on consumers. Similarly, assessments should consider the current cost of living crisis in the context of any change that may result in reduced services, charges, or behaviour change that is unevenly distributed across Scottish communities;
• That the assessment should explore how the circular economy can help tackle regional inequalities, support community wealth building, provide fair work opportunities (especially in rural and remote areas), and better recognise and support the role of social enterprises and community businesses in delivering fairer outcomes;
• Give greater consideration to evidence on how education, skills and lifelong learning shape people’s ability to benefit from the circular economy, particularly for those experiencing socio-economic disadvantage. Similarly, the assessment could include evidence on how educational access, intergenerational impacts and community-based capability building would help ensure the circular transition actively reduces poverty and inequality, and support a fairer, more inclusive economy across Scotland;
• To explore the potential of aiming for "zero carbon" instead of "net zero" since the aim of net zero may leave loopholes for both the government and organisations to pay for carbon offsetting instead of changing practices; and
• To recognise that not all people are equally educated around/aware of potential harms associated with certain product choices and the need, therefore, for regulation in ensuring that safe circular products free from harmful chemicals are available and accessible to all.

One organisation specifically recommended that the Fairer Scotland Assessment take into account existing Fair Work assessments across the UK to avoid duplication of effort, particularly for national organisations. Streamlining certification or registration processes would also be welcomed, they suggested.

Others again stressed that this assessment would be strengthened by greater use of disaggregated data, consideration of rural and island impacts, and assessment of how benefits and transition costs are distributed, to ensure the strategy actively contributes to poverty reduction and fairness. Another suggested that details around proposals for transitions of specific sectors and the communities involved in those sectors would be welcomed.

Island Communities Impact Assessment

Q13. Please provide any further information or evidence that should be considered in the accompanying Island Communities Impact Assessment

Very few individuals provided a response to this question. Those who did stressed the uniqueness of island communities per se, and the logistical challenges and costs they face with accessing services due to poor infrastructure (including accessing transport and waste management services), ferry dependency, and the limited land and housing availability limiting service provision viability:

“Many of the initiatives discussed for each of the different sectors are likely to face barriers in an island setting due to lack of required infrastructure and resource e.g. construction reuse hubs, kerbside collection of textiles, the establishment of repair hubs etc. Analysis of how each sector would embed circular economy principles in an island setting with the unique challenges they face would be beneficial.” (Individual)

One individual also suggested that policy must explicitly support decentralised and locally adapted solutions if circularity is to work across the whole of Scotland.

Similarly, the main feedback from organisations was linked to the need for local solutions for island communities. There needed to be specific recognition of challenges linked to distribution (e.g. of surplus food and waste), accessibility (e.g. to waste management services), and access to services and other infrastructure (including digital services/internet. etc.) in island communities, among other things:

“Further consideration of the impact of waste infrastructure on circular activities and associated infrastructures for reuse and repair (including social infrastructure) could be given in the resources and waste management section.” (Organisation: Academic)

A specific issue raised by organisations was the costs attached to haulage in island (and other remote) areas which some agreed indicated the need for employing a micro-hub model in some areas. Costs for haulage, alongside issues linked to the smaller levels of waste that would be generated by small island (and remote) communities, was stressed:

“Any impact on collections of materials/items of any kind from the islands and Highlands needs consideration due to the likely higher costs of haulage and implementation, the lower capture rate due to lower populations, and the lack of local infrastructure options.” (Organisation: Representative/Membership Body - Waste)

Many organisations also again reiterated that island communities should be supported to develop circular approaches that are resilient, low-input and locally managed, rather than being expected to fit into mainland-designed models. This again, was due to the perceived challenges linked to infrastructure and accessibility in these areas:

“Circular economy approaches need to account for limited transport links, higher costs, weather disruption, power outages and reduced access to services. Solutions that rely on frequent movement of materials, centralised processing, or constant digital connectivity are unlikely to work well in island contexts.” (Organisation: Private Sector - Food & Drink)

One organisation noted that it was essential that island voices were included in the development and implementation of local circular economy policies, and that support was tailored to their specific needs. The introduction of targeted grants to enable the development of circular infrastructure tailored to island needs was also posited.

Recognising and supporting innovation tailored to island circumstances was also seen as essential to build resilience, reduce reliance on imported goods and materials, and enable locally appropriate circular solutions. This might include investigation of small-scale technological solutions.

