Waste Reprocessing Infrastructure in Scotland

4. Policy landscape

The Scottish Government seeks to enable the appropriate development of domestic waste reprocessing infrastructure by ensuring a supportive policy landscape that incentivises Circular Economy outcomes, while recognising the complexity of the material value chain.

The materials reprocessing policy landscape in Scotland is considered across three dimensions that seek to maximise the value of material resources and keep them in productive use for as long as possible:

• Policies that support a stable supply of materials for reprocessing, by capturing and diverting materials from disposal that would otherwise become waste.
• Policies that stimulate demand for reprocessed materials and products, and in doing so reducing reliance on imported raw materials and the carbon and biodiversity impacts associated with virgin material extraction.
• Policies that support investment in material reprocessing, including the associated planning and infrastructure requirements, and potential financial seeding for emerging technologies.

It is rare to achieve a 100% capture or reprocessing rate for any material, but recycling rates upwards of 90% are achieved for certain products or materials such as drinks containers across Europe. Looking at the economy as a whole, over 98% of Scotland's material use stems from virgin sources, with only 1.3% of the resources Scotland uses cycled back into the economy^[26]. This compares to 7.5% for the UK as a whole, and 24.5% for the Netherlands^[27]. Availability and ease of access to collection infrastructure, knowledge of what can be recycled, an ability/desire to recycle, and the cost of collection all play a role in increasing capture rates and consequently increasing the amount of material available for recycling.

The Circular Economy Act sets out the legislative framework to support Scotland’s transition to a zero waste and circular economy. The Act requires that Scottish Ministers publish a circular economy strategy, which is currently in development. The Act also requires that Scottish Ministers Develop circular economy targets which are planned from 2027.

Scotland's circular economy and waste route map to 2030^[28] sets out the Scottish Government’s existing and planned policies measures to move towards a more circular economy. Measures that contribute to the development of appropriate domestic infrastructure in Scotland are summarised in the rest of this chapter.

Supply of material for reprocessing

Recycling is part of everyday life in Scotland, in large part due to the range of policies that have already been put in place to drive the separation and collection of recyclable materials within Scotland’s waste stream, and the success of the waste and resources industry in supporting their customers to recycle.

Scotland’s household recycling rate is currently 43.5%^[29], and more than doubled between 2004 and 2011. However, local authority household recycling rates vary significantly, from 20.7% to 58.2% in 2023. SEPA estimates that commercial and industrial recycling rates are around 53%, while commercial and industrial waste has steadily reduced with a 29% decrease between 2011 and 2023^[30].

Improvements in Scotland’s household recycling rate have stalled in recent years, with large quantities of recyclable materials still in the residual waste stream and sent for disposal, meaning that the value of that material is lost. For Scottish households, just over half of what we throw away at the kerbside could theoretically be recycled through existing systems^[31].

Conversely, just under a fifth of material put out for recycling by householders is non-recyclable^[32]. This contamination reduces the quality of material available for reprocessing, increasing cost and reducing the value of the final project. In some cases whole loads of material cannot be recycled and must instead be incinerated or landfilled due to contamination.

The Scottish Government has a wide range of existing and planned policies to drive the collection of materials for recycling and reprocessing. However, any policies that seek to increase the amount of material available for reprocessing should ensure that they divert material from becoming waste, and not from outcomes higher up the waste hierarchy, for example by recycling material that could otherwise be repaired or reused.

Local authority recycling

The Environmental Protection Act 1990 was amended by Scotland's 2012 Waste (Scotland) Regulations ^[33] to place requirements on Local Authorities to provide a comprehensive recycling service to their householders. In partnership with the Convention of Scottish Local Authorities (COSLA), the Scottish Government developed the voluntary Scottish Charter for Household Recycling and associated Code of Practice^[34] which sets out a minimum level of service and seeks to deliver more consistent recycling collections across Scotland.

The Circular Economy Act provides for a transition from a voluntary to a statutory approach to Scotland's Household Recycling Code of Practice. We are currently working with local government and wider waste sector stakeholders to co-design a new Code of Practice to create modern, efficient, and affordable waste and recycling service standards. Putting the Code on a statutory footing will provide a clear strategic direction for household recycling, accelerating improvements to both the quality and quantity of recycling, providing more consistency in service across Scotland.

