APRS Resources

Circular Economy Route Map – letter to the Minister

This is a letter to Lorna Slater MSP, Minister for Green Skills, Circular Economy and Biodiversity regarding the consultation on Scotland’s Circular Economy and Waste Route Map to 2030

Minister for Green Skills, Circular Economy and Biodiversity, The Scottish Parliament, Edinburgh, EH99 1SP


Dear Minister,

We note the recent publication of the consultation on Scotland’s Circular Economy and Waste Route Map to 2030, which is described as “intended to lay the foundations for the system-wide transformation we need to deliver through to 2030”. These comments are in addition to our previous communications on the Bill.

As you know, Action to Protect Rural Scotland has long been active in this policy area, through our work in support of deposit return, and more recently providing evidence to the Net Zero, Energy & Transport Committee’s Stage One consideration of your Circular Economy Bill. With this in mind we are also copying this letter to the Committee for their information.

Robust and urgent action to transition the Scottish economy away from the current almost entirely linear model would, we believe, help reduce climate emissions and demand for raw resources, cut the costs local authorities face when managing linear products and packaging, and provide significant economic opportunities.

We also agree with your commentary in the introduction to the consultation that in order “to cut our emissions significantly and make real progress, we must deliver a fundamental shift across society to reduce the demand for raw material in products, encourage reuse and repairs through responsible production and consumption”.

We also accept that there are important powers in this space which remain reserved, and clearly devolved powers where action might plausibly be restricted via the Internal Market Act 2020. We do, however, have concerns with the scope and detail of the Route Map, in addition to previously-raised concerns with the legislation as introduced.

Our understanding of your position is that the Route Map is intended to set out how existing powers and resources would be used, alongside how the new powers within the Circular Economy Bill would be used, and that together this would represent a comprehensive delivery plan.

However, many of the essential foundations of a circular economy feature neither in the Bill nor the Route Map, even though most are are either devolved through the Scotland Acts or are where UK legislation has granted the necessary regulatory powers directly to Scottish Ministers, most obviously through Section 50 of the 2021 Environment Act and Section 140 of the 1990 Environmental Protection Act.

To use an analogy, the Climate Change (Scotland) Act 2009, as subsequently amended, has to be read in parallel with the 2018-2032 Climate Change Plan. Together they set out a framework for Scotland’s work to reduce emissions, even though many issues like fossil fuel licensing remain reserved. Although NGOs might argue for more urgent action on that issue, the structure in policy and legislation is clear. This approach is what we hope to see across the circular policy agenda, both through a final route map and the Bill, once it concludes its passage through Parliament.

Organisations working on the circular economy agenda had hoped that an ambitious suite of actions would be set out in the Route Map, but many of the proposed priority actions are commitments to future rounds of plans. 

Our hope would be to see the first steps taken towards comprehensive producer responsibility for both products and packaging. This is the fundamental lever of the circular economy, and one of the most direct ways to drive reuse, repairability, improved product design and waste reduction – it is also devolved and does not require exemptions under the Internal Market Act. 

In 2016, Making Things Last committed Ministers to exploring “the concept of a single framework for producer responsibility, bringing together common elements into one flexible and transparent system, making it simpler for businesses who are involved in more than one product type and making it easier to add new products and materials to the producer responsibility regime in the future.” 

A single framework of this sort, covering all products by default, might be possible via the UK 2021 Environment Act – and if not, we would recommend taking further powers in this area via amendments to the Circular Economy Bill. Yet the Product Stewardship Plan promised in the Route Map by 2025/26, lists potentially as few as three product categories to be covered, probably mattresses, tyres and textiles. Take-back responsibilities feature only as one option to consider (p32). 

The associated documentation already published, including Zero Waste Scotland’s Carbon Emissions of Scotland’s Waste, do not, for example, include evidence which points to product stewardship only being appropriate for that short list of product categories. It would be useful to see the evidence that underpins this proposal. APRS would prefer the takeback approach to be adopted as a default across all product types unless a case for a delay or exemption can be made for a particular product type, or to get as close to this as possible.

The outcome of the second consultation on the Route Map  is, in general terms, no more ambitious than the first version and, in some cases, some promising commitments seem to have been removed. The 2022 version pledged “action to reduce consumption of single-use food containers”, and to “keep pace with the EU Sustainable Product Initiative.” Both have been dropped. Similarly, the 2022 document promised to “strengthen community food redistribution networks, including additional funding”, and to “facilitate the development of a soil symbiosis programme”. Neither of those survived the second consultation, although there remains reference to research on the former.

Finally, it is not clear from this document how Ministers intend to embed this agenda into the operations of other parts of the Scottish Government’s policy-making and operations, as is done to some extent with climate change. 

Overall, we remain concerned about the process and the ambition signified by both the Route Map and the Bill as it stands, which together would see Scotland’s essentially linear economy retained for the foreseeable future, despite the urgency of the climate crisis and the biodiversity crisis. 

As per the proposals circulated to Scottish Government in January, we would of course still be very pleased to work with the Scottish Government to help devise a wider set of measures here, policy proposals which work within the devolution settlement, and which could deliver a successful transition to a circular economy.

Yours sincerely,

 Kat Jones, Director

Action to Protect Rural Scotland

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