While many organisations welcomed the Island Communities Impact Assessment, it was noted that the scope could have been wider to include rural and remote mainland areas too (especially since they often face similar spatial and access challenges, such as limited infrastructure, transport connectivity, and service availability). Similarly, one organisation noted that the decision to include only priorities that could be “reasonably predicted” to impact islands, could unintentionally narrow the scope and reduce preparedness for less obvious but significant impacts.

Some organisations stressed the need to ensure that the strategy did not result in any unintentional environmental harms to island communities, with one suggesting that the circular economy strategy would be considered to have failed if island communities continued to suffer from high levels of plastic pollution. Specific environmental concerns for islands included that long supply chains of recycling may be almost as burdensome on poorly connected islands as is the problem of those islands becoming effectively the endpoint for waste products (and as such the need for waste to be minimised using circular economy principles was key).

Other views put forward by just one or two organisations each included:

• That island communities could benefit from new employment in repair, refurbishment and recycling linked to offshore energy assets, and this opportunity should be reflected;
• Further evidence should be considered on the role of ocean-based farming, place-based cultural knowledge, and intergenerational skills that are central to island economies and identities. Evidence on barriers such as connectivity, workforce retention, skills succession, access to training, and the impact of regulatory and market pressures on small-scale industries would strengthen the assessment;
• The need to consider the unique issues and burdens linked to marine litter and fishing related plastics that affects the islands. This might include incentives being provided to such communities to recover material; and
• The inclusion of Community Asset Transfer opportunities was welcomed. Community ownership and management of assets can play a key role in supporting reuse, repair, local production and resource-sharing activities, helping to retain value locally and support inclusive economic outcomes.

A few organisations suggested that more thought and work was needed on this assessment going forwards:

“We acknowledge that this Impact Assessment does not offer full insight into potential issues that will come from the development of interventions linked to the priorities set out in the strategy and instead identifies and considers broader issues…It will be important for these issues [to be] fully explored and considered prior to development and implementation of individual interventions that come from the final strategy and upcoming roadmaps.” (Organisation: Public Body - Other)

Business and Regulatory Impact Assessment

Q14. Please provide any further information or evidence that should be considered in the accompanying Business and Regulatory Impact Assessment

Again, very few individuals answered this question and most who did focussed on the unique challenges faced by small businesses rather than any gaps in the Business and Regulatory Impact Assessment (BRIA).

Three individuals stressed that the current regulatory and procurement environment in Scotland currently favoured larger, more established businesses and that many of the circular economy measures (e.g. mandatory reuse targets and EPR) could disproportionately affect small and micro-businesses. The business impact assessments could therefore include the barriers faced by small businesses in accessing public contracts, and the costs associated with achieving compliance.

Individuals also stressed the need for tailored support for SMEs across the proposals, that more focus was needed on the changes that would be needed to business models and supply chains, and that sectoral case studies would help businesses anticipate changes.

Several organisations echoed individuals’ views regarding the potential for disproportionate negative financial impacts for SMEs, micro-businesses and community enterprises (especially those in remote, rural and island communities). Costs linked to any changes to/enforcement of regulations and stewardship schemes were seen as a key area for consideration:

“The assessment should also consider differential impacts on small and medium-sized enterprises, including access to finance, skills and supply chains, and the need for targeted support to enable compliance without disadvantaging smaller or community-based businesses.” (Organisation: Other)

Organisations were also anxious about increased costs attached to circular economy measures, with concern that these had been underestimated and would be difficult for some to absorb. This was seen as especially true for services/ suppliers operating in the public sector where it was felt that the Scottish Government would need to provide additional funding or grants to ease the transition and ensure that the quality of public services was not compromised.

More broadly, one organisation noted that the BRIA provided limited clarity on how small and micro-enterprises would be supported to participate in and benefit from the circular economy transition. Another urged the Scottish Government to set out how it would support businesses to deliver the strategy’s vision.

Again, some organisations stressed that more detail was required, specifically focusing on different sectors or different types of businesses. There were also calls for anticipated costs to be quantified more precisely for different measures, to aid business planning:

“Although the document covers many areas of interest and provides some examples of cost and benefits it fails to deliver detailed analysis and financial impacts that allow a full understanding of the positive and negative impacts of the proposals. Further, as transition plans (both detailed and general) are missing it is not possible at this point to generate the granularity required for a full assessment.” (Organisation: Private Sector - Utilities)

The impacts, costs and resource capacity of delivery bodies was also seen as an area that required further detail.

