Strengthening approach to household recycling collection services

3. Introduction

Proposals

The Scottish Government is consulting on the following areas:

• The current approach to the rural food waste exemption and whether that should continue in its current form, be amended or be discontinued.
• The approach to textile recycling, including whether to make kerbside collection of textiles by local authorities a mandatory service.

Following this consultation, we will analyse consultation responses in order to understand the full range of views on these three areas of household recycling collections. We will subsequently undertake any further supporting analysis required and impact assessment as needed.

The Scottish Government will use the findings of this consultation and any additional analysis to support development of the new household recycling Code of Practice through co-design with local authorities and other stakeholders to develop any final policy and implementation plan.

Contribution to Scotland’s key priorities

The First Minister set out the Scottish Government’s key priorities for Scotland in a statement to the Scottish Parliament:

• Eradicating child poverty
• Growing the economy
• Tackling the climate emergency; and
• Ensuring high quality and sustainable public services.

These aims are set out in the ‘2024-25 Programme for Government: Serving Scotland’^[1], committing the Scottish Government to drive a transition to a circular economy through supporting the Circular Economy (Scotland) Act 2024^[2]. The policy areas discussed in this document can contribute to helping to tackle the climate emergency and improving public services.

The Need for Change in Recycling Services

To ensure Scotland maximises value from its waste, changes to our recycling services are essential. We must accelerate progress to increase the recycling rate in Scotland by improving our recycling services. Between 2004 and 2011, Scotland’s household recycling rate more than doubled. However, in more recent years progress to increase household recycling efforts has slowed and Scotland’s rate remained at around 45% for several years. It fell back to 42% in 2020, in part due to the impacts of COVID-19 and we missed our target of a 60% household recycling rate by 2020. Since 2021, the recycling rate showed some signs of recovery, with the figure standing at 43.5% in 2023^[3].

The carbon impact of Scotland’s household waste is at its lowest levels since records began in 2011 with the waste management sector now only directly account for around 4% of total Scottish greenhouse gas emissions. ^[4] However Scotland’s Climate Change Plan^[5], reports that around four-fifths of Scotland’s carbon footprint comes from the products and services we manufacture, use and throw away - highlighting the need to continue progressing a reduction in greenhouse gas emissions in the waste sector.

The Case for Improvement

The Scottish Government’s Circular Economy & Waste Route Map^[6] set out actions to develop a more circular economy in Scotland, supported by new powers set out in the Circular Economy (Scotland) Act 2024^[7]. The Route Map sets out the strategic direction for delivering our system-wide, comprehensive vision of Scotland’s circular economy from now to 2030. We recognise the need to retain valuable material resource in our economy for as long as possible, reduce reliance on virgin resources and to reduce emissions.

Recycling helps to conserve our natural resources, keep valuable materials flowing through our economy and reduce the amount of waste sent to landfill. Disposal of valuable materials, such as plastics or metals, means these are lost from the economy. By 2030, we want a high-performing recycling system that has modernised recycling services for households and businesses across Scotland, optimised the performance of collection services, and can recycle most waste types to maximise diversion of waste from disposal. Increasing the number of materials recycled and increasing the proportion of these recycled in Scotland will deliver carbon reductions, reduce the environmental impacts associated with extracting new raw materials, and create a range of important economic opportunities to reprocess and reuse materials here in Scotland.

Only 1.3% of the resources Scotland uses are put back into the economy, with over 98% of Scotland’s material use coming from virgin resources. The country's (per capita) material footprint of 21.7 tonnes surpasses the global average of 11.9 tonnes and is close to three times what is considered a sustainable level^[8]. A circular economy approach could provide a continuous supply of these resources, often more cheaply than having to source new materials. Reducing the need for new materials can make supply chains more resilient and reduce associated environmental impacts.

However, the landscape of waste management continues to evolve, necessitating ongoing updates to our recycling services. The introduction of Extended Producer Responsibility (EPR) for packaging will ensure that producers bear the cost of an efficient and effective system for household packaging waste, further driving sustainable design and increasing recycling rates. The objective of this is to boost recycling rates for packaging materials to 76% by 2030^[9].

