A Circular Economy Strategy for Scotland – Fairer Scotland Duty Assessment (FSDA)

Fairer Scotland Duty Assessment Summary for Circular Economy Strategy for Scotland

Title of Policy, Strategy, Programme etc

A Circular Economy Strategy for Scotland

Summary of aims and expected outcomes of strategy, proposal, programme or policy

This Fairer Scotland Duty Assessment has been prepared to accompany the publication of the Circular Economy Strategy for Scotland (‘the Strategy’) and has been updated following a public consultation and analysis of the consultation responses.

The Scottish Government is committed to transitioning to a circular economy as a means of addressing the climate and nature crises while delivering sustainable economic and social benefits. A circular economy keeps materials and products in use for as long as possible, thereby reducing demand for virgin resources, minimising waste, and maximising the value retained within the economy.

Around four-fifths of Scotland’s carbon footprint comes from the products and services we manufacture,^[1] use and throw away and 90% of global biodiversity loss and water stress is caused by extraction and processing of these products.^[2] The Scottish Government is committed to delivering a different approach to our economy, one where we move from a "take, make and dispose" model to one where we value materials and keep them in use for as long as possible.^[3]

The Scottish Government has set climate change ambitions to become a net zero greenhouse gas emitting nation by 2045.^[4] Sustainable resource use is key to tackling climate change and will be vital for our efforts to reduce Scotland’s global carbon footprint, and for other sectors to deliver their own net zero goals.

The Circular Economy (Scotland) Act 2024 places a statutory duty on Scottish Ministers to publish or revise a Circular Economy Strategy every five years.^[5] The Strategy provides a high-level framework for Scotland’s transition to a circular economy, setting out a broad vision and outcomes as well as priorities across policy mechanisms, priority sectors, and product stewardship. It also sets out plans for monitoring and evaluating the impact of the Strategy via the Circular Economy Monitoring and Indicator Framework.

These priorities aim to support the Strategy “Vision” set out below:

“By 2045 Scotland will be a net zero and nature positive nation helped directly by the significant progress in transitioning towards a circular economy with sustainable levels of material use.

Scotland will have a thriving economy that meets societal needs and is based on circular economy principles, and we will have reduced the negative global impact of our production and consumption.

People, businesses and the public sector will have the skills and knowledge to benefit from opportunities arising from a circular economy and these will be fairly distributed across society.”

The Strategy builds on Scotland’s Circular Economy and Waste Route Map to 2030. While the Route Map focuses on sustainable resource use and reducing the carbon impact of our waste, the Strategy sets out the strategic direction for the future and how circularity will be embedded across the economy by looking at sectors, systems and products. Future interventions that relate to the Strategy’s priorities may include policy proposals, potential legislative measures, and supporting activity to drive systemic change across production, consumption and disposal of materials and products in Scotland.

Policy context:

The development of the Strategy aligns, as far as practicable, with key Scottish Government commitments, as set out below. The Strategy also reflects international commitments such as the UN Sustainable Development Goals,^[6] the EU Circular Economy Action Plan,^[7] and the Paris Agreement.^[8]

The Scottish Government will also develop proposals for the introduction of circular economy targets following the publication of the Strategy and associated monitoring and indicator framework. This is also a requirement of the Circular Economy (Scotland) Act 2024.

The Strategy is already supported by, and will be connected to, a wide range of existing and planned circular economy policies, interventions and activities. These include investment in reuse and recycling infrastructure resulting from our Recycling Improvement Fund, or product stewardship initiatives such as the packaging Extended Producer Responsibility scheme, the Deposit Return Scheme, or measures on other product types. The Strategy builds on existing and planned activities to set a clear direction for Scotland for the systemic change required to transition to a circular economy.

Interaction with other policies (draft or existing):

The Circular Economy (Scotland) Act 2024^[9]

The Act introduces measures that require primary legislation in Scotland’s transition towards a circular economy. The Act requires Scottish Ministers to publish a Circular Economy Strategy for Scotland every 5 years and to make new regulations to set circular economy targets.

