Draft circular economy strategy: strategic environmental assessment

5. Assessments of Likely Environmental Impacts

5.1 Built Environment

The Strategy sets out the intention to promote the adoption of lifecycle assessments for buildings. This will increase awareness of the embodied carbon of building materials, a first step towards encouraging businesses to opt for lower carbon building materials, or to reduce these impacts by adopting circular economy practices such as favouring second hand goods and choosing repair and refurbishment over purchasing new materials and components. In the medium term, this is likely to reduce the demand for new materials and components.

The Strategy also commits to working with the construction sector to develop a roadmap for the built environment. As the content of the roadmap is not yet known, this was excluded from the assessment.

5.1.1 Climatic Factors

All stages of a construction project contribute to climate change through the production of greenhouse gases (GHG): extraction of raw materials, transformation of materials into products and components, transportation of materials to the construction site, the construction process, the use and maintenance of the building or infrastructure, and the ultimate demolition and disposal of materials. All of these activities demand materials and/or energy, often derived from fossil fuels, and are therefore direct drivers of GHG emissions. The proportion of new buildings’ whole life GHG emissions resulting from embodied carbon is believed to be increasingly significant as measures to date have been more focused on targeting operational emissions and waste management^[80]. The World Green Building Council reported that 11% of global energy related carbon emissions are attributed to emissions embodied in the construction process^[81].

Promoting the adoption of lifecycle assessments for buildings is a first step towards reducing such emissions. With continued support and regulation, future interventions related to this priority have the potential to enable informed choices around lower carbon materials and promoting circular economy practices in the construction sector. In turn, this would reduce the demand for virgin raw materials and the manufacturing of new products and components, and thus the GHG emissions associated with these activities.

The impact of this Strategy priority on the SEA objective to “minimise the GHG emissions resulting from production, consumption and disposal of resources” is therefore assessed to be positive but indirect.

The Strategy priority to increase the reuse of construction materials is also expected to have a positive impact on climatic factors through the displacement of new components and virgin materials (and the emissions required to extract and producer them). Reusable elements would need to be transported to a storage location and then onto the new site. This activity is expected to produce a significantly lower amount of GHG emissions compared to the extraction, manufacture, and transport of new materials combined with the disposal of the products and materials which are instead diverted to reuse. The impact of this Strategy priority on climatic factors is therefore assessed to be positive.

SEA Assessment Significant Positive: ++ A reduction in GHG emissions is expected from the reduced demand for new building materials. This will significantly offset any negative impacts.

5.1.2 Biodiversity

Worldwide, the built environment sector is believed to be responsible for 30% of biodiversity loss^[82], and threats from infrastructure and the built environment impact 29% of threatened and near-threatened species ^[83].

The extraction and production of the new raw materials commonly used in construction can have the following negative impacts on biodiversity, according to Expedition Engineering (2024)⁸³:

• Quarrying for limestone requires land use, though mandatory rehabilitation has the potential to create longer term net gain if sites were previously on poor land
• Cement production causes air pollution.
• Aggregate mining and dredging in the UK can damage habitats.
• Iron ore and coal mining in the UK supply chain damages both marine and land habitats and pollutes groundwater.
• Steel production, recycling, and even preparation for reuse, can cause air and water pollution.
• Timber production has a significant impact on biodiversity, which can be improved by using timber from FSC and PEFC certified sources, where the development of monocultures and use of pesticides are prevented.
• The extraction and transportation of crude oil to produce bitumen can have significant negative impacts on biodiversity, despite regulation controlling the release of chemicals.
• The transportation of crude oil through pipelines generates pollution which can harm marine biodiversity.
• Limited evidence suggests the production of manufactured topsoil and removal of natural topsoil could impact biodiversity, though more research is needed on this topic.

Increasing the reuse of construction materials will reduce the demand for materials and their relating extraction and processing activities, thus limiting the potential for damage to biodiversity through habitat loss and pollution.

Indirect benefits to biodiversity are likely through avoided contributions to climate change, since climate change is currently responsible for between 11% and 16% of biodiversity loss worldwide^[84]. Adoption of lifecycle assessments for buildings will strengthen this benefit, though could go further to specifically consider biodiversity impacts as well.