In co-designing the new Code of Practice, we will review existing service structure, function and performance and consider new service demands and material flow changes. This includes consultation on the current rural exemption and separation requirements for textiles in line with EU standards, reviewing current practices with respect to separate collection of food waste and biowaste (such as garden waste), and requiring kerbside collection of plastic film and flexible packaging from 31 March 2027. The co-design process will also consider householders’ duty of care and current waste and recycling service charging. The process is already underway and aims to conclude with a new statutory Code of Practice available for consultation by the end of 2026.

The Circular Economy Act also requires Scottish Ministers to set statutory local recycling targets (e.g. recycling, preparation for reuse and composting) for local authorities to help drive further improvements in recycling performance for household waste services from 2030. The Scottish Government and COSLA have agreed to develop an action-focussed Improvement Programme to support setting and meeting targets.

The above measures will be supported by a review of funding mechanisms available to local authorities for waste and recycling services. This builds on more than £1 billion of funding made available through the Strategic Waste Fund between 2008 and 2022 to assist local authorities in the implementation of the Zero Waste Plan, and the £70m Recycling Improvement Fund^[35] introduced by the Scottish Government in 2021 to enable local authorities to improve recycling services across Scotland. Investments have supported the segregation and capture of increased quantities and quality of material for recycling, and investment in reprocessing infrastructure including the reuse and recycling of mattresses and the collection and recycling of plastic film.

Finally, policy measures elsewhere in the UK could increase the supply of some materials for reprocessing in Scotland, dependent on available domestic capacity and any relative advantage compared to processing those materials elsewhere in the UK. For example, “Simpler Recycling” in England^[36] is expected to increase collections of existing materials such as food waste, as well as mandating new services such as flexible plastics collections. If there is insufficient capacity to process these materials in England, then this could result in an increased supply to existing facilities in Scotland, or support the business case for new investment, particularly in specialist treatment facilities.

Commercial recycling

Scotland's 2012 Waste (Scotland) Regulations^[37] place requirements on commercial premises to separate certain materials for collection and recycling. Those measures have helped to drive a significant increase in commercial recycling. Working alongside SEPA and other delivery partners, we are working to undertake a targeted review of compliance with current commercial recycling requirements in Scotland to consider whether current requirements and their enforcement are achieving the intended aims, reporting in 2026.

Working with Zero Waste Scotland, SEPA, and the commercial waste and resources sector we will seek to conduct a national compositional study of residual waste from commercial premises to identify priority materials, products and sectors for waste prevention and recycling interventions. This will help us account for current and future waste composition, including the impact of policies such as Extended Producer Responsibility and the Deposit Return Scheme.

The review and compositional analysis will feed into a co-design process to develop further interventions to maximise commercial waste prevention, reuse, and recycling. Potential measures may include targeted communications and engagement, further fiscal measures to incentivise recycling or waste prevention, procurement advice and guidance. The co-design may also identify a need for further legislation or updated statutory guidance.

Producer responsibility

Certain products, including packaging, waste electronics and electrical equipment (WEEE), batteries and accumulators, and end of life vehicles (ELVs), are covered by extended producer responsibility (EPR) schemes. EPR requires that producers of those products are responsible for contributing towards their management at end of life and achieving certain recycling targets, in line with the polluter pays principle.

The Scottish Government, in partnership with the other nations of the UK, introduced extended producer responsibility (EPR) for packaging in 2025. Packaging EPR transfers the full net cost of providing an efficient and effective household packaging waste service from taxpayers and councils to packaging producers. Packaging EPR will provide approximately £150m of funding to Scottish local authorities in 2025/26, which will fund collection systems for household packaging waste and underpin sustainable service provision.

Packaging EPR also incentivises businesses to reduce excess packaging, design and use packaging that is easily recyclable, and encourage use of reusable packaging. Packaging EPR aims to ensure that at least 76% of packaging is recycled by 2030, with individual targets mandated in Regulations for each material type^[38]. Packaging EPR fees for producers must be modulated depending on environmental sustainability. PackUK, the scheme administrator, has confirmed that modulation will be on the basis of recyclability in the first three years of the scheme. In future years packaging EPR will also require recyclability labelling of products to improve consumer information on what can be recycled and how to do so.

