Climate Change Plan: monitoring report 2025
The fifth annual monitoring progress report on the Climate Change Plan update (CCPu) which updated the 2018 Climate Change Plan (CCP) and was finalised in March 2021. The report is a statutory requirement set out in the Climate Change (Scotland) Act 2009.
6. Chapter 5: Waste And The Circular Economy
6.1 Part A – Overview of Sector
The outturn emission statistics for 2022 (published in 2024) show a position of 1.6 MtCO2e.
The CCPu sets out the following four policy outcomes for the sector:
Reduction in waste sent to landfill | On Track | Off Track | Too Early to Say |
---|---|---|---|
Total amount of landfilled waste (tonnes) | - | X | - |
Total amount of biodegradable landfilled waste (tonnes) | X | - | - |
Reduction in emissions from closed landfill sites | On Track | Off Track | Too Early to Say |
---|---|---|---|
Number of closed landfill sites with exploratory landfill gas capture/ flaring | - | X | - |
A reduction in food waste | On Track | Off Track | Too Early to Say |
---|---|---|---|
Household and non-household food waste reduced (tonnes) | - | X | - |
Reduce waste and establish a more circular economy, where goods and materials are kept in use for longer | On Track | Off Track | Too Early to Say |
---|---|---|---|
Total waste generated (tonnes) | X | - | - |
Just Transition and Cross Economy Impacts
We wish to understand and report on the broader just transition and cross-economy impacts of our emissions reduction activities in addition to these sector specific policy outcomes and indicators. To do this, in this report we use data from the Office of National Statistics (ONS): Low Carbon Renewable Energy Economy (LCREE) publication. The LCREE data presented in this report is based on survey data of businesses which perform economic activities that deliver goods and services that are likely to help generate lower emissions of greenhouse gases, for example low carbon electricity, low emission vehicles and low carbon services. The LCREE indicator is narrowly defined and, while useful within its limited scope, does not give us the full picture of the impacts on workforce, employers and communities and progress towards a just transition. Over the next year, we will work to develop a more meaningful set of success outcomes and indicators aimed at tracking the impacts of our policies on a just transition to net zero, which will inform our next CCP.
Sector commentary on progress
Emissions from the waste management sector are currently around 1.6 MtCO2e per year (2022). We aim to reduce these emissions to 0.9 MtCO2e by 2025, and 0.7 MtCO2e by 2030.
To achieve this, we must: accelerate action across society to reduce the demand for raw material in products; encourage reuse and repairs through responsible production and consumption; and recycle waste and energy to maximise the value of any waste that is generated, while minimising its environmental and climate impact.
Scotland has made good long-term progress towards reaching these ambitions, and some of our key indicators are on track for delivery. The total amount of waste going to landfill in Scotland has halved over the past decade, with the indicator standing at 2 million tonnes in 2023. In the same reporting year, we met our 2025 target and CCPu indicator to reduce all waste by 15%.
Meanwhile, the latest official recycling statistics (for 2022) show that over 62% of Scotland’s waste was recycled.
Despite this progress, in some areas progress has not been at the pace and scale required, and some indicators remain off track. For example, we are off track on our target to reduce food waste, and we saw a 5% increase (or 2% per capita) against the 2013 baseline according to the most recent estimate (2021).
As well as the amount of methane generated by the decomposition of biodegradable waste, methane emissions from landfill also depend on the rate of methane gas capture at landfill sites. It is anticipated that the methane generated within landfill sites will continue to reduce, but it will also be important to monitor the methane collection efficiency to help ensure we maximise emissions reductions.
It is important to recognise that our previous 2025 waste and recycling targets (which form some of the CCPu indicators) are important milestones but should not be the end destination. The world has changed since many of these targets were set in 2010. As our final Circular Economy and Waste Route Map to 2030 sets out, in some cases, the 2025 targets are not the best indicators to deliver our circular economy, net zero or nature restoration objectives. Many of our existing “all waste” targets are weight-based, do not specifically measure emissions reduction or other environmental impacts, and do not account for the varying environmental or carbon impact of individual materials. This was reinforced by 2022 Climate Change Committee (CCC) advice to the Scottish Government and Parliament.
The Route Map's review of our resources and waste system found that the sustainable choices are still not the easy choices for households, businesses, or those in the waste sector. Large-scale and rapid system change is required to drive progress and ensure a more rapid transition to net zero and a fully circular economy in Scotland.
To ensure this progress is realised, the Scottish Government has continued to make progress in delivering key policy measures set out in our CCPu, while in some places, such as the forthcoming ban on the sale and supply of single-use vapes, we have gone further than the CCPu.
2024 marked a key point in Scotland's circular economy journey. To lay the foundations for this transformation, and to set out priority actions to accelerate more sustainable use of our resources and reduce emission associated with resources and waste, we published our final Circular Economy and Waste Route Map to 2030 in December 2024, delivering our commitment set out in the CCPu.
Alongside this, the Circular Economy (Scotland) Act was passed unanimously by the Scottish Parliament in June 2024 and contains provisions to underpin Scotland’s transition to a circular economy and modernise Scotland’s waste and recycling services. The Act delivers new powers, and working in tandem with the Route Map sets out a framework and key priorities for action into the future. The direction and actions set out in the Route Map are complemented by the provisions in the Act, and in some places are dependent on enabling powers flowing from the Act.