Climate Change Plan ^[10]

The Scottish Government publishes a statutory strategic delivery plan (the Climate Change Plan) every 5 years. The most recent plan sets out a pathway to reduce Scotland’s emissions over the period to 2040.

Scotland's National Strategy for Economic Transformation (NSET)^[11]

Scotland’s NSET sets out the priorities for Scotland’s economy as well as the actions needed to maximise the opportunities to 2032 to achieve the vision of a wellbeing economy. The NSET contains a vision for a Wellbeing Economy, ‘thriving across economic, social and environmental dimensions’, is supported by three ambitions, including ‘Greener: Demonstrating global leadership in delivering a just transition to a net zero, nature-positive economy, and rebuilding natural capital’. A number of priorities across the Strategy support the NSET.

Just Transition – A Fairer, Greener Scotland: Scottish Government response^[12]

In 2021, the Scottish Government published our response to the findings of the first Just Transition Commission. The response also comprised our National Just Transition Planning Framework, which was designed to ensure an ambitious and consistent to planning for a just transition. The framework continues to underpin the production of Just Transition Plans for different sectors and sites, all of which will support the aims of NSET.

The Good Food Nation Plan^[13]

In December 2025 the Scottish Government published its First National Good Food Nation Plan which states “In our Good Food Nation, the people of Scotland can access and enjoy food that keeps them happy and healthy. Our food industry continues to thrive and grow. The environment is protected, biodiversity loss reversed, and our net zero ambitions achieved. A Good Food Nation enables flourishing rural and coastal communities.”.

Scotland’s Biodiversity Strategy to 2045: tackling the nature emergency^[14]

Scotland’s Biodiversity Strategy and associated delivery plan recognises the need to ensure the range of actions we are undertaking are both complementary and coordinated as part of our overall efforts to tackle the twin crises of climate change and biodiversity loss.

Environment Strategy^[15]

The Environment Strategy creates an overarching framework for Scotland’s strategies and plans for the environment and climate change. Its 2045 vision and supporting outcomes describe our guiding ambitions for restoring Scotland’s natural environment and playing our full role in tackling the global climate and nature crises. In turn, this will help to build a stronger, more resilient economy and improve the health and wellbeing of Scotland’s people. It will help to ensure we live within the planet’s sustainable limits as responsible global citizens.

Green Industrial Strategy^[16]

The Green Industrial Strategy publication identifies areas of strength and opportunity for Scotland to grow globally competitive industries in the transition to net zero. It outlines what government and partners will do to support stakeholders to create an enabling environment for investment and growth. The Green Industrial Strategy’s mission is to ensure that Scotland realises the maximum possible economic benefit from the opportunities created by the global transition to net zero.

Litter and Flytipping Strategy^[17]

The National Litter and Flytipping Strategy sets out our approach to tackling litter and flytipping in order to protect and enhance Scotland’s environment; ensure safer and cleaner communities; and contribute to a thriving circular economy for Scotland. Litter and flytipping are losses of material from the economy, so reducing litter and flytipping will also help accelerate Scotland’s transition from a ‘linear’ economy, which is environmentally unsustainable and energy and resource intensive, to a more resource efficient and sustainable circular economy.

Extended Producer Responsibility (EPR) and ongoing reforms

The Scottish Government has committed to reforming the existing four nation Producer Responsibility schemes:

• Packaging Producer Responsibility Scheme^[18]
• Waste Electrical and Electronics Producer Responsibility Scheme^[19]
• Batteries and Accumulators Producer Responsibility Scheme^[20]

Reforms to the existing Producer Responsibility schemes will result in changes to how end of life products are managed, how local authorities may be funded to manage that waste and how reuse and repair are championed across the three schemes.