Actions resulting from this Strategy priority are expected to have a net positive contribution towards the two SEA objectives:

• Protect species in Scotland by reducing degradation of habitats resulting from extraction and disposal of materials.
• Support the conservation of ecosystems through reduced waste and more sustainable use of natural resources.

SEA Assessment Significant Positive: ++ Both direct and indirect positive impacts are likely

5.1.3 Material Assets

The increase in reuse of construction materials is expected to increase the lifespan of construction materials, keeping them in use for as long as possible. In this way, this Strategy priority is expected to have a significant positive impact on the two Material Assets SEA objectives to:

• Minimise the use of virgin materials and promote the sustainable management of Scotland’s natural and manufactured assets; and
• Increase reuse, repair, and recycling rates to retain value and reduce reliance on finite resources.

SEA Assessment Significant positive: ++ Positive impacts are expected as a result of this Strategy priority under both SEA objectives. Negative impacts are not expected to be significant in comparison.

5.1.4 Landscape and Visual Impacts

Increasing the reuse of construction materials could have an indirect positive impact on landscapes and visual impacts as the need to dispose of these materials by landfill is reduced, and the risk of irresponsible disposal e.g. by flytipping may be reduced in the long term if perceptions of used materials as valuable construction material become more widespread.

Avoided material extraction activity is also expected to avoid potential negative visual impacts in Scottish landscapes surrounding the areas from which such materials are obtained.

Therefore, the Strategy priorities within this chapter are expected to positively contribute to the first two SEA objectives under Landscape and Visual Impacts:

• Reduce the negative visual impacts on Scottish landscapes resulting from the irresponsible disposal of materials;
• Minimise negative visual impacts resulting from infrastructure associated with resource extraction and disposal or reprocessing of materials.

The achievement of the third objective is dependent upon the appropriate management and efficient delivery of refurbishment activity and storage of reusable materials:

• Manage additional infrastructure requirements needed to enable circular economy practices in a way that avoids unnecessary negative visual impacts.

SEA Assessment Positive: + Positive impacts are expected in the medium-long term. Monitoring of visual impact of storage of materials to be reused can reduce potential negative visual impacts.

5.1.5 Air

Promoting reuse is anticipated to have the effect of lowering the demand for new construction materials, thus avoiding the polluting activities from material extraction. For example, brick kilns and steel and iron production are known to produce a significant proportion of global black carbon emissions ^[85].

Avoided waste disposal in favour of reuse of construction materials will also result in the avoidance of negative impacts on air quality and odour resulting from landfill and energy from waste plants. However, the observable impacts at these sites are not likely to be significant.

The proposals are therefore assessed to have a positive contribution towards the achievement of the following SEA objective:

• Improve air quality through reductions in the negative environmental impacts of resource extraction and emissions from waste disposal methods such as incineration.

SEA Assessment

Positive: +

Positive impacts are expected as a result of the reuse Strategy priority within this chapter. Negative impacts are not expected to outweigh likely benefits

5.1.6 Water

Construction activities can sometimes result in the pollution of marine environments. Serious environmental harm could result from such activities, such as excessive siltation from run-off, impeding fish migration or impacts on fish spawning^[86]. Reducing new material use in favour of reuse can minimise the risk of such damage.

The anticipated reduction in virgin material demand reduces water consumption through extraction and manufacturing activities (e.g. mining) as well as reducing the risks of water pollution. For example, removal of sand and gravel from riverbeds and sea beds can destroy marine ecosystems, leading to lower water quality, and water that comes into contact with the environmentally harmful waste from iron mining can become contaminated, though these impacts are more likely to affect areas outside Scotland^[87].

The avoided disposal of construction materials which are diverted to reuse may also have a minor positive impact on water quality in areas affected by leachate from landfill sites.

The Strategy priorities are therefore expected to have a positive impact on the following SEA objectives:

• Reduce the risk of water pollution from manufacturing and disposal of materials e.g. landfill leachate, wastewater from industrial processes, and microplastics in aquatic environments;
• Reduce water use through a reduction in virgin material production processes.

SEA Assessment

Positive: +

Positive impacts are likely, but are in large part indirect, uncertain, or partially offset by related carbon positive activities

5.1.7 Human health

Health impacts will vary depending on the types of material reused, so it is not possible to assess this at this stage.

SEA Assessment

Uncertain: ?

