Delivering Scotland's circular economy - route map to 2025 and beyond: consultation

Through this consultation we set out our proposals for a Route Map to 2025, our strategic plan to deliver Scotland’s zero waste and circular economy ambitions. This consultation invites views on the proposed priorities and actions to reach our waste, recycling and emissions reduction targets.

Package 6: Minimise the impact of disposal

Achieve the best environmental outcomes for materials that cannot be captured for reuse or recycling, and ensure environmental and economic value of wasted resources and energy is maximised and harnessed efficiently.

Current actions and commitments:

  • Introduce a ban on biodegradable municipal waste going to landfill by 2025.
  • Consult on extending the biodegradable landfill ban to non-municipal waste.
  • Expand the existing landfill gas capture programme.
  • Commission analysis of bio-stabilisation options.
  • Consider and respond to recommendations from the independent review into the role of incineration within Scotland's waste hierarchy.
  • Investigate measures to ensure new energy from waste plants are more efficient and 'future-proof' waste infrastructure for carbon capture and storage (CCS) technology.
  • Consult, with other UK governments, on expanding the UK Emissions Trading Scheme to include Energy from Waste.

Proposed new actions:

  • Develop a Residual Waste Plan to ensure the best environmental outcome for materials and set strategic direction for management of residual waste to 2045.
  • Restrict the incineration of fossil materials, through the development of a sector-led plan by 2024.
  • Investigate fiscal measures to incentivise low carbon disposal, including the potential to include energy from waste in the UK Emissions Trading Scheme (ETS).

Focus of this package

The measures outlined elsewhere in this consultation are primarily focused on how to prevent materials and products from becoming waste, and how to maximise the value, through recycling and reprocessing, of those that do. All other packages will help maximise value from waste and minimise environmental harm by reducing the need for residual waste treatment. While our goal is to continue to reduce the amount of residual waste we produce, until we move to a fully circular economy there is a need to consider how to minimise the impact of residual waste.

This package sets out the measures we will take to ensure we manage residual waste in a way that maximises value and minimises carbon and environmental harm, taking account of the materials involved and the impact of different management options. This will contribute to our target to send a maximum of 5% of waste to landfill by 2025 and to reduce emissions.

Currently the majority of waste management sector greenhouse gas emissions come from landfill sites in the form of methane - a greenhouse gas that is around 25 times more potent in the atmosphere than CO2 over a 100-year time horizon. The actions set out in this package are therefore particularly important to reducing our greenhouse gas emissions.

What we want to achieve

We want to divert more material from landfill, to keep it in productive use. We want to ensure that materials are safely managed and cause the least possible environmental harm, whilst giving industry confidence to invest in new technology and the necessary capacity. We want to move beyond measuring tonnage alone, and address wider environmental impacts, including carbon, to make sure that different materials are managed in the best possible way.

The measures proposed in this package aim to:

  • Help manage materials in the right way

Our current disposal incentives, most notably the Scottish landfill tax, have made alternatives to landfill (such as recycling or incineration) more attractive. However, more could still be done to incentivise the management of waste upstream while recognising that different material streams have different needs. For example, while landfill is rarely the best disposal route for our waste, some materials such as contaminated soils and some sorting residues[123] may be better disposed of via landfill compared to the available alternatives.

  • Encourage innovation while maintaining stability

Residual waste solutions require sizeable and long-term investment. We need a stable commercial environment to give investors and the wider waste sector confidence in viable and reliable solutions for their disposal needs. However, we also need research, development and innovation in the waste and resources sector to develop and adopt the new technologies and practices required to reach net-zero by 2045.

  • Explore the scope of a more targeted approach to the Scottish landfill tax

The Scottish landfill tax is one of the most direct interventions to divert residual waste away from landfill. However, the tax primarily influences the decisions of recycling and waste service providers, and has comparatively lower direct impact on the price that households and businesses pay for producing waste. Current tax bands only provide for a lower rate of tax for less polluting materials and a standard rate for all other materials, although the legislation allows for additional lower (qualifying) rates to be created.