These actions complement the existing, wide-ranging measures we have delivered or are delivering to support our waste reduction, recycling, and emission reduction objectives. Current measures to divert waste from landfill, include a ban on biodegradable municipal waste going to landfill from 31 December 2025, and support for local authorities to secure contracts that comply with the landfill ban.We are working with the UK and devolved governments on reforms to extended producer responsibility (EPR) schemes for packaging, waste electrical and electronic equipment (WEEE) and batteries, which will help drive circular economy outcomes.
Packaging EPR fees and payments will commence this year and is anticipated to increase recycling rates for packaging materials to 76% by 2033. It requires producers to cover the full net cost of managing household packaging when it becomes waste. The revenue from fees will generate an estimated £160 million annually to support Scottish local authorities with the cost of managing household packaging waste. PackUK have been appointed as the scheme administrator and will commence payment to local authorities in November 2025.
Our £70 million Recycling Improvement Fund was launched in March 2021, and more than £66 million has been awarded to 27 local authority projects to improve recycling infrastructure, projected to save over 57,000 tonnes of CO2e per year.
We also remain committed to the delivery of a successful Deposit Return Scheme (DRS) for single use drinks containers in Scotland and are working alongside the UK Government and DAERA towards the launch of the scheme on a three-nation basis by October 2027. The Scottish Ministers have decided that UK Deposit Management Organisation Limited should be designated as the scheme administrator and a Designation Order is subject to approval by the Scottish Parliament. The draft Deposit and Return Scheme for Scotland (Amendment Regulations) 2025 and the draft Deposit and Return Scheme for Scotland (Designation of Scheme Administrator) Order 2025 were laid in the Scottish Parliament on 2 May 2025.
Developments in Monitoring Arrangements Since Last Report
There are no new arrangements in CCPu monitoring, however moving forward, work is focused on the development of a circular economy monitoring and indicator framework. It was clear from the response to both Circular Economy and Waste Route Map consultations (2022 and 2024), and through recent recommendations from the Climate Change Committee, that there is broad support for a new suite of indicators to track Scotland’s progress in moving to a circular economy and ensuring sustainable management of resources, aligned to our efforts to tackle the climate and nature emergencies.
To strengthen the strategic approach to progressing Scotland's circular economy, there is now a requirement on Scottish Ministers to publish or refresh a circular economy strategy every 5 years, as set out in the Circular Economy Act. The setting of statutory circular economy targets is also now a requirement under the Act.
Alongside the strategy an associated monitoring and indicator framework will be developed. This will monitor progress towards delivering a circular economy and inform the development of future targets.
A joint consultation for the strategy and framework will take place during the summer of 2025 with publication of both documents in 2026. We intend to set new circular economy targets from 2027.
The outputs of this work will be considered as indicators are set for future CCPs.
6.2 Part B – Progress to Policy Outcome Indicators
Policy Outcome: Cross-sectoral social and economic.
Indicator: FTE employment in Low Carbon Renewable Energy Economy Indicator.
On-Track Assessment (Milestones/Targets): Year-to-year change.
Most Recent Data: 2022.
Data Source(s): Low Carbon and Renewable Energy Estimates, Office for National Statistics (ONS).
Assessment: Too early to say.
Commentary: Data for the year 2023 is due to be published later this year, following the release of this report.
In 2022, the Scottish low carbon renewable energy economy (LCREE) sectors were estimated to provide 25,700 FTE jobs. Estimates of LCREE are based on a relatively small sample of businesses and hence are subject to a wide confidence interval.
Scottish LCREE employment in 2022 is lower than in 2021 but the difference is not statistically significant, and caution should be exercised when interpreting year on year changes due to a high degree of uncertainty in estimates.

Source: Office of National Statistics (ONS) Low Carbon and Renewable Energy Economy Estimates.
Policy Outcome: 1
Indicator: Total amount of landfilled waste (tonnes).
On-Track Assessment (Milestones/Targets): Progress to target [no more than 5% of all waste to landfill by 2025].
Most Recent Data: Waste landfilled in Scotland reduced from 2.3 million tonnes in 2022 (23% of waste generated) to 2.0 million tonnes in 2023. The percentage of total waste sent to landfill in 2023 will not be available until SEPA publish the Waste from all sources statistics for 2023.

Data Source(s): Scottish Environment Protection Agency (SEPA) official statistics – Waste landfilled in Scotland 2023, Waste from all sources 2023.
Assessment: Off Track.
Commentary: Currently, Scotland landfills less than a third of the amount landfilled in 2005, with waste sent to landfill falling from around 7 million tonnes in 2005 to 2.0 million tonnes in 2023. The percentage of Scottish waste landfilled in 2023 will not be available until SEPA publish the Waste from all sources statistics for 2023.
Achieving the weight-based, 5% to landfill target represents a significant challenge and the pace of reduction would need to accelerate markedly to meet the target. It should be noted however, that the types of waste being landfilled have changed significantly, with ‘household and similar waste’ (responsible for much of the biodegradable waste, which produces landfill gas) reducing from 46% of waste landfilled in 2005 to 27% of waste landfilled in 2023.
Much of the remaining material we landfill has a low carbon impact when landfilled or cannot easily be recycled or disposed of by other means. As we set out in the Circular Economy and Waste Route Map (2024), the 5% to landfill target does not account for the carbon intensity of waste being diverted to landfill and is not a good indicator to measure the sector’s progress to net zero. Achieving our 5% target does not fully align with our emissions reduction commitments or other environmental ambitions in the long term.
Policy Outcome: 1
Indicator: Total amount of biodegradable landfilled waste (tonnes).
On-Track Assessment (Milestones/Targets): Year-to-year change + Progress to interim target [0 tonnes of biodegradable municipal waste landfilled by 31st December 2025].