The net effect is uncertain as it will depend on the types of materials reused.

5.1.8 Soil

Actions that reduce demand for the extraction of virgin construction materials, resulting from built environment Strategy priorities, are likely to limit damage to soil quality. For example, quarrying for minerals necessitates the removal of top-soil and vegetation, and the disturbance of soil and vegetation during extraction of limestone and clay can increase the risk of erosion and run off, leading to sediments and pollutants entering the local environment. Likewise, for timber production, when the tree canopy is lost, the soil beneath becomes prone to erosion. This is then exacerbated by the use of machinery that compacts and degrades the soil further^[88]. Reducing the demand for new materials like these by promoting activities higher up the waste hierarchy such as reuse and refurbishment is therefore likely to have an indirect positive impact on soil quality in the long term, thus contributing to the following SEA objective:

• Support land stewardship and sustainable land use through the reduction of extractive and waste-intensive practices.

SEA Assessment

Positive: +

Positive impacts to soil quality are likely, but may be indirect or not realised immediately.

5.1.9 Cultural heritage and the historic environment

The proposed Strategy priorities are not expected to impact on the following SEA objective:

• Contribute to the preservation of cultural heritage and the historic environment by encouraging the retention, refurbishment, reuse, and repair of historic environment assets and materials.

SEA Assessment

None: /

No impacts have been noted.

5.2 Net Zero Energy Infrastructure

The Strategy aims to maximise the role of circularity for critical raw materials in Scotland, initially through research; and to work with the sector to develop a roadmap for Net Zero Energy Infrastructure. As the specific actions to be taken under each of these Strategy priorities has not yet been fully developed at the time of writing, these are considered out of scope of this assessment.

It is likely that the actions targeted at increasing circularity in this sector which result from the associated Strategy priorities, will lead to reduced demand for virgin materials and a reduction in disposal of used materials. The environmental consequences are therefore likely to be similar to those explored in the previous section within the Built Environment sector as a result of reduced material consumption. There is a high degree of uncertainty over the specific impacts at this stage as specific measures are yet to be defined.

5.3 The Food System

The Strategy sets out the ambition to improve circularity across the food supply chain. This ambition offers the opportunity to create new opportunities in the circular bioeconomy, to prevent process waste, and to displace virgin products with alternative by-products such as animal feed and green chemicals. At the current stage in development of the Strategy, specific actions to achieve this ambition, resulting from Strategy priorities, are not known.

The Strategy aims to develop effective options with stakeholders to support food waste reduction by businesses. It is expected that increasing awareness of food waste produced by businesses will be an important first step in reducing this waste as well as ensuring it is disposed of in the most sustainable way possible.

The Strategy sets out an ambition to develop an intervention plan to guide long-term work on household food waste reduction behaviour, noting that householders produce around 60% of Scotland’s food waste. Therefore, there is a significant opportunity to reduce organic waste arisings in this area, thus reducing the quantity of material treated by anaerobic digestion, composting, or disposed of in the residual waste stream. This in turn reduces the demand for the production of food which is ultimately wasted.

Further down the waste hierarchy, the Strategy also aims to explore improvements in collections of food waste from households. This Strategy priority is likely to increase participation with food waste recycling, thus further reducing the amount of organic matter disposed of in the residual waste stream. This is expected to increase the amount of material treated by anaerobic digestion and composting, thus increasing the availability of outputs such as soil improvers and biogas, and displacing consumption of virgin alternatives.

The net effect of these interventions combined on the total amount of food wasted and then recycled is not known but will continue to be monitored by SEPA.

The Strategy also commits to working with the sector to develop a roadmap for the bioeconomy. As the content of the roadmap is not yet known, this was excluded from the assessment.

In their feedback at the Scoping Stage of this assessment, NatureScot highlighted the importance of including the bioeconomy in the Strategy, stating that: “The main benefits of a circular economy for biodiversity, climate factors, landscape and visual impacts, water and soil depend on extending a circular economy to the rural/biological economy, including, for example, key biogeochemical cycles”.

5.3.1 Climatic Factors

The Scottish Waste Environmental Footprint Tool (SWEFT) ^[89] found that food waste was among the top contributors to climate change of all household waste streams. The climate change impact of food waste is dominated by the embodied impacts of producing the food in the first instance. Therefore, the ambitions to reduce food waste generated in households, within commercial businesses, and throughout the supply chain, are likely to have a significant positive impact on climatic factors.