Deposit Return Scheme

The Scottish Government is also committed to introducing a deposit return scheme (DRS) for single-use drinks containers in Scotland to help increase recycling, reduce litter and meet our climate change targets. We are working closely with the UK Government, and the Department of Agriculture, Environment and Rural Affairs in Northern Ireland to ensure the successful delivery of interoperable schemes across Scotland, England, and Northern Ireland in October 2027.

Single-use vape ban

The ban on the sale and supply of single-use vapes came into force on 1st June 2025 using powers under the Environmental Protection Act 1990. This approach has been used in the past to ban other items such as microbeads, cotton buds and single-use plastics. The UK-wide ban has been introduced to prevent the environmental damage disposable vapes cause and also to address health concerns associated with vaping as Scotland moves towards a tobacco-free generation by 2034.

Summary of evidence

The Fairer Scotland Duty (‘the Duty’) places a legal responsibility on named public bodies in Scotland to actively consider how they can reduce inequalities of outcome caused by socio-economic disadvantage, when making strategic decisions.

This Fairer Scotland Duty Assessment has been updated following a public consultation which ran from 21st October 2025 to 13th January 2026 and is published alongside the Strategy.

Consultation responses provided a lot of general commentary regarding further information or evidence to consider including:

• Community wealth building approaches to reduce costs
• Community capacity building regarding circular economy education access
• Regional inequalities
• Changes to procurement models to support market access for all sizes of businesses
• Household expenditure patterns
• Digital exclusion
• Behaviour change
• Disaggregated data to understand the distribution of benefits and costs of interventions
• Current “cost of living crisis”
• Taxation.

While none of these relates directly to specific socio-economic issues resulting from priorities set out in the Strategy, these issues should be accounted for during the development of any actions resulting from the Strategy, where appropriate.

Other information provided by consultation respondents has been incorporated into the sections below.

The publication of the Strategy itself will not directly impact people or communities. In addition, the priorities set out in the Strategy are intended to apply across Scotland and do not specifically target particular groups, geographical locations or sections of society.

However, we acknowledge the vulnerability of people living with social and economic disadvantage and that there is potential as individual interventions related to the Strategy priorities are developed and implemented, for them to affect everyone in Scotland (including individuals, businesses, public sector and third sector organisations).

It is therefore important to ensure that the impact on those who experience socio-economic disadvantage is understood, whether this is through low income, low wealth, material deprivation, area deprivation or socio-economic background, and that the impact of future interventions, related to the Strategy priorities, are assessed.

Across each of the priorities there may be potential for associated future actions to impact people differently across socio-economic groups.

At this stage, there are not expected to be any potentially positive or negative impacts across different socio-economic groups due to the publication of the Strategy.

The evidence gathered suggests the potential impacts outlined below should be considered when interventions related to the Strategy priorities are designed, developed and implemented.

Climate Crisis and Environment

The Strategy seeks to influence behaviours by consumers, businesses and organisations to drive circular practices and principles. This is likely to include messaging that frames circular economy imperatives around environmental issues and addressing the climate crisis.

Adults in the most deprived areas are less likely to view climate change as an immediate and urgent problem. In addition, the proportion of adults viewing climate change as an immediate and urgent problem in 2019 was highest amongst those with degree level qualifications (80%) and lowest for those with no qualifications (49%).^[21]

As such the impact of behavioural change work and public communications relating to the Strategy priorities needs to account for these differences.

Creation of green jobs

'Green Jobs in Scotland: An inclusive approach to definition,

measurement and analysis'^[22] states that green jobs are generally better paid and that the median advertised wage is greater than those defined as non-green jobs.

This report, published by Skills Development Scotland, suggests that poorer skills attainment associated with socio-economic disadvantage can impact people’s ability to gain secure and well-paid employment. This would include jobs created by a growing circular economy.

There are several reasons for this, including that those living in poverty are more likely to have caring responsibilities, be one-parent households or have limited or no access to a car. People from disadvantaged backgrounds are also less likely to have access to networks and opportunities for placements or work experience, which would reduce their job market opportunities, compared to those from higher incomes.

