Waste Reprocessing Infrastructure in Scotland

1. Introduction

Purpose of this report

This waste reprocessing infrastructure report has been prepared by Scottish Government in line with requirements in section 23 of the Circular Economy (Scotland) Act 2024^[3] (“the Circular Economy Act”). The report sets out the current, planned and proposed waste reprocessing infrastructure in Scotland, and the policies of Scottish Ministers which are in place to support its use and development. Information is supported by research conducted by Zero Waste Scotland.

For the purposes of this report, reprocessing is considered to include the various steps involved in recovery operations by which waste materials are reprocessed into products, materials or substances whether for the original, or other purposes, across the whole material value chain.

The report does not consider waste disposal sites (for example landfill), energy from waste, or bulking and transfer stations except where material is treated on site. The report also does not consider reuse, refurbishment or repair of products; it applies only to the reprocessing of constituent materials. An independent review of Scotland’s incineration capacity was conducted in 2022^[4], with a follow up assessment published last year^[5]. Separate research on Scotland's landfill capacity has been commissioned by Zero Waste Scotland.

The report summarises the current, planned and proposed waste reprocessing infrastructure across Scotland, the main barriers and opportunities for its future development, and the key policies in place to support the material value chain. Individual chapters for each material stream provide data on waste arisings and capacity. It provides a baseline to underpin further sector engagement and policy development, based on replicable, publicly available data sources. The report focuses on fifteen material streams which comprise the majority of waste arisings in Scotland^[6].

All policies described in this report are existing Government policies or proposals; it does not set out any new policy commitments or proposals. Regard has been given to the National Planning Framework 4 (NPF4) throughout this report and reference is given to other Scottish Government publications where relevant. Key challenges and opportunities highlighted by the analysis will be considered through the forthcoming Circular Economy Strategy required under the Circular Economy (Scotland) Act 2024, and inform ongoing policy discussions in Scotland and with the other UK nations.

Scotland’s Circular Economy

A circular economy, based on sustainable consumption and production, is essential to power Scotland’s transition to a fair, green and sustainable economy, and critical to meeting our obligations to tackle the twin climate and nature emergencies.

This means minimising our demand on primary resources and maximising the reuse, recycling and recovery of resources, rather than treating them as waste. Keeping materials in productive use for as long as possible will reduce the carbon and biodiversity impacts associated with the extraction and disposal of raw materials, support resource security, particularly of critical raw materials, and provide economic and job creation opportunities in Scotland.

To achieve this, we are committed to delivering a different approach to our economy, one where we move from a "take, make and dispose" model to one where we value materials and keep them in use. The Scottish Government’s key policies to achieve this are set out in Scotland's Circular Economy and Waste Route Map to 2030^[7], which focuses on:

• Responsible Production, where a circular economy is embraced by the businesses and organisations that supply products, ensuring the maximum life and value from the natural resources used to make them.
• Responsible Consumption, where people and businesses demand products and services in ways which respect the limits of our natural resources. Unnecessary waste, in particular food waste, will be unacceptable in Scotland.
• Maximising Value from Waste and Energy, where the environmental and economic value of wasted resources and energy is harnessed efficiently.

The Circular Economy and Waste Route Map identified waste reprocessing infrastructure as a key element in delivering this transformation. Appropriate domestic reprocessing supports our recycling objectives and offers significant opportunities for job creation and economic growth, as we retain material value within the Scottish economy. This underpins the need to identify future strategic infrastructure requirements, both in Scotland as a whole, and on a place-based basis. As part of this work, we need to understand the available waste reprocessing capacity for material resources in Scotland, and the opportunities and barriers associated with future development of domestic reprocessing, where it is appropriate and economically viable to do so.

Exporting materials for reprocessing may be the most appropriate approach in certain instances. There are already functioning markets for many materials, which include both export for reprocessing elsewhere, and import of some materials for reprocessing in Scotland. However, our objective is to manage and process as much as possible here in Scotland, taking responsibility for reducing emissions and waste, and preventing the loss of local economic opportunities. Reflecting this, NPF4 identifies Circular Economy Materials Management Facilities as a National Development, and the Circular Economy (Scotland) Act 2024 requires that in development of the circular economy strategy, Scottish Ministers must have regard to the desirability of the economy being one in which waste is managed in Scotland where it is appropriate to do so.

Data limitations

Waste arisings and material flows

The primary data sources for this work are the Scottish Environment Protection Agency (SEPA) Waste from All Sources (WFAS) database^[8] and the SEPA Waste Sites and Capacity Tool^[9]. These sources provide information on the quantity of material that arise within Scotland. However, the data do not always indicate the proportion of material that is available for reprocessing further down the supply chain, for example if transported to a different facility.

Material-specific information is based on European Waste Catalogue (EWC) codes. EWC codes do not capture all waste streams, particularly textile products and those that form part of the bioeconomy^[10][11][12]. This means that there is a lack of data available for some material types. Where this is the case, information has been sourced from alternative data sources as far as possible.

Existing reprocessing infrastructure

Existing and planned reprocessing infrastructure are mapped based on information published by SEPA and Scottish Local Authorities. SEPA’s publicly available tool: Scotland’s waste sites and capacity data tool^[13], provides data on the waste management sites in Scotland that are regulated by SEPA. The tool includes the numbers, types, locations and capacities of these sites, with data available up to 2023. Waste data^[14] are also available via Scottish Waste Site returns, which displays a summary of wastes managed by individual facilities on a quarterly/annual basis. Where other data have been utilised sources have been referenced. SEPA has also previously published capacity gap reports with the last published in 2018 but running to 2025^[15].

Planned and proposed reprocessing infrastructure

There is no centralised database with a list of all planned waste facilities in Scotland. To understand what waste reprocessing facilities are currently in the planning pipeline, a review of the planning portals for each of the 32 local authorities was undertaken. This provides the most systemic available approach to determining planning reprocessing infrastructure, on the basis of information that is formally available and therefore not subject to ongoing commercial sensitivity or other limitations.

This approach cannot provide a complete picture of all planned and proposed waste reprocessing infrastructure. Some facilities only need permitting consent for their operations, and some waste operations are exempt from requiring a waste management licence^[16]. It also cannot include prospective reprocessing facilities for which a planning application has not yet been submitted. As with any planning application, situations can change and applications can be amended or withdrawn, making it difficult to state with certainty future pipeline capacity until a facility is being constructed.

Full information on each facility, including permitted capacity, planning status, and relevant dates are set out in Appendix 2.