Measures to increase capture of food waste for recycling, such as improving household food waste collections, will also have a positive impact on climatic factors, since the GHG emissions per tonne of food waste treated by anaerobic digestion or composting are less than those associated with the disposal of food waste in the residual waste stream. This is because outputs are produced which can displace the production of chemicals and products such as fertilisers, soil improvers, and biogas.

While the net impact on the total tonnage of food waste destined for recycling as a result of the combined Strategy priorities in this chapter is not known, the impact under climatic factors is expected to be positive (i.e., to reduce GHG emissions). This is because the actions resulting from the Strategy priorities are expected to move organic material up the waste hierarchy: additional tonnes of food waste recycled are expected to in turn reduce those disposed of in the residual waste stream; and reductions in food waste sent for recycling are expected to be a result of avoiding the generation of waste in the first instance.

SEA Assessment

Significant positive: ++

An overall reduction is expected in the GHG emissions associated with organic waste management and the production of food which is ultimately wasted.

5.3.2 Biodiversity

Of all household waste streams, the latest SWEFT results find food waste to be the largest contributor to biodiversity loss, again dominated by embodied impacts from the production of food that is ultimately wasted^[90]89. These impacts are driven by climate change, acidification of soils, increasing levels of nitrogen and phosphorous in bodies of water, emissions of harmful chemicals, land-use and associated habitat loss, and water consumption.

If we reduce avoidable food waste, much of these embodied impacts could also be avoided. Recycling food waste has little effect in offsetting the biodiversity loss, this is because food waste is not recycled into new food, but instead used for energy or as compost/fertiliser^[91]89. Therefore, the Strategy priorities with the greatest scope to reduce biodiversity loss are those focused on reducing food waste generation.

SEA Assessment

Significant positive: ++

An overall reduction is expected in damage caused to habitats and species as a result of the production of food which is ultimately wasted.

5.3.3 Human health

The impacts of these interventions on human health are largely indirect e.g. a benefit to public health as a result of properly managed organic waste collections.

The Strategy priority with the greatest potential to impact human health is the ambition to introduce household food waste reduction behaviour interventions. There may be interplay between the waste prevention elements of these interventions and the food consumption behaviours within targeted households. For example, some food waste reduction interventions focus on encouraging the preparation of appropriate portion sizes, which could have the added benefit of encouraging healthy portion sizes, and thus discouraging overeating. Likewise, there may be health and safety benefits to interventions targeted at the appropriate storage of food to extend its lifetime e.g. through raising awareness of appropriate fridge temperatures to maximise food preservation. However, it is possible that some interventions could have unintended consequences relating to health. For example, if users are focusing on reducing food waste generation, they may be tempted to overeat to avoid leftovers going in the (food waste) bin. Until the nature of the specific interventions are known, it is not possible to assess the likely human health impacts.

When further developed, there is an opportunity for these interventions to contribute to the following SEA objective:

• Support improvements to human health by promoting food waste reduction behaviours in a way that complements wider policy goals on diet and healthy weight.

SEA Assessment

None: /

Impacts on human health are uncertain and/or indirect. There may be potential for some synergies between household food waste behaviours and healthy eating habits, but there in insufficient detail available at the time of writing to assess the likelihood, scale, and nature of such impacts.

5.3.4 Landscape and Visual Impacts

Visual impacts may be affected in some areas by the ambition to improve food waste collection services. In some cases, offering new services, such as additional food waste collections in areas of high-density housing, can involve the requirement to place additional communal bins on streets. In older, narrower streets, this may result in minor visual impacts.

The impacts are uncertain, as they are dependent on the design of any changes to collection infrastructure.

Positive impacts to Scottish landscapes as a result of reduced food waste, and reduced production of food that is ultimately wasted are expected to be indirect and not considered likely to be significant.

SEA Assessment

None: /

Impacts are uncertain in nature at this stage and are likely to be minor or indirect.

5.3.5 Air

The latest SWEFT ^[92] results consistently find food waste to be among the top five main contributors to air pollution due to embodied impacts from the production of food that is ultimately wasted. Therefore, actions discussed in this chapter resulting from Strategy priorities that aim to reduce food waste arisings, are expected to have an indirect positive impact on air quality.