Producers are required to evidence recycling through the purchase of Packaging Recovery Notes (PRNs) or Packaging Waste Export Recovery Notes (PERNs). The PRN/PERN system was originally introduced under the 1997 Producer Responsibility Obligations (Packaging Waste) Regulations as a way for producers to demonstrate that they have met their statutory recycling obligations each year and continues to apply under packaging EPR. PRNs and PERNs are issued by accredited recycling processors or exporters for each tonne of eligible packaging waste recycled. The Scottish Government plans to conduct a consultation on reform to the PRN/PERN system in partnership with the other governments of the UK, to consider measures to strengthen obligations and support domestic reprocessing.

Single use drinks containers between 150ml and 3l, made from PET plastic or metal are exempt from packaging EPR, and instead will be part of Scotland’s Deposit Return Scheme^[39] (DRS). DRS requires an increase recycling rates for single use drinks containers from the current rate of approximately 65%² to at least 90%. The separate collection of drinks containers will also lead to a substantial increase in the quality of material collected and available for reprocessing. Scottish DRS Regulations were laid in 2020^[40]and establish the framework for an industry-led DRS in Scotland. The Scottish Parliament has designated UK Deposit Management Organisation Ltd. as scheme administrator to operate the scheme. We are working closely with the UK Government and the Department of Agriculture, Environment and Rural Affairs in Northern Ireland to ensure the successful rollout of interoperable schemes across Scotland, England, and Northern Ireland in October 2027. We will also continue to work closely with the Welsh Government as they develop their plans for a separate DRS^[41].

The Scottish Government, alongside the other nations of the UK, has committed to reforming existing EPR Regulations for waste electronics, batteries, and end of life vehicles. In 2023 the four nations published a consultation and call for evidence on reforms to the Waste Electrical and Electronic Equipment (WEEE) Regulations 2013, which are intended to drive up levels of separately collected WEEE for re-use and recycling. The consultation set out proposals to expand collection infrastructure for household WEEE, reform take-back obligations for retailers, and expand obligations on online marketplaces and producers of vapes. WEEE EPR Regulations have since been amended to create new obligations on online marketplaces and producers of vapes, and the four nations continue to consider all proposals set out in the consultation, including ensuring that they keep pace with the growth in new technologies and renewable energy installations such as solar panels as we transition to a clean energy economy. The four nations are also considering policy measures to reform existing batteries and end of life vehicle regulations, taking into account the impact of the EU batteries Regulation (EU) 2023/1542 of the European Parliament and of the Council of 12 July 2023, and the shift towards electrification of the economy.

Diversion from landfill and incineration

In 2011 42.8% of Scotland’s waste was sent to landfill; by 2023 this had reduced to 19%, with a further 20.2% sent for incineration. This major shift away from landfill has been driven by a long-running policy focus to divert material from disposal. As we accelerate our move to a circular economy, we will produce less waste and increase the volume of materials recovered for recycling and reprocessing. There may always be a requirement to manage some materials as waste, and so we are also developing a Residual Waste Plan to 2045 to help minimise the environmental impact of waste and ensure that we have appropriate management capacity in place for those materials that cannot be avoided, reused, or recycled.

Any material disposed as waste at a landfill site in Scotland must pay Scottish Landfill Tax^[42]. The value of the tax has continued to increase since its introduction in 1996, and has been a key factor in reducing the amount of waste sent to landfill and encouraging recovery of material. From 31 December 2025 we will introduce a ban on biodegradable municipal waste going to landfill to further divert material from landfill to recycling or other disposal, and in particular to reduce greenhouse gas emissions from landfilling biodegradable waste.

Following the 2022 independent review of incineration, the Scottish Government set out in National Planning Framework 4 that it will not support new developments of energy from waste facilities, except under limited circumstances. We are undertaking work to support development of an indicative capacity cap to ensure that we have an appropriate amount of capacity as the amount of residual waste continues to decline.