Where we are now

We sent approximately 2.6 million tonnes of material to landfill in 2020, less than half of what we sent in 2005. The proportion of waste sent to landfill has decreased from 43% in 2011 to 32% in 2018.[124] This trend has been driven by a number of factors, including increased landfill taxes, a marked shift from landfill to incineration,[125] improved recycling rates and upstream management of waste, and the upcoming ban on sending biodegradable municipal waste (BMW) to landfill.

Nevertheless, achieving our target to send a maximum of 5% of waste to landfill target by 2025 represents a significant challenge. Much of the remaining material we landfill cannot easily be recycled or disposed of by other means and, therefore, achieving our 5% target may not align with our carbon other environmental ambitions in the long term.

What we have done

The Landfill Tax (Scotland) Act 2014has been one of the most direct incentives to divert waste away from landfill. It comprises two rates - a standard rate, and a lower rate for qualifying materials including 'inert' wastes, such as soil and stones. Rates have increased over time since the introduction of the tax.

What we are already doing

[From 2025] We have introduced a ban on biodegradable municipal waste going to landfill, the first nation in the UK to do so. This will ensure that biodegradable material is recycled or disposed of through other means. We have already seen a marked reduction in the amount of material being sent to landfill since the ban was announced, and the full ban will come into force across Scotland on 31 December 2025. We will also consult in 2022 on extending the ban to include biodegradable non-municipal wastes to further reduce the amount of biodegradable waste being sent to landfill.

[From 2022]

We commissioned an independent review of the role incineration plays in Scotland's waste hierarchy. This includes an analysis of capacity requirements and options for residual waste treatment, including decarbonisation opportunities. We have published the report[126] and will set out our initial response to the findings and recommendations in June 2022. The findings of this review will be taken into consideration in the final Route Map.

[From 2022]

We have consulted on the draft National Planning Framework 4 (NPF4)[127] which includes measures to ensure that new energy from waste plants are more sustainable. For example, it includes requirements to supply a decarbonisation strategy aligned with Scottish Government decarbonisation goals.

[From 2022]

Zero Waste Scotland have commissioned a review of biostabilisation of waste, where waste is treated to reduce its biodegradability before being sent to landfill. This has been suggested to have a lower carbon impact than other treatment options. The review includes an assessment of technical, economic, policy and environmental factors that influence the implementation of biostabilisation technologies in practice. Research will be published in summer 2022.

[From 2023]

We will expand the existing landfill gas capture programme by 2023 to mitigate the negative effects of landfill and the environmental impact of closed landfill sites, supported by additional funding from Low Carbon Fund.

What we are proposing to do


1. We will develop a Residual Waste Plan by 2024 to ensure the best environmental outcome for materials and set the strategic direction for management of residual waste to 2045, and to bring this area in-line with net zero targets.

We propose to develop a Residual Waste Plan to provide direction for future disposal practices in Scotland and ensure the best environmental outcome for material. The plan will establish a long-term vision for industry and government, and map a pathway from 2024. We will work in partnership with the public, private and third sectors to build joint ownership and the confidence needed to invest in infrastructure across the resource recovery chain.

We will establish an Advisory Panel to oversee development of the plan, consisting of the Scottish Government, public sector and private industry representatives and non-governmental organisations. The plan will transition from a weight-driven approach to one that seeks the best environmental outcome for different materials, and take account of national strategic infrastructure planning, emerging and future technologies, and mechanisms for encouraging innovation.

If this measure is taken forward, we will consider a range of policy measures in developing the plan, including:

  • Options to use Scottish Landfill Tax and the Aggregates Levy,[128] separately or jointly, to drive further recycling and develop secondary markets (see package 5).
  • Alternative pathways for sorting residues, by researching potential uses, treatment options, cost benefit analysis, market demand and implementation measures.
  • Actions to address recommendations of the independent review of incineration capacity (see Box 5),[129] which consider our national capacity requirements, societal impacts ,and decarbonisation opportunities.
  • Investment to transition to lower emission residual treatment options to deliver integrated and optimised treatment solutions and ensure a planned retreat from landfill.