We can therefore expect an indirect positive contribution towards the following SEA objective:

• Improve air quality through reductions in the negative environmental impacts of resource extraction and emissions from waste disposal methods such as incineration.

Since the landfilling of biodegradable municipal waste will soon be banned^[93], the scope to reduce air pollution impacts by diverting the waste management method for food waste is limited. Since the outputs of food waste recycling methods do not displace new food production, they do not offset air pollution impacts of food waste to any significant extent.

SEA Assessment

Positive: +

Indirect positive impacts on air quality are anticipated as a result in a reduction in demand for and production of food which is ultimately wasted.

5.3.6 Water

SWEFT^{[94] 92} reported food waste impacts among the two highest contributors to water consumption by a significant margin. Again, the impacts were driven largely by embodied production impacts, and therefore are not offset by diverting food waste to recycling.

Positive impacts can be expected on the contribution of wasted food to water consumption in Scotland, though effects are expected to be indirect.

SEA Assessment

Positive: +

Indirect positive impacts on sustainable water consumption are anticipated as a result in a reduction in demand for and production of food which is ultimately wasted.

5.3.7 Soil

Large areas of land are required for food production and manufacture. In some cases, this can result in soil degradation and contamination e.g. due to surface run-off and erosion. In particular, intensive agriculture has been linked to a decline in soil health and productivity^[95]. A reduction in unnecessary food production may reduce the extent of these negative effects. However, impacts are likely to be indirect and may take time to be realised.

There may be a change in demand for chemical fertilisers and peat-based composts as a result of changing quantities of food waste sent to anaerobic digestion and composting, both of which would have subsequent impacts on soil and peatland quality. However, the nature of this change is not yet known and cannot be assessed at this point in time.

SEA Assessment

Uncertain: ?

Impacts on soil quality are uncertain and indirect

5.4 Transport

Improving circularity of light goods vehicles and passenger vehicles includes the ambition to influence the design of vehicles, their maintenance, and their end of life treatment. Specific actions, relating to Strategy transport priorities, are expected to encourage eco-design of new vehicles to make repair and recycling easier, extending the lifetime of the vehicle and the materials and components used to produce it.

Increased reuse of parts will improve availability of second hand components, thus strengthening the repair industry, and reducing the requirement to import or produce new parts. Ultimately, this results in a reduction in demand for raw material extraction, manufacturing, and disposal of materials and components.

Encouraging domestic recycling of materials in end-of-life vehicles is considered as a potential action resulting from the Strategy priorities , which would further reduce the demand for virgin materials, and improve availability of secondary materials without the need to transport them long distances.

Incentives to light-weight vehicles would further reduce demand for raw materials, and would also reduce transport and disposal impacts at end-of-life.

Likewise, improving repurposing, recycling and material reprocessing of EV batteries will reduce the disposal of potentially environmentally damaging materials, and can reduce demand for virgin materials which can be displaced by reprocessed outputs.

5.4.1 Climatic factors

Reducing the demand for the extraction, manufacturing, and disposal requirements associated with passenger and light goods vehicles will in turn reduce the associated GHG emissions, limiting the sector’s contribution to climate change.

Encouraging lightweighting of vehicles will reduce the material requirements for such vehicles, as well as reducing the emissions produced during the use phase of the vehicle’s lifespan. This will further reduce the GHG emissions associated with these vehicles.

Encouraging the reuse of components used in electric vehicles may make it cheaper and easier to purchase and maintain such vehicles, thus encouraging lower carbon vehicle purchases. These impacts are uncertain as they are dependent upon the specific nature of future actions taken in this sector which relate to the Strategy priorities.

Strategy priorities within the transport sector are therefore anticipated to have a positive impact on the following SEA objectives:

• Minimise the GHG emissions resulting from production, consumption and disposal of resources. 

SEA Assessment

Significant positive: ++

A reduction in GHG emissions from multiple stages of the lifecycle of vehicles is expected as a result of the proposed the Strategy priorities in this sector, though greater detail will be needed on the specific actions resulting from the Strategy priorities.

