The Environment Strategy for Scotland: Consumer Duty Impact Assessment (CDIA)

Annex

Q20. Are there any positive or negative impacts from the draft Environment Strategy that have not been identified in the draft Consumer Duty Impact Assessment?

Two thirds (68%) of those answering Q20 expressed the view that there are no additional impacts from the draft Environment Strategy that have not been identified in the draft Consumer Duty Impact Assessment. The remaining 33% indicated there could be additional unidentified impacts.

Twenty-nine respondents provided a range of views on potential consumer impacts that they felt were not fully identified in the draft Consumer Duty Impact Assessment. Many respondents agreed that the Assessment is a helpful starting point, but requires more detailed analysis of affordability, access, communication, and regional differences.

Affordability

The most prevalent theme, raised by many respondents, was the risk that transition costs could be passed on to consumers and widen inequalities. Respondents noted that upfront costs for low-carbon heating, electric vehicles, and home retrofitting, as well as potential increases in energy and service charges, could disproportionately affect lower-income households and rural and island consumers. Some highlighted concerns about perceived reductions in product choice or a sense of consumers being priced out of sustainable options, describing a risk of elitism if support is not fair and accessible.

Access and inclusion

Several respondents raised a concern about unequal access to any benefits of transition measures. Respondents highlighted barriers for remote and island communities, digital exclusion for older or lower-income households, and uneven availability of public transport and recycling services. Island stakeholders noted higher costs and lower availability of waste and recycling services, with the risk that consumers in these areas may face reduced service levels or higher prices.

Consumer information

Several respondents stated that consumers require clearer, trustworthy information to make sustainable choices. They requested accessible guidance on energy efficiency, waste reduction and reuse, and sustainable travel, along with feedback on outcomes, to build confidence. Sector examples included calls for guidance on correct stove use and credible certification, as well as tailored advice for park home residents on retrofit options and likely bill savings. Several respondents called for sustained consumer engagement during implementation to identify unforeseen issues and ensure equitable benefits. They recommended targeted, plain-language communication and a mix of digital and non-digital channels to reach all consumers. Stakeholders suggested sector partners, such as CIWM Scotland, could help communicate guidance to specific consumer groups.

Consumer choice

Some respondents said the CDIA could better consider changes in product availability over time. They suggested that a shift toward more seasonal and plant-based foods may increase some choices and reduce others, which some consumers may welcome, while others may view it negatively. Other respondents cautioned that dietary messaging should be clear and balanced, noting the role of locally produced nutrient-dense foods such as lamb and seafood.

Disruption to services and places

Some respondents noted that delivery of environmental projects could cause temporary disruption to services or access to local spaces, for example, during the construction of flood defences or renewable infrastructure. A few respondents cautioned that poorly planned projects might inadvertently restrict access to valued natural spaces, with unequal effects for communities with lower mobility.

Small businesses as consumers

Some respondents highlighted that small and medium-sized enterprises are also consumers of energy, transport, waste and other services. They suggested that the Assessment could better consider the implications for SME costs, competitiveness, and access to information, especially for rural and family-run businesses.

Sector-specific consumer impacts

A few respondents raised sector-specific consumer issues. In aquaculture, it was believed that stricter measures might increase production costs and seafood prices for lower-income consumers in coastal and island communities. In the stove and wood-fuel market, consumer education and credible standards were viewed as crucial to prevent misuse and promote health and affordability. Island consumers were reported to face higher costs and lower availability of recycling services, which could lead to reduced participation and trust.

Digital opportunities

Some respondents highlighted potential positive impacts not fully emphasised in the Assessment. These included digital tools to support smart energy use and travel planning, lower long-term household costs from energy efficiency and circular practices, and consumer empowerment through reuse, repair and community-led initiatives.

Views on the Consumer Duty Impact Assessment

Some respondents viewed the draft CDIA as relatively slim and requested more detail on distributional impacts, affordability, and access. A few recommended clearer links to monitoring and evaluation, allowing consumer outcomes to be tracked over time. A few respondents requested sectoral case studies, regional analyses for islands and rural areas, and a clearer description of how communications and support will reach digitally excluded consumers.