Most Recent Data: Biodegradable municipal waste (BMW) landfilled has reduced from 2.0 million tonnes in 2005 to 0.55 million tonnes in 2023.

Data Source(s): SEPA official statistics – Waste landfilled in Scotland 2023
Assessment: On Track
Commentary: Clear reductions have been seen over the past 15 years in the amount of BMW landfilled. The amount of biodegradable municipal waste (BMW – the biodegradable component of Municipal Waste) disposed to landfill in 2023 was 554,000 tonnes, a decrease of 144,000 tonnes (21%) from 2022 and a reduction of 1.5 million tonnes (73%) since 2005. The longer-term downward trend is expected to continue as we move towards the ban on landfilling biodegradable municipal waste, which will come into force on 31 December 2025. Work continues to support local authorities to put in place alternative solutions to comply with the ban.
Policy Outcome: 2
Indicator: Number of closed landfill sites with exploratory landfill gas capture/ flaring.
On-Track Assessment (Milestones/Targets): Progress to target [12 by 2025].
Most Recent Data: N/A
Data Source(s): To be determined.
Assessment: Off Track.
Commentary: This was a new policy, as outlined in the CCPu, to accelerate Landfill Gas Capture, working with SEPA and key industry partners to scale up the existing landfill gas capture programme to mitigate effects of landfill and environmental impact of closed landfill sites. This is supported by additional funding from the Low Carbon Fund, with the aim to harness the energy generated from landfill gas capture and maximise circular economy opportunities. Due to other unavoidable resource and budget implications, including COVID-19 contingency work, progress on this policy outcome has been challenging.
The final Circular Economy and Waste Route Map reaffirms our intention to work with industry and the public sector to maximise landfill gas capture opportunities in Scotland. Subject to future budget outcomes, we will seek to extend the landfill gas capture programme to increase the number of sites undertaking investigative or development work, to optimise and increase the amount of landfill gas captured in Scotland and minimise environmental and climate impacts of closed landfill sites. We intend to support this with research to explore current and emerging options for low-level gas capture. We will set out further detail on this work in our next draft Climate Change Plan in 2025. Please see Part C for more information.
Policy Outcome: 3
Indicator: Household and non-household food waste reduced (tonnes).
On-Track Assessment (Milestones/Targets): Progress to target [reduce all food waste by 33% from 2013 baseline by 2025].
Most Recent Data: An estimated 1,037,671 tonnes of food and drink in Scotland was wasted in 2021.
Data Source(s): 2021 Scottish Food Waste Estimate – Zero Waste Scotland, January 2024 2021 Scottish Food Waste estimate
Assessment: Off Track.
Commentary:
Comparison of food waste estimates in 2013, 2018, and 2021
Sector | 2013 baseline (tonnes) | 2018 estimate (tonnes) | 2021 estimate (tonnes) | 2025 target (tonnes) |
---|---|---|---|---|
Food & drink Manufacturing | 248,229 | 282,682 | 281,396 | 171,032 |
Households | 598,890 | 600,312 | 610,167 | 412,640 |
Other sectors | 140,964 | 144,107 | 146,109 | 97,125 |
Total | 988,083 | 1,027,102 | 1,037,671 | 680,797 |
A review of Scotland’s Food Waste Reduction Action Plan was published in 2024, along with a food waste estimate for the year 2021. The Review shows that progress to reduce food waste was limited by the COVID-19 pandemic and the cost-of-living crises. Overall, it found that actions set out in 2019 were not enough – food waste has not decreased. The 2021 food waste estimate indicated that there was a 5% increase compared to 2013, which represents a 2% increase per capita against the 2013 baseline. According to 2021 data, the two largest sector sources of food waste are Household & Consumer (59%) and Food & Drink Manufacturing (27%). While supporting change within Scottish households is required, the relationships between the consumer, the retailer and the supply chain are complex, with each influencing the others’ decisions and behaviour. The remaining 14% is food waste generated by the Hospitality & Catering, Wholesale & Retail, Education, and Healthcare sectors.
Scotland is not alone in facing this challenge. Globally, no country has successfully demonstrated how to reduce food waste at a sufficient scale; a comparable increase in food waste has been seen across the UK during the same period between 2018 and 2021.
The Circular Economy and Waste Route Map was published in December 2024. It marks a collective reset of our approach to tackling food waste as part of wider, cross-government food policy, noting that continuing on the same path will not yield the results we need to see. The actions set out in the Route Map are based on the evidence we have available and set out how we will reset our approach to accelerate a reduction of national food waste and move towards the UN Sustainable Development Goal (SDG) target of a 50% reduction by 2030.
Policy Outcome: 4
Indicator: Total waste generated (tonnes).
On-Track Assessment (Milestones/Targets): Progress to target [reduce total waste by 15% by 2025 against 2011 baseline].
Most Recent Data: The estimated total quantity of waste generated in Scotland in 2022 was 10.16 million tonnes.

Data Source(s): SEPA official statistics – Waste from all sources 2022.
Assessment: On Track.
Commentary: The total amount of waste generated in 2022 was 10.16 million tonnes, an increase of 6.2% from 2021. This equates to an 15.1% reduction compared with 2011. Despite the annual increase, for the second year in a row Scotland has met its 2025 target to achieve a 15% reduction of all waste against 2011 levels.