The Strategy also seeks to increase uptake of circular practices through improved skills and education opportunities. It is likely that these groups of people may be more likely to miss out on circular economy job opportunities, for the reasons highlighted above.

Consultation responses reiterated this need and called for consideration to evidence how education, skills and lifelong learning shape people’s ability to benefit from the circular economy. Without access to learning, reskilling and systems understanding, the benefits of innovation, green jobs and cost savings are unevenly distributed. This was highlighted specifically by some respondents in relation to rural communities and specific rural employment sectors.

Also highlighted was the need to embed circular skills in all educational settings. Additionally, a potential pay gap between current and circular jobs was perceived to be a potential barrier to employment – especially in areas affected by the energy transition.

Socio-economic disparities also exist for some people in Scotland across and within the protected characteristic groups in terms of educational and labour market outcomes. For example, gender segregation happens from school via approaches to subject choice and paths to employment being developed with a gendered lens.^[23] This carries into the labour market, resulting in under-representation in certain subjects and occupations by different genders.^[24] These disparities contribute towards an overall gender pay gap of 8.7% in Scotland.^[25]

In addition to this, while some ethnic minority groups achieve highly in the education system in terms of attainment, labour market outcomes^[26] are far lower in comparison to the wider population. Finally, outcomes for disabled individuals, both in education and the labour market, also tend to be lower than the wider population.^[27]

The impact of the Strategy on those with protected characteristics can be seen in the associated Equalities Impact Assessment (EQIA).

Low incomes, low wealth and material deprivation 

The Strategy seeks to empower consumers and organisations to adopt circular behaviours and support businesses to increase circularity and uptake of circular business models. This may lead to changes in the price of specific items depending on the nature of future interventions.

Over a million people in Scotland live in relative poverty and around a quarter of them are children, with nearly half a million of these people in very deep poverty.^[28] According to the 2023 household survey,^[29] 13% of those aged 16-34 and 11% of 35-59 years old said they are not managing well financially.

Affordability was raised by consultation respondents - this included how some circular economy measures may reduce cost but also that higher up-front costs may prohibit low-income households from engaging with circular activities.

As such, the potential impacts, positive or negative, on costs for consumers on low incomes should be assessed as and when appropriate.

Rural communities 

Living in more rural areas in Scotland incurs additional costs.

A Scottish Government report from 2021 estimated that the minimum cost of living in ‘remote rural’ Scotland is between 15% and 30% higher than urban parts of the UK.^[30]

Socio-economic inequalities being exacerbated in rural communities was a point raised by multiple respondents to the consultation. Finding localised approaches was suggested to build rural community resilience and reduce disparities.

It is unclear how the impact of the Strategy priorities would be significantly different for people living in rural communities – in addition the Strategy seeks to expand the application of a place-based approach to the circular economy.

Nevertheless, it is important that potential impacts, positive or negative, on rural communities should be assessed as and when appropriate.

The impact of the Strategy on those living in island communities can be seen in the associated Island Communities Impact Assessment (ICIA).

Food insecurity

The Strategy seeks to develop effective options with stakeholders to support food waste reduction by businesses, improve circularity across the supply chain and guide long-term practices on household food waste reduction behaviour.

Food waste and food insecurity are interconnected and 9% of adults in Scotland in 2021 experienced food insecurity in the previous 12 months.^[31]

Zero Waste Scotland calculates that 59% of Scotland’s food waste comes from households and that the average UK family of four stands to save £1,000 a year simply by wasting less food.^[32]

In 2019 Waste and Resource Action Plan (WRAP) estimated that around 3.6 million tonnes of food surplus and waste are generated in UK primary production – with a market value of £1.2 billion^[33]. WRAP calculated that if 10% of this was fit to redistribute it would be the equivalent of around 850 million meals a year. Along with edible, surplus food that goes to waste from retailers and manufacturers this figure rises to 1.3 billion meals a year, which could be utilised to feed economically vulnerable people in the UK.

