Strengthening approach to household recycling collection services: consultation analysis

3. Rural Food Waste Exemption

This chapter analyses responses to questions on the Scottish Government’s proposals to change the current rural food waste collection exemption. The Environmental Protection Act of 1990 required all Scottish local authorities to provide segregated food waste collection for households, and food businesses consistently producing 5 kg or more food waste a week must also segregate this from general waste and present it for separate collection. However, an exemption was included for rural areas to ensure that food waste collection was efficient, minimising any detrimental environmental impacts from the waste collection service. Rural exemptions were based both on population density and proximity to waste treatment facilities. The consultation asked whether the exemption should continue in its current form, be changed or be removed entirely.

This section of the consultation consisted of five questions, with a mix of open and closed components.

Among those answering, half were located in an area with a rural food waste exemption, 39% were not, and 11% were unsure. Organisations were more likely than individuals to be located in an area with a rural food waste exemption (63% and 37%, respectively). Of the 13 local authorities that answered Q1, 77% were located in an area with a rural food waste exemption.

At Q2, responses were split almost evenly, with 32% of those answering preferring to keep the rural food waste exemption as it is, 34% preferring to remove it, and 34% making other suggestions. More individuals supported removing the exemption compared to organisations (47% and 24%, respectively), while more organisations suggested alternatives than individuals (43% and 24%, respectively). Local authorities were split between keeping the rural food waste exemption (42%) and making alternative suggestions (42%), with 17% preferring it is removed.

Financial and resource implications

Just over one third of respondents provided further detail at the open question. Of those, the most common theme was concern about the financial and resource implications of changing the exemption. To reduced repetition, those responses have been analysed alongside similar responses which were also the most prevalent theme at Q5.

Keep the exemption as it is

Some respondents, primarily organisations, felt the food waste exemption should be kept in its current form. They expressed the view that removing the exemption in some areas would be unviable. Respondents felt it was unacceptable to expect people living in isolated or hard-to-access areas to comply with food waste collection requirements, as it would place an unfair burden on communities with limited access to services and infrastructure, as they may need to travel long distances to collection points or depend upon infrequent or unreliable waste services. One respondent noted that both urban settings, such as flats, and extremely rural areas could present significant challenges to adhering to food waste collections if the exemption were removed.

“We fully support retaining the rural food waste exemption and the exemption for all business producing less than 5kg of food waste per week.” - Charity Retail Association

A small number of respondents raised environmental concerns about extending food waste collections to remote rural areas, noting the potential increase in carbon emissions from additional vehicle use. These comments emphasised the need to consider rurality, waste volumes, and the net carbon impact to avoid unnecessary collections that may do more harm than good.

Remove the exemption

In contrast, some respondents felt that having an exemption in place is a barrier to developing the infrastructure for food waste collection and reprocessing in areas that are currently exempt. Two respondents commented on the exemption resulting in technological advancements lagging behind, with one respondent noting that separate food waste collection can be achieved using a dedicated section in a collection vehicle, avoiding the need for an additional vehicle and reducing associated carbon impacts.

“Collection systems and vehicles have evolved since the introduction of the exemption” - Dundee City Council

A few respondents raised concerns about how locations are classified as exempt, suggesting that some areas that are currently exempt should not be. For example, one noted that in Moray, some large commercial settings are exempt because they are in rural areas, despite generating substantial volumes of food waste.

“For businesses, there are many areas that are currently exempt from food waste collections, that both produce significant quantities of food waste and have access to a collection system (i.e. there is a service provided nearby). The current exemption is used as an ‘excuse’ to not treat this material higher up the waste hierarchy. Removal of this exemption would ensure this food waste will be captured and recycled” - REA - Renewable Energy Association

Resource Management Association Scotland supported a consistent requirement for segregated food waste collection across Scotland, noting that it would enable national-level campaigning and messaging to drive behavioural change, improve participation, and reduce contamination.

Composting

Some respondents proposed composting as an alternative to food waste collection in exempt areas. One respondent noted that many rural households have the space to manage food waste through methods such as closed-bin^[2] or hot-box composting^[3], and that promoting these practices could reduce the need for formal collection services. Others highlighted that rural areas often benefit directly from the outputs of composting – such as fertilisers and soil improvers – and should be supported to contribute to and make use of these processes locally.