However, it should be noted that 2021 was an atypical year due to the impact of COVID-19 and, even in years not affected by COVID-19, year-to-year changes in waste can be marked – generally driven by year-to-year variability in construction and demolition waste. In 2022, most of the increase in waste generated is construction type wastes such as Soils and Mineral waste from construction and demolition. Due to the level of year-to-year fluctuation, the target has been met in 4 years (2012, 2014, 2021, 2022) but not the other 5 years for which data is available. Excluding construction and demolition waste, the trend is clearer with a decline in combined household and commercial & industrial waste from 6.8 million tonnes in 2011 to 5.5 million tonnes in 2022, a drop of around 18% in 11 years. As a result of the December 2020 cyber-attack on SEPA, waste from all sources publications for 2019 and 2020 were not available.
In December 2024, our Circular Economy and Waste Route Map set out measures to accelerate progress towards sustainable resource use and a circular economy in Scotland through to 2030. This included measures designed to cut waste, challenge the current approach to consumption and production by mainstreaming reuse and repair, and incentivising and promoting sustainable choices; focusing on reducing food waste from all sources; and embedding circular construction practices to reduce resource needs, reduce waste and carbon, and encourage refurbishment and re-use.
6.3 Part C – Information on Implementation of Individual Policies
Outcome 1: Reduction in waste sent to landfill
Policy: End landfilling of biodegradable municipal waste by 2025, reduce the percentage of all waste sent to landfill to 5% by 2025 and recycle 70% of all waste by 2025 by:
- Continuing our commitment 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.
- Delivering our Circular Economy and Waste Route Map which was published in December 2024, following two public consultations and extensive engagement across public, private and third sectors. The Route Map sets out an ambitious plan to deliver the priority actions to 2030 that will help us to progress to a circular economy and ensure we maximise the positive impact of the new Circular Economy Act for communities across Scotland.
- Establishing a £70 million fund to improve local authority recycling collection infrastructure.
- Further promoting reuse and recycling, in line with EU requirements, ensuring separate collection of textiles by 2025; and ensuring that biowaste (e.g. garden waste), is either separated and recycled at source, or is collected separately and is not mixed with other types of waste by 2023.
- Considering an extension to the forthcoming ban on biodegradable municipal waste to landfill to include biodegradable nonmunicipal wastes, subject to appropriate consultation and work to provide assurance around some specific waste streams, in response to a recommendation from the CCC.
Date announced: 2020-21 Programme for Government (PfG).
Progress on implementation since time of last report / CCPu: The ban on biodegradable municipal waste being landfill will commence on 31 December 2025.
In December 2024 Scotland’s Circular Economy and Waste Route Map to 2030 was published, following two consultations in 2022 and 2024. This fulfils the commitment set out in the CCPu. The Route Map focuses on the delivery of 11 priority actions with clear timelines to drive progress and maximise impact to 2030.
Since 2021, over £66 million has been allocated to local authority recycling and reuse collection infrastructure from the Scottish Government’s Recycling Improvement Fund, including 16 garden and food waste schemes which are helping to get organic waste out of residual waste streams.
We are further promoting reuse and recycling, including consulting on separate collection of textiles and expansion of food waste collections to more rural areas. Strengthening approach to household recycling collection services - gov.scot
In response to a recommendation from the CCC, in March 2025 we published a Call for Evidence around the potential to extend the forthcoming ban on biodegradable municipal waste to landfill (which starts on 31 December 2025) to include biodegradable non-municipal wastes, and work to provide assurance around some specific waste streams.
Have any implementation indicators / milestones been set for this policy? If so, most recent data for progress against these: See above, and the final Circular Economy & Waste Route Map. Scotland's circular economy and waste route map to 2030 - gov.scot
Timeframe and expected next steps: See above.
Policy: Work with the Convention of Scottish Local Authorities (COSLA) in the coming year to evaluate the Household Recycling Charter and review its Code of Practice as a key step in developing a future model of recycling collection.
Date announced: 2020-21 PfG.
Progress on implementation since time of last report / CCPu: As part of the Circular Economy and Waste Route Map, and as outlined in the Circular Economy (Scotland) Act 2024, we are reviewing the Household Recycling Charter's supporting Code of Practice using a co-design process with Local Government.
The Code of Practice will be put on a statutory basis to deliver better and more consistent recycling services across Scotland. This new statutory Code will aim to provide clear guidance for both householders and waste practitioners, ensuring best practices are the easiest options.
Working closely with local authorities is integral to this review, as their input ensures the practicality and effectiveness of the new Code across diverse communities. Co-design will help address the diverse sociological, geographic, and population differences across Scotland.
These efforts aim to provide households with simpler, more intuitive recycling systems while ensuring waste practitioners have a clear and robust framework to support Scotland's circular economy ambitions.
Work has commenced with local government stakeholders to agree a co-design methodology and agree the programme of research required to underpin development of the new Code of Practice. This has included initial engagement events with local government and other stakeholders. As set out in the Circular Economy & Waste Route Map, published in December 2024, the co-design process for high quality, high performing household recycling and reuse services will take place across 2024 – 2026.
Have any implementation indicators / milestones been set for this policy? If so, most recent data for progress against these: N/A
Timeframe and expected next steps: The new household recycling Code of Practice will be completed by the end of 2026, after which it will be made available for consultation.
Policy: Underpinning this we will take steps to improve waste data, continuing to
work with UK Government, other devolved governments, and agencies to develop electronic waste tracking, which will help deliver a step change in the quality and usefulness of waste data for decision making. This will include taking the necessary steps alongside SEPA to drive implementation of the system in Scotland.
Date announced: Low Carbon Fund 2020.
Progress on implementation since time of last report / CCPu: In January 2025, the Digital Waste Tracking launch date was delayed to April 2026, subject to further reviews and updates in May 2025.