In their consultation response Fareshare highlighted the need for further engagement regarding socio-economic benefits of food redistribution. They also highlighted a need to align with the Scottish Government “Cash-First - towards ending the need for food banks in Scotland” plan.^[34]

In other responses surplus food redistribution was recognised as a way to address food insecurity but that it must be achieved with dignity-preserving approaches.

As such the potential impact, positive or negative, in relation to food insecurity should be assessed as and when appropriate.

Transport

This Strategy, alongside the Transport Strategy,^[35] seeks to improve circularity of passenger and light goods vehicles.

Socio-economically disadvantaged groups are less likely to use cars or own them.

This fact can adversely affect access to employment, education, training, and ability to travel to see family and friends, attend medical appointments or access to shops and public services.

Access to repair services for low-income households was specifically raised in responses to the consultation.

As such the potential impact, positive or negative, in relation to car use and car ownership should be assessed as and when appropriate.

Access to affordable housing

The Strategy seeks to increase reuse of construction materials.

Interventions in the built environment are complex and there are many factors determining house prices (such as land value, wider housing market trends and overarching economic conditions), so impacts are difficult to forecast and measure.

For example, following a policy intervention, property developers may choose to increase/decrease their prices and pass on additional costs/savings or risk to consumers. A negative scenario for consumers could create an increased barrier to low-income households purchasing a newbuild property.

The same is true of the potential to increase rental costs: people on low incomes or who are unemployed and seeking work are more likely to live in the social rented sector.

According to the 2019 Scottish Household Survey,^[36] 21% of households in the social rented sector did not manage well financially. This was significantly higher than among owner occupier households (3%) and households in the private rented sector (14%). People on lower incomes are more likely to live in deprived areas.

Differences in housing costs between areas can limit the neighbourhoods that

people on lower incomes can live in. For example, the Scottish Household Survey 2019 found that 47% of socially rented households were in the most deprived areas compared to 17% of privately rented households and 12% of owner-occupied households. This has been increasing since 2013.

As such any future interventions that could lead to a positive or negative impact on housing costs should be assessed as and when appropriate.

Other activity likely to result from the Strategy

This FSDA acknowledges and assesses some generic activities that may result from pursuing interventions linked to stated priorities. This will enable an element of impact assessment at this stage and highlight areas for attention for fuller assessment in future. These generic activities are:

• Research activity
• Policy development activity
• Communications activity

Future research activity may impact on socio-economic groups at two stages. Firstly, via impact during research due to methodology, and secondly the potential impact of policy implementation following research.

For the former, it is not possible to assess at this stage where and how this impact may occur. As such, this research activity must encourage inclusivity and diversity to avoid bias and generalisations. It should be accessible and ensure perspectives and experiences represent the breadth of Scottish society, including organisations and individuals that represent different socio-economic groups.

It is also not possible to assess where and how this impact may occur for the latter at this stage. As such, future research related to the Strategy priorities should require a methodology that includes perspectives, and experiences of different socio-economic groups.

Similarly, future policy development activity must encourage inclusivity and diversity to avoid bias and generalisations. It should include voices from organisations that represent all socio-economic groups.

Finally, future communications activity must be inclusive, suitable and accessible to all socio-economic groups. There is a need for socio-economic disadvantaged groups to access the same level of information and understanding as their peers - regarding future changes or opportunities as a result of interventions resulting from the Strategy priorities.

Summary of assessment findings

This FSDA has identified that no positive or negative impacts will result directly from the publication of the Strategy.

However, it has helped to highlight areas where there may potentially be impacts on certain protected characteristics following the development of interventions related to the Strategy priorities.

These impacts should be considered closely during their respective design, development and implementation – and be subject to their own FSDA where appropriate.

Sign off

Name: Russell Bain

Job title: Deputy Director, Circular Economy Division