Box 5: Review of the role of incineration in Scotland's waste hierarchy

We appointed Dr Colin Church to lead an independent review into incineration, with the aim of ensuring that how residual waste is managed in Scotland aligns with Scotland's carbon reduction ambitions.

We published Dr Church's report on 10 May, which sets out 14 recommendations. Some of those that are relevant to the proposal to develop a Residual Waste Plan include:

The Scottish Government should ensure that no further planning permission beyond that already in place is granted to incineration facilities unless balanced by an equal or greater closure of capacity.

Scottish Government and local authorities should work with industry to develop a strategic approach to planning and deploying waste collection, reprocessing and management facilities.

As part of an overall strategic approach to planning and deploying waste management capacity, the Scottish Government should develop an indicative cap that declines over time for the amount of residual waste treatment needed as Scotland transitions towards a fully circular economy.

Operators of all residual waste treatment facilities should work to significantly strengthen community engagement and trust before, during and after development. Clear guidelines for authentic and effective community engagement should be co-produced by Scottish Government with community groups and local authorities by the end of 2023.

All 14 recommendations are available in the report. We are considering these carefully and will set out an initial response in June 2022.


2. We will facilitate the development of a sector-led plan by 2024 to restrict thecarbon impacts of incineration.

The independent review of incineration has made two provisional recommendations, pending the outcome of a longer piece of work to consider the options to decarbonise the residual waste sector. We will use the outputs from this piece of work to consider the options and incentives to decarbonising the sector, including how to ensure energy from waste plants are more efficient and waste infrastructure can be 'future-proofed' for carbon capture and storage (CCS) technology.

Taking account of the review's recommendations, we propose to work with the waste and resources sector to accelerate the reduction of the carbon impacts of existing incineration plants. We will begin by focusing on measures to divert the highest carbon-emitting materials from incineration, such as plastics. Industry ownership would help ensure economic and environmental viability, identify the potential challenges for investment, and better identify the mechanisms needed to direct materials to disposal routes with better environmental outcome. Whilst we believe that a significant impact can be achieved on a voluntary basis, we will also explore options for mandatory compliance.


3. Investigate further fiscal measures to incentivise low-carbon disposal.

We propose to consider what additional fiscal measures could be introduced to reduce the carbon emissions associated with disposal, and particularly the incineration of waste. We will investigate the potential of an incineration tax, inclusion of Energy from Waste within the scope of the UK Emissions Trading Scheme (see Box 6), and determining an appropriate carbon price for waste sector emissions.

Box 6: UK Emissions Trading Scheme (ETS) consultation

With UK government and other devolved administrations, the Scottish Government launched a consultation on Developing the UK Emissions Trading Scheme on 25 March 2022. As part of this consultation, we have launched a call for evidence on expanding the UK ETS to include energy from waste (EfW).

We are seeking views on a proposed expansion to the scheme by the mid-late 2020s to include waste incineration with and without energy recovery. It follows recommendations from the Climate Change Committee for Government to consult on the introduction of a carbon tax (either as part of the UK ETS or a separate instrument) aimed at EfW.

Our call for evidence seeks input on:

  • The timing of proposals;
  • Monitoring, reporting and verification of emissions;
  • Potential impacts, including on operators of EfW plants, LAs, consumers and customers;
  • The potential for the expansion to incentivise decarbonisation; and
  • Unintended consequences, including the ability of EfW operators to pass on costs to customers.
Figure 9: Actions to minimise the impact of disposal
This shows the proposed timeline of existing and new proposed actions by the Scottish Government to minimise the impact of disposal, from 2022 to 2030. These measures are set out in the text above.

Consultation questions

Question 11. To what extent do you agree with the measures proposed in this package to minimise the impact of the disposal of residual waste? Please provide evidence to support your answer if possible.

[Strongly agree / Agree / Neither agree nor disagree / Disagree / Strongly disagree / Not answered]

Question 12. Are there any further measures that you would like to see included in the Route Map to minimise the impact of disposal?



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