More broadly, the Circular Economy and Waste Route Map (December 2024) sets out our intention to set new circular economy targets from 2027, with work to develop a monitoring and indicator framework before this.
Improvements in waste data are overseen by the multi-stakeholder Scottish Waste Data Strategy Board. Across the Circular Economy and Waste Route Map there are a range of measures that rely on timely data and evidence to maximise delivery of meaningful benefits. To ensure this happens, and we have a data landscape that remains fit for the future, we intend to work closely with partners to review and refresh the strategy's action plan. We will also give due consideration as to whether the strategy itself should be refreshed. We will seek to undertake this work to align with the outputs of the new strategy and monitoring and indicator framework for Scotland's circular economy, and emission reduction-related monitoring requirements, which will both inform future data requirements. We will account for the changes to the data landscape that key measures like extended producer responsibility schemes, modernising recycling reform, and the Digital Waste Tracking service, will have.
Have any implementation indicators / milestones been set for this policy? If so, most recent data for progress against these: See above.
Timeframe and expected next steps: See above.
Following the publication of a circular economy monitoring and indicator framework in 2026, circular economy targets will be developed and set by 2027.
Outcome 2: Reduction in emissions from closed landfill sites.
Policy: Accelerate Landfill Gas Capture and Landfill Legacy Management: we will work with SEPA and key industry partners to scale up the existing landfill gas capture programme to mitigate effects of landfill and environmental impact of closed landfill sites.
Date announced: Low Carbon Fund 2020.
Progress on implementation since time of last report / CCPu: This policy has not been progressed due to competing budget pressures and priorities.
The Route Map sets out our commitment to work with industry and the public sector to maximise landfill gas capture opportunities in Scotland. Subject to future budget outcomes, we will seek to extend the landfill gas capture programme to increase the number of sites undertaking investigative or development work, to optimise and increase the amount of landfill gas captured in Scotland and minimise environmental and climate impacts of closed landfill sites.
We intend to support this work with research to explore current and emerging options for low-level gas capture. Further details will be set out in our next draft Climate Change Plan later in 2025.
Have any implementation indicators / milestones been set for this policy? If so, most recent data for progress against these: None.
Timeframe and expected next steps: As above, further details will be set out in our next draft Climate Change Plan later in 2025.
Policy: Landfill gas capture on closed sites: in association with SEPA and the waste industry, double the number of landfill gas capture sites that undertake investigative or development work (from 12 to 24 sites) by 2025, in order to harness energy generated from landfill gas capture and maximise other circular economy opportunities. SEPA has already identified 12 sites for potential investigative work.
Date announced: Low Carbon Fund 2020.
Progress on implementation since time of last report / CCPu: Same as above.
Have any implementation indicators / milestones been set for this policy? If so, most recent data for progress against these: Same as above.
Timeframe and expected next steps: Same as above.
Outcome 3: A reduction in food waste
Policy: Scottish Government has committed to reduce food waste by 50% by 2030, in line with UN Sustainable Development Goal (SDG) 12.3.
Date announced: Food Waste Reduction Action Plan (FWRAP) published 2019; 2020-21 PfG; Review of FWRAP published 2024.
Progress on implementation since time of last report / CCPu: Reducing food waste remains a significant and growing challenge, as the 2024 review of FWRAP set out.
Key milestones in policy development have been achieved through the unanimous passing of the Circular Economy (Scotland) Act 2024 and the publication of the Circular Economy and Waste Route Map – both of which support work to tackle food waste. The Circular Economy and Waste Route Map was published in December 2024. It marks a collective reset of our approach to tackling food waste as part of wider, cross-government food policy, noting that continuing on the same path will not yield the results we need to see. The actions set out in the Route Map are based on the evidence we have available and set out how we will reset our approach to accelerate a reduction of national food waste, and towards the UN Sustainable Development Goal (SDG) target of a 50% reduction by 2030.
The two Route Map priority actions are developing an intervention plan to guide long-term work on household food waste reduction behaviour change (by 2026-27), and from 2025/26, developing with stakeholders effective options to implement mandatory public reporting for food waste and surplus by businesses.
Have any implementation indicators / milestones been set for this policy? If so, most recent data for progress against these: As above.
On data, it remains the case that measuring food waste is a costly and time intensive process. We acknowledge that improving how we measure food waste and identifying where and why it occurs across businesses and households, is a critical step: to better understand the volume and make-up of waste which will allow for more effective interventions and allow for resources to be targeted to make a real impact. The measures outlined above are designed to help address this challenge while also acting as effective interventions that will reduce food waste.
Timeframe and expected next steps: See above.
Next steps include establishing an advisory group to support working with stakeholders on effective options to implement mandatory public reporting of food waste and surplus by businesses (from 2025-26) and supporting Zero Waste Scotland on the development of an intervention plan to guide long-term work on household food waste reduction behaviour change (by 2026-27).
Policy: Improving local authority segregated food waste collections to help break down barriers to food waste reuse and recycling. Supporting leadership, innovation, effectiveness and efficiency in Scotland’s public, private and hospitality sectors by expanding pilot programmes across the education sector and public sector buildings; Support the development and implementation of an NHS Scotland national action plan on food waste; develop best practice guidance for public sector procurement teams to drive new ways of working and more transparent supply chains. A sustained approach to public engagement and communications to enable the public to make changes in their choices and behaviours around food and food waste, in partnership with Zero Waste Scotland.
Date announced: Food Waste Reduction Action Plan 2019 andCCPu.