This is why we have already committed to introducing household collections for recyclable plastic film and flexible packaging by 31 March 2027.

Although significant investments have already been made, there is a need to further enhance our recycling infrastructure. The Scottish Government’s Recycling Improvement Fund, launched in 2021, has allocated over £66 million to 27 local authorities to improve recycling services, marking a substantial step forward for reuse and recycling infrastructure. These funds are driving crucial changes, such as increasing the frequency of recycling collections, expanding food and garden waste services, and improving the recycling of challenging materials like plastic films. These efforts are projected to increase recycling by over 60,000 tonnes per annum and projected to save over 59,000 tonnes of CO2e per year^[10].

Links to other policies

Co-Design of a Statutory Code of Practice for Household Waste Recycling:

The Circular Economy & Waste Route Map to 2030 prioritises the co-design of a new Code of Practice for household waste recycling under the strategic aim to Modernise Recycling. Currently, only a third of local authorities fully comply with the voluntary household recycling Code of Practice^[11], but under the Circular Economy (Scotland) Act 2024, adherence to the new statutory Code of Practice will become mandatory for local authorities.

We are in the early stages of co-designing the new Code of Practice with key stakeholders, particularly the local authorities that deliver waste and recycling services. Additionally, feedback will be sought from waste management businesses, householders, and other relevant parties. This consultation is only one part of engagement to establish an evidence base on which to co-design the new Code of Practice. The main goal of this co-design process is to ensure the new mandatory Code sets out an approach to increase recycling that is practical, effective, and feasible for local authorities and other service providers, rather than enforcing a rigid, top-down model. The Code should not only support environmental and climate objectives but also be deliverable across various regions, reflecting the diversity of local authorities in Scotland.

The co-design process aims to ensure the new Code of Practice is adaptable, considering differences in geography, demographics, housing, and existing infrastructure. While everyone should have access to consistent recycling services that make environmentally friendly choices easy, it is essential to recognise that different areas may require different approaches to service delivery.

The policy areas that are being consulted on are being explored in the context of the development of this new statutory Code of Practice and may form part of the co-design process depending on the findings of this consultation. Depending on future policy decisions, legislative change may also be required out with the Code of Practice.

Food Waste:

We continue to prioritise action to tackle food waste, given it is one of the most important ways that we can reduce the carbon impact of Scotland’s waste. We are working towards a 50% reduction in food waste by 2030, as outlined in the United Nations Sustainable Development Goals.

Actions contained within the Circular Economy & Waste Route Map, supported by powers detailed in the Circular Economy Act (Scotland) 2024, underscore our ambitions to work with businesses and households to prevent food waste. This includes requiring some businesses to report on food waste and surplus, encouraging householders to take different decisions regarding the purchase, storage and usage of food and reviewing the exemption on recycling food waste in some areas across Scotland.

Preventing food waste can help householders and businesses save money and reduce carbon emissions.

Product Stewardship for Textiles:

Scotland is actively exploring a range of approaches to address textile waste and create a more sustainable textiles sector. As part of this effort, the Circular Economy & Waste Route Map outlines pathways for reducing waste, promoting resource efficiency, and encouraging the reuse and recycling of materials.

A key element of Scotland's ongoing efforts is the development of a Product Stewardship plan with textiles identified as a priority product. While still in the early stages, this strategy aims to explore ways to encourage better product design, promote responsible production, and support more effective end-of-life management of textile products. These initiatives are part of a broader ambition to shift towards a circular economy for textiles, where waste is minimised and resources are maximised through reuse and recycling. As part of these efforts, Scotland is also working closely with other nations to identify shared challenges and solutions in the area of textile waste management. By collaborating with international partners, Scotland aims to benefit from global best practices, learn from others' experiences, and develop coordinated approaches to reduce the environmental impact of textile waste.