5.4.2 Biodiversity

The extraction and production of new materials and products used in the production of new vehicles can have negative impacts on habitat loss globally: 8% of mining-related deforestation is attributable to the motor vehicle sector (the second largest contributor after the construction sector)^[96]. Measures targeted towards extending product lifespans, reusing materials, and reducing demand for virgin materials will therefore have an indirect positive impact on biodiversity, though impacts are likely to occur outside Scotland.

Encouraging domestic reprocessing of materials may have a net positive impact on global biodiversity whilst disrupting local habitats and species, e.g. if reprocessing activity increases within Scotland. Reprocessing facilities must be managed appropriately to minimise the risk of introducing pollutants into local wildlife habitats.

Extending the lifespan of vehicles, and in turn reducing the amount of material disposed in Scotland will have a positive impact on wildlife and biodiversity in Scotland through the avoidance of associated pollution, water use, land-use, ecosystem disturbance, and GHG emissions^[97].

The Strategy priorities are expected to have a positive impact towards the achievement of the following SEA objectives, with some uncertainty around the location and nature of likely impacts:

• Protect species in Scotland by reducing degradation of habitats resulting from extraction and disposal of materials;
• Support the conservation of ecosystems through reduced waste and more sustainable use of natural resources.

SEA Assessment

Positive: +

Positive impacts on biodiversity are anticipated within this sector, with some uncertainty noted.

5.4.3 Material Assets

Both proposed Strategy priorities within this chapter aim to extend the lifetime of valuable materials, keeping them in use for a longer time instead of being disposed, thus contributing to the following SEA objectives:

• Minimise the use of virgin materials and promote the sustainable management of Scotland’s natural and manufactured assets;
• Increase reuse, repair, and recycling rates to retain value and reduce reliance on finite resources.

SEA Assessment

Significant positive: ++

Positive impacts are expected on preserving the value of material assets in the transport sector.

5.4.4 Air

The priorities set out in the Strategy are anticipated to reduce the air pollution associated with extraction and production of materials and components used in the production of new vehicles as some of this activity can be displaced by increased reuse, repair, and refurbishment activity. However, it is likely that a large proportion of these impacts will occur outside Scotland.

Increasing the availability of refurbished and second-hand parts for electric vehicles may make the purchase and maintenance of such vehicles more affordable and accessible in Scotland. Though these impacts are uncertain, there may be positive impacts on air quality if the measures are successful in encouraging the use of electric vehicles in favour of petrol and diesel engines. However, it should be noted that active travel and public transport must be encouraged as a priority over private vehicle use in order to fully maximise improvements to air quality in Scotland, as electric vehicles still contribute to congestion and pollution from tyres.

While increased reprocessing and domestic recycling of vehicle components in Scotland will bring down global air pollution impacts associated with the production of new components, this activity may have the effect of bringing air pollution impacts of reprocessing activity (and associated transport impacts) into Scotland. Therefore, while the global impact may be net positive, the negative impacts felt within Scotland could increase.

SEA Assessment

Positive: +

Positive impacts are expected, though there is some uncertainty and benefits are likely to offset by some negative air pollution impacts increasing in Scotland.

5.4.5 Water

The European Environment Bureau estimates that the production of a single 1500kg combustion engine car requires over 400,000 litres of water across the value chain^[98]. The measures aimed at extending the lifespan of vehicles have the potential to reduce the demand for new vehicles, and the associated water use in the long term. It is expected that these impacts would occur largely outside Scotland.

SEA Assessment

Uncertain: ?

Positive impacts are expected, though may take some time to be realised and there is some uncertainty around the extent to which used vehicles and parts will displace more new vehicles as a result of measures within the Strategy. Impacts are likely to be widespread, largely occurring outside Scotland.

5.5 Textiles

The Strategy states an ambition to align with the EU Strategy for Sustainable and Circular Textiles^[99] where appropriate, a strategy focused on supporting the sustainable production and consumption of textile products. The EU strategy includes the ‘right to repair’, which, if adopted in Scotland, would improve the repairability of clothing and accessibility of repairs for consumers. Combined with eco-design and durability standards, this is anticipated to increase the average lifespan of clothing and textile products, thus delaying and reducing the demand to replace them with new products, and reducing the quantity of textiles disposed.

