Scotland consultation: the good, the bad and the interesting


Paul Sanderson’s report:

Last week saw the publication of Circular economy and waste route map to 2030: consultation by the Scottish Government.


It builds on the first consultation that was issued in 2022 and is now seeking views on this update. 

There are many positives in the consultation for the recycling industry in Scotland, but also some massive concerns. 

Let’s start with the bad.

Although exports of recycling are a UK Government matter, the Scottish Government is urging it to go beyond its stated aim of banning exports of plastics to non-OECD countries with a full ban on exports of recycled plastics. Concerningly, it also said it would like the UK Government to “consider further targeted restrictions around other materials, in line with the Climate Change Committee’s call to ‘phase out’ exports of waste by 2030”.

We’ll push back on this mad idea of course, both in the consultation and continue to demonstrate to the UK Government the value of exports of recycled materials. 

On the one hand, it is good that the Scottish Government has dropped its crazy idea in the previous consultation of mandatory business waste zones recognising the “significant concerns regarding impact, in particular on small and medium sized enterprises in Scotland around potential loss of competition and monopoly price escalation”. But on the other hand, it will still allow these zones to be voluntary and it isn’t clear how these voluntary zones will be created or operate. 

Again, we don’t like the competition implications of this, so will push back in it.

Now, let’s look at the good.

The consultation wants to see high quality recycling and we’ll always welcome that. Measures to ensure quality include consistent collections across Scotland and replacing volume targets for recycling with a circular economy target by 2030 that will also understand the environmental impact of recycling. It also proposes a co-design process for collections involving the recycling industry and other stakeholders to optimise both household and commercial collections (this will also inform these voluntary business waste zones mentioned above). 

Interestingly, Scotland also wants to put more emphasis on the householder to reduce contamination of recycling, with potential fixed penalty fines for those who persistently contaminate.

There will be a fit and proper person test for waste carriers, it will look to consider the wider environmental impact of vapes on top of the UK ban on single use vapes, and it is proposing a study to understand the composition of commercial waste.

I will of course be responding to this consultation on behalf of The Recycling Association and I welcome any thoughts you may have on it. The consultation is here if you wish to read it and respond. It closes on 15 March 2024.