3.1 Review of Rural Food Waste Exemption

The Scottish Government is consulting on the current rural food waste exemption and whether that should continue in its current form, be amended or be removed.

The Environmental Protection Act 1990 requires local authorities to provide segregated food waste collection to householders and separately requires all food businesses producing more than 5kg food waste a week to ensure the separate collection of food waste unless the rural exemption applies.

The rural food waste exemption was included in the Environmental Protection Act 1990 when it was amended by the Waste (Scotland) Regulations 2012 due to the environmental and economic impracticalities of segregated collection from some rural areas. Cost effective collection requires high enough population density for efficient collection rounds and good proximity to treatment infrastructure. Major food waste treatment infrastructure is located across the central belt and in the east of Scotland.

The exemption is designed to prevent the positive impact of food waste recycling being offset by negative impacts of collecting and transporting waste from rural locations. For example, the potential benefit, in greenhouse gas emission terms of diverting food waste from landfill could be lower than the transport emissions associated with waste collection vehicles covering large geographical areas for small volumes of food waste. Additionally, on-site management options such as composting or diversion to animal feed or community-scale composting is potentially more widespread in these rural areas, potentially limiting the proportion of food waste being sent to landfill or incineration. It is also important to note that from 31 December 2025, biodegradable municipal waste (which would include both household and commercial food waste) will be banned from landfills. Therefore, if food waste is not recycled it will require to be incinerated from that date.

The exemption operates by permitting local authorities not to follow the requirement to provide a receptacle for separate collection of food waste if properties are located in areas designated as ‘remote small towns’, ‘accessible rural areas’ or ‘remote rural areas’ in the Scottish Government’s 6-fold Urban/Rural Classification of 2009-10. The background to this is set out in detail in ‘Defining rural and non-rural areas to support zero waste policies’^[12].

The most recent Scottish Food Waste Estimate (from 2021) from Zero Waste Scotland indicated that Scotland produced approximately 1.038 million tonnes of food waste that year. Of this, 59% came from households, 27% from food and drink manufacturing, and 14% from other sectors. This equates to approximately 4.74 million tonnes of carbon dioxide equivalents^[13].

Furthermore, Zero Waste Scotland’s Household Waste Composition Analysis^[14] indicates that from 2021 to 2023, households produced 440 thousand tonnes of food waste, approximately 174.5kg per household per year. Of this, it is estimated that 30.9%, or 130.8kg per household per year, is placed in residual waste bins and therefore not recycled.

The current rural food waste exemption is based on the 6-fold classification from 2009-2010 rather than the most recent update of the classification in 2022. The classification in 2022 includes fewer postcodes classified as rural due to demographic changes such as population increase and areas of new building. Adopting the 2022 classification would result in fewer postcodes being eligible for the exemption.

As of 2022, 80.3% of households live in areas with access to food waste collection^[15], in some areas co-mingled with garden waste. A lack of food waste recycling service for rural communities could be perceived as unfairly penalising those who live in such areas. Therefore, removing the exemption may provide a more equitable service, regardless of location. It is not known whether composting or other on-site treatment of food and organic waste is higher in rural areas.

With regards to household collections, an analysis of services in early 2020 highlighted that many local authorities are providing segregated collection of food waste even in exempt rural areas if they have determined it to be economically viable; examples include Aberdeenshire, South Ayrshire and Stirling. For others, ‘over and above’ collections were seen as prohibitively expensive. For example, one local authority estimated that providing full coverage to all households would cost up to £800,000 per year.

If current food waste recycling participation rates were maintained and taking into account the ‘over and above’ collections by local authorities, it is possible there would only be a limited amount of additional food waste captured by changes to the exemption.

The responses to this consultation will help to inform a decision whether or not to keep the rural food waste exemption unaltered, amend it to include or exclude additional areas by various means, such as updating to the 2020 urban/rural classification, or remove it entirely.

3.2 Kerbside Collection of Textiles

The Scottish Government is consulting on whether to make kerbside collection of textiles by local authorities a mandatory service.