Progress on implementation since time of last report / CCPu: The Scottish Government’s Recycling Improvement Fund has funded 16 food waste recycling schemes which are helping to get organic waste out of residual waste streams.
The Scottish Government is also reviewing the current rural food waste exemption, which started with a consultation launched in March 2025. The findings of this consultation, alongside research currently being undertaken by Zero Waste Scotland on effective approach to organic waste collections, will inform subsequent policy development to increase collection of food waste and other organic waste, potentially through the co-design of the new household recycling Code of Practice.
Progress has focussed on delivering overarching milestones including the passage of the Circular Economy (Scotland) Act and the consultation and publication of the final Circular Economy and Waste Route Map to 2030.
Particular progress has been made through our programme partners at Zero Waste Scotland who have continued to support leadership and innovation through their one-to-many approach to business engagement, which has included work with key partners to help influence others in the sector. Zero Waste Scotland have also progressed work to support NHS Scotland action on food waste and issued guidance to all Health Boards in Scotland through the Catering Services Expert Group to empower their food service operations. However, due to financial constraints, efforts to deliver targeted communication campaigns have been hampered and instead resource has been redirected to priority actions. Social media infographics have continued to be shared to raise awareness about food waste.
Wider actions to drive a reduction in food waste and develop public procurement opportunities to reduce the environmental impact of public spending, are set in the final Circular Economy and Waste Map.
Have any implementation indicators / milestones been set for this policy? If so, most recent data for progress against these: See above, and the final Circular Economy and Waste Route Map.
Timeframe and expected next steps See above, alongside the final Circular Economy and Waste Route Map.
Outcome 4: Reduce waste and establish a more circular economy, where goods and materials are kept in use for longer.
Policy: We will work with local authorities and the future DRS administrator to explore options that will unlock reprocessing investments, including pricing and incentive schemes, to create jobs and a ready supply of recycled material for new packaging.
Date announced: 2020-21 PfG.
Progress on implementation since time of last report / CCPu: As referred to above, the Circular Economy and Waste Route Map sets out a range of measures to be delivered in the coming years to improve recycling and waste management services, increase the recyclability of products, increase capture at end-of-life and provide greater incentives for domestic reprocessing. This includes extended producer responsibility (EPR) schemes for packaging, waste electrical and electronic equipment (WEEE) and batteries.
We are working with Zero Waste Scotland to support delivery of measures set out in the Route Map, including actions to increase the quantity and quality of materials captured for recycling and to develop the capacity and infrastructure required to reprocess more materials domestically. This work will help maximise the economic opportunities from recycling in Scotland and reduce our reliance on export, while supporting a just transition to net zero. As set out in the Circular Economy Act, we are also developing a waste reprocessing infrastructure report for publication in 2025. This will help inform future investment and policy decisions to ensure Scotland has the capacity to manage more of its waste onshore.
Legislation for packaging EPR came into force in January 2025. Packaging EPR fees and payments will commence this year and is anticipated to increase recycling rates for packaging materials to 76% by 2033. It requires producers to cover the full net cost of managing household packaging when it becomes waste. Funding will go to local authorities to fund effective and efficient collection systems for household packaging waste. PackUK have now been appointed as the scheme administrator and will commence payment to local authorities in November 2025. We have also published a four-nation joint policy statement on packaging EPR which sets out the intended environmental effects of the policy and how it is intended that the policy will achieve those effects.
We also remain committed to the delivery of a successful DRS for single use drinks containers in Scotland and are working alongside the UK Government and DAERA towards the launch of the scheme on a three-nation basis by October 2027. (Further information is provided below).
To reduce Scotland's global carbon impact, we must take responsibility for our own waste, managing and processing as much as possible here in Scotland. A large majority of Scotland's waste is already managed within Scotland, but around 15% is currently processed elsewhere, representing a lost economic opportunity and an environmental cost too. Measures within Modernise recycling and Decarbonise disposal chapters of the Route Map are focussed on tackling this. The recycling co-design action will help consider the available markets and reprocessing capacity for collected materials, and opportunities to facilitate this. This will complement existing measures like extended producer responsibility schemes and our planned waste reprocessing infrastructure report. To strengthen public confidence in where recycling goes, we intend to consult on the introduction of end destination public reporting of household recycling collected.
Have any implementation indicators / milestones been set for this policy? If so, most recent data for progress against these: The reprocessing infrastructure report will be laid in parliament before the Act gains royal assent.
Timeframe and expected next steps: With local authorities and other waste sector stakeholders, we will co-design high quality, high performing household recycling and reuse services in order to develop a new statutory Code of Practice for household waste services by the end of 2026. The Scottish Government plans a similar exercise to co-design measures to improve commercial waste service provisions by 2030.
Packaging EPR comes into force from January 2025, first year of the Scheme begins April 2025. Producers to begin paying local authorities the full net cost of managing household packaging waste: first local authority payments will be made from November 2025.
Policy: Measures to encourage more sustainable consumer purchasing, including plans to take further steps to consult on a charge on single use disposable beverage cups and to increase the carrier bag minimum charge from 5p to 10p in this parliamentary session.
Date announced: Boosted in 2020-2021 PfG.
Progress on implementation since time of last report / CCPu: Bag Charge was increased to 10p on 1 April 2021.
A consultation on proposals to implement a minimum charge on single-use beverage cups ran from 22 August 2024 – 14 November 2024. Responses from the consultation will be considered when developing policy proposals further.
Have any implementation indicators / milestones been set for this policy? If so, most recent data for progress against these: No
Timeframe and expected next steps The consultation analysis will be published in 2025
Policy: Banning priority single use items: We will consult on banning a number of problematic plastic items identified in the EU’s Single Use Plastics Directive (with a view to introducing legislation in 2021) and outline how we will give effect to the wider requirements of the Directive before the end of 2020.