One local authority expressed a view that the BRIA should further recognise the role of consumer behaviour in driving circular economy outcomes and recommended that the BRIA consider how funding derived from the ‘polluter pays’ principle could be directed towards supporting circular economy transition costs, particularly for smaller businesses and those operating in rural and island areas.

Alignment with existing regulatory regimes was urged (including EU regulatory regimes), as well as the need for consistency across the UK and synchronicity of administrations to deliver a joined-up, four nations approach. It was also stressed that burdens should not be placed on domestic producers that leaves them at a disadvantage to international producers that are harder to regulate with domestic legislation. Further, policy stability was said to be needed for public bodies and organisations to invest, and so any regulatory changes must consider contract cycles and infrastructure/funding lead times.

Many other, disparate comments were also provided, but which were not directly related to the BRIA. These were highly varied with no common themes or topics.

Consumer Duty Impact Assessment

Q15. Please provide any further information or evidence that should be considered in the accompanying Consumer Duty Impact Assessment

There were very few responses to this questions overall (n=24), and especially among individuals (n=5).

Feedback from individuals was generally quite negative, and focussed on a lack of clarity in the strategy and assessment of how any cost increases to consumers, brought about by implementing circular economy principles, would be affordable:

“Consumers are being asked to behave more sustainably while the systems supporting them remain fundamentally linear. Without affordable, accessible circular options - such as local refill stations, deposit-return systems, and repair schemes - the burden of change is unfairly shifted onto individuals.” (Individual)

Individuals also suggested that consumers needed clear product information on durability, repairability, and environmental impact, as well as clear food labelling (and perhaps education on date labels) to make informed decisions. One individual suggested that suppliers/retailers should be accountable for offering circular options, rather than penalising consumers.

Organisations also highlighted the need for greater awareness among the general public/consumers of such things as the chemicals that are in primary and recycled products, as well as circular economy principles in general:

“…consumer-facing circular initiatives need to be clear, practical and accessible…There is a risk that well-intentioned circular measures can increase complexity, cost or confusion for consumers, particularly those already under financial pressure. Circular options should not rely on additional time, specialist knowledge or higher upfront costs in order to be effective. Digital tools, simple guidance and locally relevant solutions can help consumers reduce waste and make more sustainable choices without increasing burden. Consumer duty should prioritise clarity, fairness and ease of participation, particularly for low-income households and those with limited access to services.” (Organisation: Private Sector - Food & Drink)

Three organisations outlined suggestions to ensure accurate and comparable information provision, transparency and trust. This included the use of digital product passports and verified recycled content claims, as well as the introduction of clear, accessible “where your waste goes” dashboards for waste services.

Again, organisations stressed that both cost burdens and risk of harm should never be placed on the consumer. It was felt that the current proposals potentially contained an inherent assumption that reused or repaired goods would be cheaper for consumers, but this may not be the case. One organisation suggested that it should be explicitly noted within the assessment that any increased costs for industry/business as a result of implementing circular economy proposals was also likely to result in increased costs for consumers:

“The Consumer Duty Impact Assessment should consider how circular economy measures will affect consumer choice, affordability, and access to services such as reuse, repair, and recycling. It should assess risks of disproportionate impacts on low-income households, rural and island communities, and digitally excluded consumers, and ensure that interventions…do not reduce availability or increase costs unfairly. Mitigations like clear consumer information, affordable options, and accessible service delivery should be included to uphold fairness and transparency.” (Organisation: Public Body - Health)

Organisations also again stressed that both regulation and targeted support had a key role to play in ensuring that vulnerable individuals were not penalised (especially low-income consumers).

Others stressed that more careful and detailed assessment was needed of consumer impacts, which considered the unique challenges faced by low income households, remote, rural and island communities, and other marginalised groups. Similarly, differentiating between short- and long-term consumer impacts was encouraged, as well as focus on affordability during the transition period to achieving a circular economy.