We are working with other nations in the UK on the expansion of the UK Emissions Trading Scheme (ETS) to include incineration and energy from waste^[43]. Establishing a carbon price to burn fossil-based material aims to drive decarbonisation of energy from waste (EfW), and further incentivise alternative uses of this material. This will be supported by the development of a sector-led plan that will focusing on measures to end unnecessary incineration of high carbon-emitting materials.

Demand for reprocessed material

Demand for reprocessed material is largely assumed to be driven by market dynamics, rather than explicit policy requirements. Businesses may favour reprocessed material due to lower cost, greater availability, where consumer preference supports the use of recycled content, or to support their own sustainability targets. However, certain sectors may also avoid reprocessed materials where there are concerns over quality assurance or potential trade-offs against other properties such as durability.

There are currently relatively few policies in Scotland that aim to directly drive demand for reprocessed material, though the Scottish Government is currently investigating approaches to encourage recycled content through public sector procurement. Many demand-side policies such as product standards are reserved to the UK Government and therefore require a UK-wide approach. In some cases there may be a case for market intervention, for example to provide a level playing field for reprocessed material compared to virgin imports, or to support early-stage technologies. There is a growing interest in this area, both to increase supply chain resilience through reduced reliance on import of virgin materials, and to accelerate the transition to a net-zero, circular economy.

In 2022 the UK Government implemented a Plastic Packaging Tax (PPT) across the UK that applies to manufactured or imported plastic packaging components which contain less than 30% recycled plastic. In 2025 the rate of the tax was £223.69 per tonne. The tax intends to create an economic incentive for businesses to use recycled material in the production of plastic packaging, and to drive greater demand for recycled plastic. In 2024 the UK Government confirmed that businesses may use a mass balance approach to evidence recycled content in chemically recycled plastic for PPT, and the Scottish Government is engaging with the UK Government on a wider review of the effectiveness of the tax.

The European Union is considering or has adopted various measures to drive demand for reprocessed material, including for critical raw materials^[44], packaging materials^[45] and batteries^[46]. This could impact reprocessing markets in Scotland if reprocessing facilities in Europe seek to retain or import materials for reprocessing to improve economies of scale. The Scottish Government seeks to align with the EU where it is meaningful to do so and in a manner that seeks to contribute towards maintaining and advancing environmental standards, and we will continue to engage with the UK Government and other nations of the UK on the implications of EU policy for Scotland.

Any policies that seek to increase demand for reprocessed material should consider alternative input sources and the cost or availability of technologies to provide that material. The use of reprocessed material may impact upon product quality, durability and recyclability. There is also a risk that expanding demand for reprocessed material could create dependencies within the supply chain that undermine efforts to reduce the total amount of material becoming waste or manage material higher in the waste hierarchy.

Reprocessing infrastructure investment

Scotland’s domestic waste reprocessing infrastructure is primarily driven by private investment, which depends on a competitive market and a stable and supportive policy landscape. The public sector, notably local authorities and the Scottish Government have also provided some direct investment, for example through the Recycling Improvement Fund (see above). In addition, Scotland’s Enterprise Agencies offer support to businesses in all parts of Scotland, as well as international investors, to take advantage of new market opportunities. This includes working with businesses to secure investment, access supply chains or networks, identify the right skills or workforce, and locate at appropriate sites.

Any policies that seek to expand domestic reprocessing must consider alternative waste management routes. Domestic reprocessing of waste is not always the most economically viable or environmentally sustainable option. There may be alternative treatment or reprocessing options elsewhere in the UK, where economies of scale cannot be achieved in Scotland. Technologies may be immature or have high energy costs. Use of reprocessed material may not be economically viable for some materials based on quality and contamination. There is also a risk that expanding reprocessing capacity could create dependencies that undermine efforts to reduce the total amount of material becoming waste or manage material higher up in the waste hierarchy.

Circular Economy Investment Fund

The Circular Economy Investment Fund (CEIF), jointly funded by the Scottish Government and the European Regional Development Fund (ERDF), was open for applications from 2016 until 2022. In total, four businesses classed as recycling services were funded by the CEIF to the value of £1,075,214, attracting private investment of £1,537,927 and adding an annual reprocessing capacity of 15,794 across three different material streams. Two projects focused on plastic reprocessing, one on large WEEE and one on mattresses deconstruction for material recovery.