The Scottish Government’s Circular Economy & Waste Route Map and 2020 Climate Change Plan update, made commitments to consult on the separate collection of textile waste from households. We are considering whether textile collections should be a mandatory requirement for local authorities in Scotland, as well as alternative approaches.

Textiles are not currently accepted for kerbside household recycling collection by any local authority in Scotland. The existing options include depositing textiles at a recycling centre; third sector recycling textile banks or collection options; donating to charity shops and through some high street clothing shops. Many options only accept clothing textiles and not other kinds, such as towels and sheets.

Textiles are not routinely recycled, contribute significantly to landfill and are a major source of waste sector emissions. The Zero Waste Scotland Carbon Metric shows textile waste made up 4% of waste in 2021 but 32% of the carbon impacts^[16].

The key rationale for the separate collection of textiles and textile strategy is to increase reuse, repair and recycling of textiles, alongside reducing textiles impact on the environment. Collections intend to increase volume of textiles collected and support a circular fashion system. In 2020, the EU generated 6.95 million tonnes of textile waste, with the majority of this ending up in mixed household waste.

Research and case studies from Europe show that there can be benefits to kerbside collection of textiles, particularly in improving convenience for residents, making recycling the easier choice, which boosts participation rates and reduces the amount of textile waste ending up in landfill. For example, the European Clothing Action Plan (ECAP) reported that kerbside collection systems have effectively increased textile recovery, thereby decreasing landfill dependency ^[17]. Additionally, a study by Zero Waste Europe highlights that municipalities with kerbside collection services have observed higher engagement from citizens, leading to improved sorting and recycling outcomes^[18]. These findings suggest that kerbside textile collection can play a significant role in promoting sustainable waste management practices across Europe. However, there are potential barriers to kerbside collection of textiles. These include low quality textiles, processing capacity and market demand, the cost of operating these services and the impact on the charity and third sector stock.

The introduction of kerbside textile collection by local authorities raises potential concerns about the impact on the third sector. Evidence from the Netherlands highlights negative reactions from charities that rely on resalable goods such as clothing^[19], noting that this shift could inadvertently divert donations from repair and reuse activities to recycling – preventing management of goods higher up the waste hierarchy. In order to support reuse organisations and avoid unintended consequences, the views of the third sector will be essential to understand how any changes to collection, alongside Extended Producer Responsibility (EPR) considerations, might affect their operations and to ensure that recycling initiatives do not undermine repair and reuse efforts.

It is notable, however, that an ECAP report on textile collections in European cities found that domestic reuse markets were limited to the top 10-20% in quality of used textiles^[20], underlining that alternatives to reuse further down the waste hierarchy still have a key part to play.

As part of their Strategy for Sustainable and Circular Textiles, the European Union (EU) have committed to revising the EU Waste Framework Directive to include mandatory and harmonised Extended Producer Responsibility (EPR) schemes for textiles in EU Member States. Under EPR schemes, companies that sell to consumers in the EU could be required to cover the cost of collection, sorting and recycling of textiles. Additionally, from 2025, under the EU Waste Framework Directive, EU Member States must establish a separate collection system for used textiles. This obligation does not require that collections must be at the kerbside.

In 2023 Defra noted that textiles will be excluded from UK Government EPR plans while they prioritise progress of packaging materials before considering inclusion of other materials. Defra is funding the “Textiles 2030” voluntary initiative which is supporting businesses and organisations within the fashion and textile industry to meet 2030 targets and transition to a circular economy.

The consultation aims to provide the Scottish Government with further intelligence and information from householders, local authorities and the third sector, on the impact and feasibility of household textile collections. This will help us to understand the benefits and challenges associated with mandatory kerbside textile collection or alternative provision to increase textile reuse and recycling. This will then allow the policy to be considered in the co-design of the new household recycling Code of Practice, if assessed to be practical and desirable, or what complementary measures may be required before textile collections could be established, either through legislative measures amending the Environmental Protection Act 1990, or through the implementation of voluntary measures.