Date announced: 2020-21 PfG.
Progress on implementation since time of last report / CCPu: Legislation banning the supply and manufacture of some of the most problematic single-use plastic items came into force in 2022.
A ban on the sale and supply of single-use vapes will come into force later in 2025.
Have any implementation indicators / milestones been set for this policy? If so, most recent data for progress against these: No.
Timeframe and expected next steps: An evaluation of the implementation of the 2022 single-use items ban regulations will be published by Zero Waste Scotland in Spring 2025.
Policy: Implementation of our Deposit Return Scheme (DRS) for single use drinks containers.
Date announced: CCP 2018.
Progress on implementation since time of last report / CCPu: We remain committed to the delivery of a successful DRS for single use drinks containers to increase recycling rates for single use drinks containers to at least 90%.
We continue to work closely with the UK government and DAERA to launch the scheme across the three nations in October 2027. The schemes will cover England, Northern Ireland and Scotland when launched in 2027, but the legislation for the scheme in Scotland must be determined by the Scottish Parliament. Regulations covering the English and Northern Ireland DRS were approved by the UK Parliament on 21 January 2025.
The application process for organisations wishing to become the DRS Scheme Administrator for Scotland, England and Northern Ireland closed on 3 Feb 2025. A single application was received for the 3-nation DRS schemes with wide support from industry. Officials have worked collaboratively with colleagues from UKG and DAERA to assess that application. The Scottish Ministers have decided that UK Deposit Management Organisation Limited (UK DMO) should be designated as the scheme administrator and a Designation Order is subject to approval by the Scottish Parliament. DEFRA and DAERA have also appointed UK DMO as the scheme administrator for DRS in England and Northern Ireland, effective from 2 May 2025.
We are amending legislation to give effect to the agreed joint policy positions which allows an interoperable three nation approach to a DRS. The draft Deposit and Return Scheme for Scotland (Amendment Regulations) 2025 and the draft Deposit and Return Scheme for Scotland (Designation of Scheme Administrator) Order 2025 were laid in the Scottish Parliament on 2 May 2025.
Have any implementation indicators / milestones been set for this policy? If so, most recent data for progress against these: The draft amending regulations require Scottish Ministers to review the DRS in Scotland by 1st October 2032.
Timeframe and expected next steps: We are aiming to launch the DRS in October 2027. The draft amending DRS regulations and the draft designation order were laid in the Scottish Parliament on 2 May 2025. Parliamentary scrutiny should be complete by the end of June and subject to approval by the Parliament the scheme administrator (UK DMO) will be designated.
Policy: We will also work collaboratively across the public sector developing tools and guidance and a practical approach to influence and empower buyer, supplier and key stakeholder communities to use public procurement to support a green recovery and our wider climate and circular economy ambitions through procurement, embedding climate considerations in organisational procurement strategies by 2021 and reporting progress in annual procurement reports.
Date announced: 2020-21 PfG.
Progress on implementation since time of last report / CCPu: We continue to promote our national suite of online Sustainable Procurement Tools to support Scottish public sector procurers to adjust to a more resource efficient and sustainable procurement practice, with learning and guidance provided on climate and the circular economy. The latest annual report is available at (Procurement: annual report 2022 to 2023 - gov.scot
Have any implementation indicators / milestones been set for this policy? If so, most recent data for progress against these: N/A
Timeframe and expected next steps: The Circular Economy & Waste Route Map was published on 18 December 2024 and sets out 11 priority actions that we need to take to deliver sustainable use of our resources and progress towards a circular economy in Scotland by 2030.
This includes action to further develop public procurement opportunities to reduce the environmental impact of public spending, including scoping new legislative circular economy requirements for contracting authorities under section 82 and 82A of the Climate Change (Scotland) Act 2009.
Policy: We are introducing extended producer responsibility for packaging from 2025 alongside the other UK governments, which will see producers paying local authorities the full net cost of running an efficient and effective household packaging collection service.
Date announced: 2020-21 PfG.
Progress on implementation since time of last report / CCPu: The Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 were made on 11 December 2024 and are now in force.
PackUK was appointed as the scheme administrator on 12 December 2024, by all four nations, representing a key milestone in the delivery of the scheme. Scottish Government officials will continue to work closely with the other UK governments and PackUK on the delivery and development of the scheme.
PackUK’s functions will include setting packaging fee rates, raising these fees from obligated producers and making packaging waste disposal payments to local authorities. The revenue from fees will generate an estimated £160m annually to support Scottish local authorities with the cost of managing household packaging waste.
Have any implementation indicators / milestones been set for this policy? If so, most recent data for progress against these: PackUK is required to set out how it will measure and report on delivery of its objectives and outcomes. The key performance indicators it will apply will be set out in its yearly Operational Plan. Together, with the other UK nations, we will monitor the PackUK’s performance, including through its annual report, the first of which will be due by 30 September 2026 for year 1 of EPR for packaging and each year thereafter.
Timeframe and expected next steps: A final version of the EPR producers’ fees for year one of the scheme is expected to be published by summer 2025 using tonnage data reported by producers for the full year of 2024.
Local authorities will receive their first packaging EPR payment in November 2025, followed up by subsequent payments in January and March 2026 for the first year.