Investment in Grangemouth refinery site

In 2024 the UK Government and Scottish Government funded the ‘Project Willow’ feasibility study into the long-term industrial future for the Petroineos Grangemouth refinery site. The project identified nine initial viable “project sets” within the categories of wastes, bio-feedstock, and support for offshore wind which are suited to deployment at Grangemouth. Of these nine, six relate directly to materials reprocessing:

• Hydrothermal upgrading – breaking down hard-to-recycle plastics to produce pyrolysis oil
• Chemical plastics recycling – using chemicals to break down plastics and return them to a virgin state
• Acetone–butanol–ethanol (ABE) biorefining – bacterial fermentation of carbohydrate-rich waste material
• Second generation bioethanol – breaking down and fermenting Scottish timber into bioethanol
• Anaerobic digestion – fermentation of organic waste and biogas upgrading to produce biomethane
• Hydrogenated esters and fatty acids (HEFA) – converting Scottish cover crops into sustainable aviation fuel (SAF) and renewable diesel (RD) using low-carbon hydrogen

Proposals associated with these project sets will require significant public and private sector investment to be brought forward. As such, the Scottish Government has made £25 million available through the Grangemouth Just Transition Fund to support immediate opportunities arising from Project Willow and the UK Government has also made £200 million from the National Wealth Fund available to support investible propositions.

Scottish Enterprise is triaging enquiries that have been submitted following the conclusion of Project Willow, with the agency reporting to the Grangemouth Investor Taskforce on a monthly basis. Scottish Enterprise are focussed on identifying and progressing the most commercially and technologically viable proposals that are the best fit for the site and which require public sector support to bring them to fruition. Given the existing expertise and infrastructure at the site, actions to attract reprocessing investment to Grangemouth, in tandem with the broader policies outlined above to drive domestic reprocessing, have the potential to position the area as a global leader in materials reprocessing, green energy and sustainable manufacturing.

Onshore wind sector deal and Green Industrial Strategy

The Scottish Government’s 2023 Onshore Wind Sector Deal^[47] sets out the opportunities associated with maximising the reuse of materials and minimising waste in the wind sector supply chain presents, particularly as more sites become ready for decommissioning. Our Green Industrial Strategy further sets out our ambition for Scotland to be a world leader in the reuse, refurbishment, remanufacturing and recycling of wind turbine components and wider assets, which in turn will create jobs and export opportunities^[48].

The Sector Deal committed the onshore wind industry to delivering at least one specialist blade treatment facility in Scotland by 2030. As part of this commitment, Zero Waste Scotland and Scottish Enterprise have provided support to Reblade, based in Dumfries, the UK’s first dedicated wind turbine decommissioning service. This includes a £60,000 grant for operational costs and product development as part of the Circular Economy Development Grant. The company has developed innovative processes and blade-handling protocols aimed at maximising circular outcomes for decommissioned blades. Efforts focus on repurposing blades into practical structures such as bus shelters and bike sheds.

National Planning Framework 4

The Scottish Government’s National Planning Framework (NPF4) sets out our Sustainable Places National Spatial Strategy: that Scotland’s future places will be net zero, nature-positive places that are designed to reduce emissions and adapt to the impacts of climate change, whilst protecting, recovering and restoring our environment. NPF4 identifies Circular Economy Materials Management Facilities as one of eighteen ‘National Developments’, in order to maximise Scotland’s potential to retain the energy and emissions values within materials already in the economy. These are significant developments of national importance that will help to deliver our spatial strategy, and are therefore a focus for delivery. Circular Economy Materials Management Facilities cover facilities for managing secondary materials and recycling facilities, with a particular focus on construction and demolition industries and the decommissioning industry.

NPF4 also establishes Zero Waste as a Policy Principle, to encourage, promote and facilitate development that is consistent with the waste hierarchy. It requires that Local Development Plans should identify appropriate locations for new waste management infrastructure to support the circular economy and meet identified needs in a way that moves waste as high up the waste hierarchy as possible, as well as the consideration that must be given to local communities and the natural and historic environment.