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 4: Improve recycling from commercial businesses

Support businesses to reduce waste and increase recycling

Current actions and commitments

  • Implement the Scottish Deposit Return Scheme (DRS) on 16 August 2023.
  • Implement extended producer responsibility (EPR) schemes for packaging, waste electrical and electronic equipment, and batteries from 2024 onwards.
  • Develop a digital waste tracking service, in partnership with the UK government and other administrations.
  • Take action to address waste crime, including publication of a new Litter and Flytipping Strategy and creation of the Flytipping Forum.

Proposed new actions:

  • Conduct a national compositional study of waste from commercial premises.
  • Review compliance with recycling requirements.
  • Co-design measures, including targeted communications, to improve commercial waste service provisions that drive waste prevention and reuse, with a particular focus on food waste recycling.
  • Research and pilot commercial waste zoning approaches.

Focus of this package

Commercial and industrial waste accounted for 28% of Scotland's waste in 2018. Sources are wide-ranging, and includes waste from agriculture, forestry and fishing, manufacturing, and waste produced by businesses and organisations, for example, wholesale, retail, hospitality. The variety of activities and sectors makes smart and targeted interventions challenging to prioritise or measure.

Measures to reduce waste and improve recycling from commercial and industrial businesses contribute towards our targets to reduce all waste by 15%, reduce food waste by 33%, and recycle 70% of all waste by 2025. Achieving these targets will also help to meet our targets to send no more than 5% of waste to landfill by 2025.

This package will particularly focus on measures to improve recycling from commercial premises. Measures to reduce waste and promote recycling through product design and stewardship are covered in package 1. Measures to increase recycling from households are covered in package 3.

What we want to achieve

We want businesses to have the information and support they need to reduce waste and maximise recycling, with clear incentives in place to ensure that the most sustainable choices are the easiest choices. We want high quality and reliable commercial waste management services, that minimise wider impacts such as air pollution and waste crime. We want a clear focus on businesses and materials where specific barriers exist to improving recycling.

Building on measures already in place or underway, the measures proposed in this package aim to:

  • Improve commercial waste data

There is currently no detailed data or analysis of commercial waste at a national level or internationally. A better understanding of the composition of commercial waste streams will help design interventions that maximise prevention, reuse, and recycling.

  • Provide incentives for commercial businesses to increase reuse and recycling

The Waste (Scotland) Regulations 2012[78] require producers of waste to separate recyclable materials from non-recyclable waste. However, the risk of regulatory action may not be a strong enough incentive for smaller businesses which can face high staff turnover and have limited time and resources. Market competition and profit margins often provide a disincentive to move towards more sustainable procurement, products, and business models.

  • Support investment in commercial waste collection services

Commercial waste service provision is highly competitive, faces tension between operating costs and maximising recycling performance. High performing commercial waste services require significant ongoing investments, and the certainty to make that investment.

  • Tackle waste crime

During the COVID-19 pandemic, SEPA noted an increase in waste services being advertised via informal channels, such as social media. This highlights that waste crime continues to operate in the waste sector in Scotland, undercutting legitimate operators for collections.

Where we are now

SEPA estimates that the commercial and industrial recycling rates are currently 53%, and waste has steadily reduced year on year with a 22.1% decrease between 2011 and 2018.[79] The changes in commercial waste management are significant and highlight the success of the waste industry in supporting their customers to recycle more and dispose of less. The most significant changes between these periods include:

  • Separately collected food waste more than doubling from 123,904 to 329,787 tonnes.[80]
  • An increase in separately collected glass (79%) and plastics (36%).
  • Mixed municipal waste nearly halving from 1.35 million to 721,797 tonnes.

Changes in how we use some materials has had a significant impact on the waste requiring management.[81] For example, there has been little change in industrial wastes (e.g. agricultural, chemicals). Recycling rates are influenced by a wide range of factors, including the variety of products and materials used by business, data uncertainty, price volatility, product design, limited service provision, confusion, time, money and human resources. The largest sector for waste production, construction & demolition, is addressed separately in Package 5.

What we have done

Scotland's landmark 2012 Waste (Scotland) Regulations which place requirements on all waste producers (except householders) to take all reasonable steps to present key recyclable wastes separately for collection.

A range of business support services are available to identify and implement energy, water, and waste saving measures to embed better environmental performance.[82],[83],[84],[85].

What we are already doing

[From 2022]

We will introduce a new £2 million Textile Innovation Fund in the first half of 2022 to support businesses working in this sector to address issues associated with textile waste and throwaway culture.

[From 2022]

As set out in our Food Waste Reduction Action Plan (2019), we intend to break down barriers to food recycling by consulting on the current rural exemption and food separation requirements for food waste collections in 2022.

[From 2022]

We are working with the fishing and aquaculture industries to improve waste management of end of life gear, developing a system with other UK administrations that will support the collection and recycling of these items. To enable easier recycling, the Scottish Government is also working internationally on the development of a CEN standard[86] for the circular design of fishing and aquaculture gear.

[From 2023]

The Scottish Deposit Return Scheme (DRS) will launch across the whole of Scotland on 16 August 2023. The scheme will introduce a 20p deposit on single-use PET, steel, aluminium, and glass drinks containers, which will be refundable once the container is returned for recycling. It is anticipated that the scheme will produce a modest improvement in the commercial and industrial recycling rate by reducing the amount of material in the residual waste stream.