Alternative suggestions

Some respondents proposed alternative suggestions for collecting or using food waste. These included:

• Combining services for efficiency with two respondents recommending integrating food waste collection with other services, such as textile collection, to improve efficiency and reduce logistical challenges.
• Improved household practices as one respondent calling for better separation of food waste from residual waste at the household level.
• Flexible collection frequency with another respondent suggesting that collection frequency be tailored to local needs, noting that weekly collections may not be necessary in all areas.

Another suggestion was reducing food waste through redistribution and community-based initiatives.

Vans collecting fruit and vegetables close to their use-by date could be collected from local supermarkets and grocer shops and delivered to local hubs to be given away free to those in need or used to provide healthy community meals. - Individual

Mandatory collection of food waste from commercial sources that generate significant volumes was called for by one organisation:

“Dependant on rurality, tonnage & carbon impact (we shouldn't be collecting just for the sake of it in extremely rural areas). That being said, we believe there should be consideration for compulsory collection of commercial food waste production when in large volumes. - Perth and Kinross Council

Two respondents called for a Scotland-wide review of the exemption criteria, emphasising the importance of modelling the net carbon impact of any proposed changes before implementation.

Among those answering Q3, 69% were likely to opt-in to a food waste collection service if their local authority were to offer it (65% very likely and 4% somewhat likely). Conversely, 8% were very unlikely to opt-in, and 23% were unsure. Individuals were likely to opt-in with 71% being very likely and 7% being somewhat likely. Organisations were either very likely to opt-in (58%) or unsure (42%). Of the seven local authorities who responded, 3 (43%) indicated they would be very likely to opt-in and 4 (57%) were unsure.

One third of respondents answered Q4. Of those answering, 14% currently use at-home composting to handle their food waste, no respondents take their food waste to a local recycling centre, and 88% use another method. Among individuals who answered, 25% use at-home composting and 75% another method. Of the organisations that answered, all except one local authority used other methods to manage food waste.

Other alternatives

One in five respondents provided further detail at the open question. In line with the focus of the question, some respondents provided examples of how they manage food waste. From most to least mentioned, these included:

• Home composting, including feeding food waste to hens, using hot-box composting for non-vegetable waste, and more general composting practices.
• Disposal of food waste in the general waste bin, either alongside residual waste or in non-recyclables.
• Minimising food waste by meal planning and avoiding overconsumption.
• Food waste is sent to an incinerator and turned into heat for the district heating.

Q5. Do you have any other views regarding the rural food waste exemption?

Just over half of respondents left a comment in response to Q5. However, the analysis below also includes comments raised at other questions in this section of the consultation, particularly Q2, where the themes aligned with those evident at Q5.

Financial implications

The most common theme at both Q2 and Q5, raised by several respondents including many local authorities and public bodies, was concern about the financial challenges of collecting and reprocessing of food waste. The costs associated with these processes were frequently highlighted, particularly in remote rural and island communities where it was felt that costs would be ‘unreasonably high’ due to the nature of the location.

Cost concerns were primarily raised by organisations rather than individuals. These challenges included:

• The need for investment in additional infrastructure, such as dedicated collection vehicles and storage facilities
• Compliance with strict contamination limits for organic waste, which may require costly monitoring and enforcement measures
• The perceived high expense of transporting waste over long distances to treatment facilities, particularly in remote or island areas where transport logistics are more complex and fuel costs are higher.
• Some highlighted that low volumes of waste and extensive collection networks make the service inefficient and costly in certain areas.

“The provision of the food waste collection service would not be cost-effective or efficient across the whole region, to collect small volumes of food waste. Services have already been reduced due to participation by members of the public being low in all areas. To increase service provision, considerable revenue budget provision would be required.” – Dumfries & Galloway Council

“To remove the rural exemption altogether would mean having to provide a separate small tonnage vehicle solely for the collection of food waste separately for these 200 households which being spread across the 2,500 square miles of Aberdeenshire would not be deemed as being efficient.” - Aberdeenshire Council

Some respondents were concerned that increased pressure on local authority budgets could impact other services, suggesting that Scottish Government funding would be necessary to cover the costs associated with expanded food waste collection.

