APRS Resources

Letter to the Minister on the Circular Economy Bill

APRS, along with other LINK members wrote to Lorna Slater the Minister for Green Skills, Circular Economy and Biodiversity on 17 October 2023 to encourage her to make the Circular Economy more ambitious

Dear Lorna Slater MSP, Minister for Green Skills, Circular Economy and Biodiversity

Circular Economy (Scotland) Bill 

We are pleased to see the long-awaited Circular Economy Bill.  We support the Bill and welcome that it aims to set up a framework to drive a systemic change to a more circular economy in Scotland, which we so urgently need in view of the climate and nature crises.  We support the inclusion of the provision to restrict the destruction of unsold consumer goods and the requirement to report on waste and surpluses, and would like to stress the importance of these being applied widely to maximise impact.

However, we are disappointed that the target setting element of the Bill is weak. We would like to see the Scottish Government showing real commitment to this by setting a carbon footprint target on the face of the bill; or, at a minimum, we would like to see an obligation to set consumption reduction targets within two years of the passing of the Bill. 

We also think it is important to improve the description of the circular economy for the purposes of the Bill and to include a purpose clause in the Bill.  Although we welcome the focus on reducing consumption of materials, the current definition does not say anything about preventing the leakage of harmful materials into the environment and does not align with the waste hierarchy that places more importance on prevent and reuse measures than recycling and recovery.

In order to provide the level of expert advice and scrutiny needed, we think that an independent body should be created and the Bill should bring in a requirement to establish such a body.

The Bill should be used to bring in secondary legislation (as it already does for other measures) to ban further single-use items for which there is clear evidence of environmental (or other) harm, such as single-use vapes and single-use wet wipes that contain plastic. These measures are popular with the public.  Likewise, an obligation on producers to take back products to encourage efficient reuse or recycling, accompanied by well-monitored targets on circularity and with lessons learned from the implementation of the WEEE Directive would be a welcome addition to the Bill with real potential to catalyse the system change we need.

The Bill must recognise soil as the cornerstone of a circular economy and, at a minimum, include a commitment to carbon and phosphorus budgeting and a requirement for the Agricultural Act to include provisions such that good soil management is a condition of public funding.

We look forward to discussing the Bill at our meeting later in the month.

With best wishes,

Phoebe Cochrane, Scottish Environment LINK

Kim Pratt, Friends of the Earth Scotland

Pete Ritchie, Nourish Scotland

Calum Duncan, Head of Conservation Scotland, Marine Conservation Society

Catherine Gunby, Fidra

Kat Jones, APRS

More detail on the above and further ideas for improvements to the Bill can be found in the evidence we submitted to the Committee: https://www.scotlink.org/publication/circular-economy-scotland-bill-link-evidence-to-nzet-committee/ 

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