[From 2024]

We will introduce extended producer responsibility (EPR) schemes for packaging, waste electrical and electronic equipment (WEEE) and batteries. Schemes are currently being reviewed at UK level, and we are committed to developing legislation to fully implement schemes in Scotland. We expect packaging EPR to begin from 2024, with implementation dates for other schemes still to be confirmed. All schemes aim to increase the recyclability of products and increase capture at end-of-life. Packaging EPR is anticipated to increase recycling rates for packaging materials to 75% by 2032. Payments will be distributed to local authorities to cover the costs of providing effective systems for managing household packaging waste, which is likely to lead to significant changes in the funding model for local authority collection services.

[From 2024]

We are developing a digital waste tracking service in partnership with the UK government and other administrations. The service will make it easier to monitor waste and resources in real time throughout the economy, adding value for all users via a simple-to-use service. We conducted a joint consultation on the service from January to April 2022,[87] and anticipate that the service would be introduced from 2024.

[From 2022]

We are taking forward a range of measures to address waste crime. Illegal waste activities have no place in Scotland, undercut legitimate operators, and remove materials from the circular economy. In 2022, we launched a Flytipping Forum to support effective, coordinated action on flytipping, and will publish a new Litter and Flytipping Strategy. Our consultation on the draft strategy[88] proposed action to strengthen enforcement measures, including raising fixed penalties, improving data collection, supporting private landowners and promoting responsible behaviours. Flytipping has also been on the agenda of the Serious Organised Crime Taskforce; and partners on the Taskforce will continue to use every means at their disposal to disrupt this crime.

To strengthen the current enforcement regime, we propose to introduce a new enabling power in the Circular Economy Bill that will allow a fixed penalty notice to be issued to the registered keeper of a vehicle[†] when a littering offence has been committed from that vehicle. This will both increase the deterrent effect and the options available to enforcement officers in tackling roadside littering.

What we are proposing to do

SEPA has produced 16 specific sector plans, which identify opportunities for businesses to move beyond compliance on a sector by sector basis; with a further 17 sectors identified for future plans.[89] The measures set out below highlight cross-sectoral opportunities to support progress towards our waste and recycling targets.


1. We will conduct a national compositional study of waste from commercial premises by 2024.

There is currently no detailed data or analysis of commercial waste at a national level, so it is unknown how much recyclable material is contained in residual commercial waste. Data from households suggest that 60% of residual waste could be recycled through existing services; a similar figure for commercial waste would represent a significant opportunity to improve recycling rates, as well as a sizeable carbon saving.

We propose to conduct a national compositional study of residual waste from commercial premises by 2024, in order to identify priority materials, products and sectors for waste prevention and recycling interventions. From 2025 onwards, we will begin a rolling assessment of commercial waste so that we can assess change over time and evaluate the impacts of interventions.


2. We will review compliance with recycling requirements by 2024.

The Waste (Scotland) Regulations 2012 require commercial premises to segregate paper, card, plastic, metal, and food waste for recycling. We propose to work with SEPA to review current compliance levels and understand the barriers to participation. We will use the review to support compliance and develop further interventions to maximise waste prevention, reuse, and recycling.

From over 4000 inspections carried out in partnership with Local Authorities, SEPA estimates that around 60% of businesses had the correct recycling infrastructure and were using it, 20% were at least attempting to recycle, and 20% did not have the necessary infrastructure.


3. We will co-design measures to improve commercial waste service provisions that drive waste prevention and reuse by 2025.

Following our waste compositional analysis (measure 1) and review of compliance (measure 2), we propose to work with key stakeholders to co-design a package of interventions which seek to improve performance in prevention, reuse, and recycling across the commercial sector.

While enforcement is one aspect of encouraging behaviour change, we are keen to understand the market incentives that drive performance, opportunities to engage small and medium-sized enterprises (SMEs), and what more can be done to address the challenges faced by businesses. Possible interventions include targeted communications and engagement, fiscal measures that incentivise recycling or waste prevention, and procurement advice and guidance.

We will particularly prioritise improvements in food waste recycling from commercial premises, given the important contribution this will make to further increasing recycling rates while reducing the carbon impact of Scotland's waste. While food waste prevention measures are addressed in package 2, we want to maximise recycling where unavoidable food waste does arise.


4. We will research and pilot commercial waste zoning approaches by 2024[†]

We propose to investigate the application of commercial waste zoning in Scotland to drive consistency, performance, and compliance of recycling, and generate wider social and environmental benefits. We propose to take the necessary powers to explore and trial commercial waste zoning approaches in Scotland through the Circular Economy Bill.

Zoning has been utilised in a number of locations[90] to encourage collaboration and reduce local environmental impacts, such as a reduction in local air quality caused by multiple vehicles providing the same service in the same area. Analysis by WRAP has suggested that businesses could save up to 40% by collaborating on service procurement.[91] Collaboration could also improve service consistency and improve recycling performance through optimised efficiency of collections.

Commercial waste zoning has not been tested in Scotland, and we recognise that it could pose several challenges. These include the administrative burden to define zones and manage contracts, the impact on waste service providers, implications of reduced competition, and overlap with local authority services. We will conduct research on the feasibility of a zoning approach and run trials with partner organisations to understand the feasibility of wider rollout.

Figure 7: Actions to improve recycling from commercial businesses
This shows the proposed timeline of existing and new proposed actions by the Scottish Government to improve recycling from commercial businesses, from 2022 to 2030. These measures are set out in the text above.

Consultation questions

Question 7. To what extent do you agree with the measures proposed in this package to improve recycling from commercial businesses? Please provide evidence to support your answer if possible.

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

Question 8. Are there any further measures that you would like to see included in the Route Map to improve waste recycling from commercial businesses?



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