Future actions, which may result from Strategy priorities, such as the introduction of digital product passports and the restriction of textile waste exports will improve the transparency of the end-of-life destinations for waste textiles, which in turn is expected to incentivise responsible disposal methods, prioritising reuse and repair wherever possible, and repurposing or recycling of materials when garments are no longer wearable. The option to introduce a ban on the destruction of unsold textiles and footwear would further reduce the disposal of wearable textiles, both avoiding the associated disposal impacts, and displacing the need for the production of new garments.

Other actions, relating to Strategy priorities, will focus on increasing recycling of textiles that cannot be reused. These activities are expected to divert textiles from disposal by landfill or incineration, whilst increasing the availability of secondary materials. This could be supported by setting minimum recycled content standards for textiles, thus increasing both the demand and supply of quality recycled materials. User accessibility would be maximised by improved collection of used textiles, such as kerbside collections. There may be some conflicts between measures: e.g. if recycling of textiles becomes easier than repairing an item or donating it to a charity shop, perverse incentives are created to divert waste lower down the waste hierarchy.

The ambition to support sustainable alternatives to fast fashion is likely to further support these outcomes, but cannot be assessed in full until specific actions resulting from Strategy priorities have been defined.

The Strategy also commits to working with the sector to develop a roadmap for textiles. As the content of the roadmap is not yet known, this was excluded from the assessment.

5.5.1 Climatic factors

Out of all the household waste streams, textiles waste has the biggest impact on climate change, largely driven by the embodied production impacts^[100]. Measures which drive used and unsold textiles higher up the waste hierarchy, displacing the need for the production and manufacturing of new materials and garments will reduce these impacts. The Strategy priorities are therefore expected to have a positive impact on climatic factors, particularly those focusing higher up the waste hierarchy.

These measures are therefore likely to have a positive contribution towards the achievement of the SEA objective:

• Minimise the GHG emissions resulting from production, consumption and disposal of resources. 

SEA Assessment

Significant positive: ++

A reduction in GHG emissions is expected by multiple Strategy priorities targeted at driving textiles higher up the waste hierarchy and extending the lifetime of garments and related products. Some uncertainty remains around specific actions, resulting from Strategy priorities, and the interplay between them e.g. a potential conflict between improving accessibility of textiles collections for recycling and encouraging reuse and repair.

5.5.2 Biodiversity

Textiles waste is the second largest contributor to biodiversity loss after food ^[101]. Measures such as improving access to repair services and encouraging sustainable alternatives to fast fashion will reduce biodiversity impacts by increasing the lifespan of garments and thus lowering the demand for new textile products.

While increasing recycling of textiles into new materials will have some potential benefit to biodiversity, this is dependent upon the recycled materials displacing the production of new fabric, and on the adoption of sustainable recycling processes.

These measures are therefore likely to have a positive contribution towards the achievement of the SEA objective:

• Protect species in Scotland by reducing degradation of habitats resulting from extraction and disposal of materials;
• Support the conservation of ecosystems through reduced waste and more sustainable use of natural resources.

It should be noted that biodiversity loss resulting from the extraction of the raw materials used to produce textiles and the manufacturing of garments are likely to occur largely outside Scotland.

SEA Assessment

Positive: +

A reduction in contribution to biodiversity loss from waste textiles is expected as a result of multiple Strategy priorities and likely associated future actions targeted at driving textiles higher up the waste hierarchy and extending the lifetime of garments and related products, thus reducing the demand for new materials. Impacts are uncertain as they are dependent upon the assumption that increased reuse and extension of the lifetime of clothing will displace the consumption of new clothing. It should be noted that impacts are likely to occur outside Scotland.

5.5.3 Air

Textiles are the largest contributor to air pollution out of all the household waste streams^[102]101. As with climatic factors and biodiversity, if measures are selected to increase product lifespans through repair and design for durability, air pollution impacts associated with the production of new garments are expected to decrease.

We therefore expect the measures within this chapter to contribute to the first part of the following SEA objective, and additionally through the promotion of the use of electric vehicles:

• Improve air quality through reductions in the negative environmental impacts of resource extraction and emissions from waste disposal methods such as incineration.

SEA Assessment

Significant positive: ++

A reduction in contribution to air pollution from waste textiles is expected as a result of multiple Strategy priorities targeted at driving textiles higher up the waste hierarchy and extending the lifetime of garments and related products, thus reducing the demand for new materials. It should be noted that impacts are likely to occur outside of Scotland.