Capacity and infrastructure concerns

Concerns around the capacity and infrastructure in place to collect and reprocess food waste were highlighted by some respondents at Q2 and Q5. A few respondents felt that the necessary infrastructure in some rural areas was insufficient and highlighted a lack of waste processing facilities. A few respondents mentioned the upcoming landfill ban on biodegradable municipal waste. These respondents noted that the ban could reduce disposal options and potentially increase costs for local authorities. For example, Perth and Kinross Council noted that separate food waste collections, as opposed to co-mingled food and green waste, would require investment in updated infrastructure.

At Q2, a few respondents also mentioned issues with the capacity to collect, with one suggesting that this could lead to non-compliance, i.e., households or local authorities not following the required rules or regulations for waste separation and disposal. Two respondents mentioned concerns about difficulties with reprocessing food waste and tighter controls on preventing contamination from mixing types of waste.

“Many Local authorities in Scotland currently collect comingled food and garden waste to make collections more efficient. There is concern from the market and local authorities about a potential lack of outlets and capacity, and subsequently increased disposal costs, in part due to the stricter limits on contamination (plastics) in post-consumer organic waste.” - LARAC

Efficiency concerns

Some respondents questioned whether the environmental benefits of food waste recycling in remote areas would justify the carbon and energy costs of collection.

“The cost, energy and carbon footprint for collecting food waste separately from a small population spread over such a wide geographical area would far outweigh any gains. Additionally, this material would likely be collected utilising smaller containers and experience has shown that anything smaller than a 240-litre bin put at kerbside is disproportionately affected by island winds, resulting in increased litter.” – Comhairle Nan Eilean Siar

A few respondents suggested that exemptions should remain in place for areas where collection is not economically or environmentally viable, and that on-site (i.e. at home) treatment using digesters may be more suitable. A few respondents noted that a one-size-fits-all approach may not be appropriate, and the carbon impact of collection should be weighed against the benefits on a case-by-case basis.

“The current approach, which makes provision for providing differing levels of collection services is sensible. This is especially so for food waste.” - The Highland Council

Shetland Council described local solutions created to combat the environmental impacts of food waste. It felt that these solutions are also efficient and offer an alternative to changing the current exemptions.

“Our current set up with the energy from waste incinerator feeding the local district heating scheme provides a good solution to food waste, while providing heat for over 1,300 properties in Shetland.” - Shetland Islands Council

Reasons to review or remove the exemption

A small number supported reviewing the current exemption area. It was suggested that rural classifications be updated and that some form of exemption be retained in remote or low-volume areas, with a focus on alternative treatment like on-site composting. Respondents suggested that some larger towns are currently included in the rural exemption and since creating the initial classification, collection systems and vehicles have evolved.

“We are not averse to a review of the current rural exemption and, at the very least, suggest that this is more closely aligned with the updated rural classification.” - Scottish Environmental Services Association

Other reasons for changing the regulations around the food waste exemption were highlighted by a small number of respondents. These included, from most to least prevalent:

• A belief that environmental goals must take precedence, and that removing the exemption is necessary to meet modern sustainability targets and reduce landfill.
• A concern that the exemption causes inequality by leaving rural residents with fewer waste disposal options and forcing them to take on personal costs to combat hygiene issues.
• Support for greater system-wide development, as it is believed that the exemption hinders progress in building better food waste collection systems and infrastructure, especially as technology and logistics have improved.

“The rural food waste exemption is effectively a barrier to changing the behaviour of food waste producers and to developing a collection system that would provide a cost-effective food waste collection service.” – Dundee City Council

Other suggestions

Some respondents provided other suggestions regarding the food waste exemption.

Less commonly mentioned suggestions made by respondents about food waste included:

• Emphasising avoiding food waste and promoting community composting.
• Introducing schemes involving local charities and local authorities to collect short-dated food to help those in poverty.
• Improving communication and environmental education to start behaviour change and empower communities to manage food waste in environmentally friendly ways.
• Combining food waste collection with other waste streams, like textiles, to improve cost-effectiveness.