Policy: We are boosting our commitment to building a circular economy, where goods and materials are kept in use for longer. We will deliver this by embedding circular recovery principles in the wider green recovery. Through Zero Waste
Scotland and Scottish Environment Protection Agency (SEPA), we will intensify our work with industry and businesses to address emissions associated with production, consumption, and waste of products/resources; and to promote resource efficiency.
Date announced:CCPu.
Progress on implementation since time of last report / CCPu: The Circular Economy (Scotland) Act 2024 was unanimously passed by Parliament in June 2024. The Act establishes the legislative framework to support Scotland’s transition to a zero waste and circular economy, significantly increase reuse and recycling rates, and modernise and improve waste and recycling services.
The Act requires that Scottish Ministers publish a circular economy strategy and make regulations to set circular economy targets. The strategy and associated monitoring and indicator framework are currently being developed jointly with ZWS and with SEPA input.
We published the Circular Economy and Waste Route Map on 18 December 2024 setting out actions that we need to take to deliver sustainable use of our resources and progress towards a circular economy in Scotland by 2030.
Scotland's circular economy and waste route map to 2030 - gov.scot
We also published the Green Industrial Strategy on 11 September 2024 which identifies areas of strength and opportunity for Scotland to grow globally competitive industries in the transition to net zero and outlines what government and partners will do to support stakeholders to create an enabling environment for investment and growth.
Green industrial strategy - gov.scot
Have any implementation indicators / milestones been set for this policy? If so, most recent data for progress against these: A monitoring and indicator framework is being developed as part of the strategy which will track progress towards a more circular economy.
Timeframe and expected next steps: A consultation on the strategy and monitoring framework is planned for summer 2025 with publication in 2026. Development of targets will follow in 2027.
Policy: In the context of the latest CCC recommendations and building on progress already made by the sector, we will consider measures to ensure new energy from waste plants are more efficient, and ‘future-proofed’ for Carbon Capture and Storage technology.
Date announced:CCPu.
Progress on implementation since time of last report / CCPu: Since 2020 the Scottish Government has commissioned, published, and responded to an independent review on the role of incineration in Scotland’s waste hierarchy[29].
In its response to the review, the Scottish Government recognised and adopted this recommendation, which goes further than ensuring new facilities are CCS ready, while remaining conscious of relevant statutory obligations which must apply to all planning decisions. The response also highlights actions to improve the efficiency of energy from waste plants and the appropriate use of Carbon Capture Use or Storage technology.
National Planning Framework 4 (NPF4) was adopted and published by Scottish Ministers on 13 February 2023 and sets out that development proposals for energy-from-waste facilities will not be supported except under limited circumstances, where a national or local need has been sufficiently demonstrated, and where relevant criteria are met. This includes the requirement to show consideration was given to methods to reduce carbon emissions of the facility (for example through carbon capture and storage); and, supplying an acceptable decarbonisation strategy aligned with Scottish Government decarbonisation goals.
As a matter of law, all planning applications must be determined in accordance with the development plan, unless material considerations indicate otherwise. NPF4 forms part of the statutory development plan and will directly influence all planning decisions. This includes considerations for new Energy from Waste (EfW) facilities.
The Circular Economy and Waste Route Map to 2030, published in December 2024, sets out a range of actions to incentivise further decarbonisation of the waste sector, including energy from waste.
Have any implementation indicators / milestones been set for this policy? If so, most recent data for progress against these: N/A.
Timeframe and expected next steps Apart from the completed work on NPF4, we will also consider what additional fiscal measures and supporting policies could be introduced to reduce the carbon emissions associated with disposal further, particularly through the Sector-Led Plan to minimise Carbon Impacts of Energy from Waste, due to be published in 2027.
Policy: As part of our work on developing a route map to 2025, we will undertake a specific and focused piece of work to examine the range of fiscal measures used by other countries to incentivise positive behaviours and to develop proposals to go further in this area.
Date announced:CCPu.
Progress on implementation since time of last report / CCPu: The Scottish Government is working closely with our UK nations co-members of the UK Emissions Trading Scheme (ETS) Authority to support the inclusion of energy from waste and incineration in the UK ETS. In 2023 the Authority published a response to its first consultation on expanding the UK ETS to include incineration and a second consultation closed in August 2024. The response to the second consultation is expected to be published in due course. We believe the UK ETS could facilitate reductions in the incineration of plastics, emissions, and increased efficiency of EfW plants through incentivising increased levels of recycling, mixed waste sorting to remove fossil content from residual waste, and CCS. The UK ETS Authority is also exploring if it would be possible to incentivise heat offtake.
However, we acknowledge the barriers to some of these decarbonisation options, such as cost and infrastructural difficulties around CCS and heat offtake and the relative immaturity of chemical recycling technologies.
As set out in the Circular Economy and Waste Route Map, we will also consider what additional fiscal measures and supporting policies could be introduced to reduce the carbon emissions associated with disposal further, particularly through the Sector-Led Plan to minimise Carbon Impacts of Energy from Waste, due to be published in 2027.
In 2023 research was undertaken to look at international examples of direct variable charging models and the lessons we can learn for future service design in Scotland. Direct Variable Charging, a system in which the cost of residual waste collections reflects the amount of waste created, incentivises the use of recycling and food waste collection services and the minimisation of residual waste produced. The research showed limited potential benefits and highlighted the complexity of setting up a new system. Direct Variable Charging has not been taken forward and there are no current plans to explore the policy further in Scotland.
Have any implementation indicators / milestones been set for this policy? If so, most recent data for progress against these: N/A
Timeframe and expected next steps: UK ETS expansion to include incineration Government response expected in due course, which will set out details of timeframes and next steps.
Contact
Email: climatechangeplan@gov.scot