Managing controlled waste - code of practice: duty of care - equalities impact assessment

Consultation

23. Proposals to require collection of plastic film were consulted upon as part of proposals for a UK-wide packaging EPR scheme. Three consultations have been conducted on these proposals:

• 2019. Consultation on reforming the UK packaging producer responsibility system^[24]
• 2021. Consultation on the introduction of Extended Producer Responsibility for Packaging^[25]
• 2023. Consultation on the draft Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024^[26]

24. Implementation of the requirement to collect for recycling of plastic films from the non-household municipal sector is taken forward through amendment of the existing Duty of Care Code of Practice for managing controlled waste. The Scottish Government published a further public consultation on the updated Code from 27 November 2025 to 5 February 2026.^[27]

25. The consultation included a number of questions with regards to various impacts assessments. This included the following question specifically in relation to people with protected characteristics

a. Is there any further evidence relating to the impact on protected characteristics that you would wish to be considered in updated impact assessments:

26. The 2025 consultation received responses from a range of organisations with responsibilities across the sector, including waste management, food and drink producers, local authorities, and other representative organisations. Respondents noted that staff responsible for waste segregation may include individuals with protected characteristics, and that any increase in workload, complexity, or manual handling requirements should be assessed for potential indirect impacts.

27. Consultation feedback has informed this EQIA and will inform implementation of new recycling requirements introduced under the Code. The Scottish Government has separately published a response to consultation feedback.