5.5.4 Water

Water consumption impacts resulting from household waste are dominated by textile waste (and food waste)^[103]101. Recycling and reuse help to offset some of the impacts of textiles, though the vast majority of impacts result from the production of materials in the first place.

As above, if measures are selected to increase product lifespans through repair and design for durability, water pollution impacts and water consumption associated with the production of new garments are expected to decrease. This will be partially offset by the water required for the washing of used textiles for reuse and resale, and water consumption associated with textile recycling.

The measures are therefore expected to have a positive impact towards the following SEA objective:

• Reduce water use through a reduction in virgin material production processes.

SEA Assessment

Positive: +

A reduction in contribution of both water pollution and water consumption from the production and disposal textiles is expected as a result of multiple Strategy priorities targeted at driving textiles higher up the waste hierarchy and extending the lifetime of garments and related products, thus reducing the demand for new materials. It should be noted that impacts are likely to occur outside of Scotland, and will be partially offset by the water required for textile recycling and the preparation of garments for reuse.

Policy Mechanisms

The following priorities were set under the ‘Policy Mechanisms’ chapter of the Strategy:

• Business support:
  • Support to business to increase circular practices and business models.
• Behaviour change:
  • Empower consumers and organisations to adopt circular behaviours.
• Place based approaches:
  • Expand a place-based approach to the circular economy.
• Procurement:
  • Promote circular purchasing through procurement practices.
• Skills and Education:
  • Increase uptake of circular practices through improved skills and education.
• Circular Economy Data:
  • Improve data availability, quality, and granularity.
• Policy alignment and systems thinking:
  • Integrate circular economy principles across policy.

These priorities have been excluded from the assessment due to their high-level nature, meaning the specific environmental consequences of them cannot be evaluated. However, it is anticipated that these Strategy priorities will support and embolden the consequences of the priorities within the sector-specific chapters of the Strategy, thus enabling and enhancing the environmental impacts identified in the preceding sections.

5.6 Cumulative effects

There are a number of synergies between different Strategy priorities and chapters within the Strategy, as well as among the different environmental topics.

It is anticipated that the cumulative impact across the different sectors will help to embed circular economy practices in Scotland, normalising circular business models and the use of second-hand materials and products. Removing negative perceptions around used goods in one sector, for example, could help to encourage reuse in another.

Strategy priorities and future activities relating to them within related sectors may also support each other if they help to build up relevant skills and expertise that could be used within both sectors. For example, Net Zero Energy Infrastructure and the Built Environment - overcoming logistical challenges around the storage, repair, and reuse of materials and components used in the Built Environment may also be applicable to Net Zero Energy Infrastructure projects. There may be opportunities to make use of transferable skills across the two sectors, for example, when it comes to refurbishment and repurposing of building materials.

In particular, the priorities within the ‘Policy Mechanisms’ chapter of the Strategy will help to maximise the benefits achieved through the sector-specific priorities and any associated future actions. For example, promoting opportunities to develop circular economy skills and education will be beneficial in building up the necessary expertise and experience needed to offer mainstream repair and refurbishment services; and addressing barriers to increase business and consumer confidence in circular business models will encourage more businesses of this sort, resulting in more competitive and affordable access to these services, for example, product-as-a-service contracts and product rentals. There will also be interplay between the different environmental topic areas. For example, impacts affecting climatic factors are likely to have knock-on effects across the other environmental topics. The World Economic Forum estimated that climate change is currently responsible for between 11% and 16% of biodiversity loss worldwide^[104]. This in turn can affect Scottish landscapes and visual impacts if flora and fauna which contribute the natural beauty of the local environment are affected. In turn, human health can be indirectly impacted by a change in the quality of our surroundings, such as green spaces in cities and natural landscapes which impact people’s mental health.

Comparison against reasonable alternatives

The reasonable alternative of a more ambitious timeline was considered against the results presented above.

Increasing urgency e.g. by attaching specific and ambitious timelines to the Strategy priorities would reduce the uncertainty in the assessed environmental benefits, thus improving some of the SEA scores.

The nature of the environmental impacts would be otherwise unchanged under an expedited version of the Strategy.