One organisation also suggested that the Consumer Duty Impact Assessment be edited to adopt a broader definition of ‘consumer harm’. Others suggested the need to further develop the concept of ‘consumer responsibility’ and reflect the role of consumer behaviour, behaviour change and motivation to change in the assessment:

“…further evidence should be considered on the role of consumer responsibility, informed choice and education in delivering circular economy outcomes. Consumers influence production, transport and waste through everyday decisions, yet their ability to act responsibly depends on access to clear information, affordability, skills and understanding of product lifecycles. Evidence on how education, labelling, transparency and public awareness shape consumer behaviour - particularly in relation to overconsumption, durability, repair and end-of-life choices - would be valuable. Recognising consumers as active participants, rather than passive recipients, would ensure the assessment reflects the shared responsibility needed to reduce environmental harm and support fair, sustainable consumption across Scotland.” (Organisation: Third Sector)

Child Rights and Wellbeing Impact Assessment

Q16. Please provide any further information or evidence that should be considered in the Child Rights and Wellbeing Impact Assessment

As above, a very small number of respondents provided feedback at this question (n=23), including very few individuals (n=5).

Views from individuals were unique, as follows:

• A circular economy should secure a healthier, more sustainable future for young people, but that the strategy lacked tangible education or engagement mechanisms to address this;
• Circular economy measures can reduce household costs, which in turn would benefit families with children, especially those in low-income brackets, but that understanding the impact of digital access/exclusion would be important;
• Reducing food waste and improving food redistribution would support children's rights to adequate nutrition, while school meal programs should model circular practices and educate children about food waste;
• The damaging effects of fossil fuel emissions on children should be considered in the strategy; and
• Wellbeing targets should be established.

Organisations who answered this question (which again were few in number) largely reiterated how circular economy policies were key in helping to provide access to affordable, safe, and sustainable products; reduce pollution and create cleaner local environments; improve housing quality; reduce food waste; limit exposure to harmful substances; support access to affordable, healthy food; and provide opportunities for education and skills development. All of these could have significant benefits for children’s wellbeing, it was felt. As such, there were suggestions that the assessment could consider more fully how proposed measures protect children’s rights to health, a safe environment and an adequate standard of living, both now and in the future.

Organisations also noted that children could be particularly vulnerable to the impacts of any exposure to danger introduced by recycled or reused products. As such, careful monitoring of all products and services delivered to young people was urged, alongside robust regulations.

Other comments from organisations included that not all children and young people engage with learning and wellbeing in the same way, or have equality of opportunity in terms of accessibility. The impact assessment should therefore recognise diversity of learning pathways and opportunities to ensure all children have fair access to circular economy benefits:

“Supporting flexibility, choice and locally appropriate approaches will help ensure that children’s rights and wellbeing are upheld across different family and community contexts.” (Organisation: Private Sector - Food & Drink)

Similarly, one organisation noted that the Child Rights and Wellbeing Impact Assessment should assess risks such as digital exclusion for families in rural or low-income areas. They also wanted it to ensure that interventions promote fairness, health, and wellbeing for all children, while supporting engagement through schools and community initiatives.

Additional suggestions, put forward by one organisation each, included that:

• Circular economy approaches could be aligned with such things as Rights Respecting Schools and UNCRC-aligned awards;
• Circular economy policies should be aligned with health, social justice, and environmental policies, and aspirations for children and young people;
• National support through funding, frameworks, and shared indicators was essential to scale impact;
• The assessment could more directly set out how circular economy policies influence the wellbeing of children and young people in rural and island communities, both directly and indirectly; and
• School outreach activities and programmes could be integrated within circular hubs to build future skills and awareness.

Two organisation stressed that the voices and views of children could or should have been better incorporated in the development of the strategy. It was argued that young people should be recognised as key stakeholders in any decisions made about tackling the climate crisis and the circular economy, and that decision-makers needed to create opportunities for young people to meaningfully participate in designing and delivering a circular economy across Scotland.

Overall, organisations supported and endorsed the positive impacts for children and young people which could result from a circular economy, compared to the existing linear economy, and felt that the assessment should reflect this more strongly. They also felt that the assessment could more explicitly address the potential long-term impacts of the strategy on children’s rights and wellbeing:

“The impact assessment should consider and identify the negative impacts to rights and wellbeing created by the linear economy that could be rectified by transition a circular economy.” (Organisation: Third Sector)