APRS has responded to the consultation on the Circular Economy (Scotland) Bill. In summary our view is that the bill, as it stands, needs considerable improvement if it is to drive Scotland’s transition towards a circular economy. Waste should be seen as a systemic issue, and we need greater provisions for producer responsibility rather than the blame lying solely on individuals.
The key points we would like to see improved are:
- strong definitions of ‘circular economy’ and ‘circularity’ on the face of the Bill
- provisions for a strong refill system for glass bottles to complement a deposit return system
- measures to enhance the circularity and sustainability of the housing and planning system, such as greater provisions for repair and refurbishment of buildings
- Measures should make it easy for the public to ‘do the right thing’, whereas at the moment it takes great effort and often expense to reduce, reuse and recycle.
- greater requirements for takeback of items which can be managed further up the waste hierarchy, encouraging producers to take greater responsibility for what they produce.
- Emissions targets should be consumption-based, measuring the environmental impact of goods and services we consume in Scotland rather than purely the emissions generated within Scotland’s borders
The Scottish Government’s Circular Economy Bill was laid in Parliament in June 2023. It is the first bill of its type in Scotland and is an exciting and critical step in curbing overconsumption, tackling our throwaway culture, and transforming our economic system towards one that works for both people and planet. Currently, however, APRS believes that the bill does little to actually ensure a transition towards a circular economy and is in need of radical change. Here we discuss our thoughts on the bill, as well as some improvements we would like to see. You can also see our response to the consultation here.
A circular economy is one in which materials are used, reused, and valued, where our material consumption is reduced and waste is all but eliminated. It is one where businesses and producers take responsibility for what they produce rather than contributing to a linear, throwaway culture. It is also necessary if we are to reduce both our material and carbon footprints to ensure a healthy and sustainable environment, both in Scotland and globally.
Currently, just 1.3% of the materials and resources Scotland uses are cycled back into the economy after use, and we consume close to three times what is considered a sustainable level, according to Scotland’s Circularity Gap Report. Our economy typically favours single-use, which are designed to be used for minutes, or even seconds, before being thrown away. In measuring our emissions, only our domestic material footprint is accounted for, meaning that the materials and carbon emissions generated through everything we import are not included in our emissions reporting.
It is clear that Scotland has a long way to go in moving towards a circular economy where waste is minimised and ultimately prevented. However, APRS believes that the Circular Economy Bill as it stands needs considerable strengthening to work towards achieving this economy. APRS responded to the recent call for evidence by the Net Zero, Energy, and Transport Committee of the Scottish Parliament with some proposals which we believe would work towards strengthening the bill.
The bill as it stands does not have an explicit definition of what is meant by ‘circular economy’ or ‘circularity’, which could lead to these terms being used as buzz words with little meaning. As part of our response, we proposed a clear definition of these terms, which views a circular economy as one in which waste is reduced and ultimately prevented at both a production and consumption level, where reuse is promoted, and where the design of products allows for reuse and recovery of materials. We also believe that this should prevent ‘downcycling’, which means that the recycled product is of lower quality of functionality than the original product.
APRS led the campaign for a deposit return scheme for Scotland since 2014. Last June, the Scottish Government announced that they would delay this circular economy measure for a further two years to align with the rest of the UK. However, we believe that there is scope to decrease drinks-related litter and waste and move towards a more circular form of beverage packaging. In the bill we would like to see measures that would allow for a strong refill system for drinks containers, especially glass bottles, alongside our deposit return system. As glass is the most carbon-intensive material used in drinks containers, and the most dangerous when littered, a reuse system could have a significant impact on making glass packaging more environmentally friendly.
A circular housing and planning system is also critical in reducing Scotland’s material and carbon footprint. According to the Circularity Gap Report for Scotland, a more circular built environment can reduce our material and carbon footprints by over 11%. We believe that priority should be given to the refurbishment and repair of existing buildings, that planning authorities should be required to ensure circular practices are in place where possible, and that construction materials should be recovered and regenerated at the end of use.
The bill also proposes charges for single-use items, such as disposable coffee cups and takeaway food containers, which APRS supports. However, we also believe that where the onus is on the public to reduce their use of single-use items, it should be made as easy as possible to ‘do the right thing’ through clear communication, availability of alternatives, and deposit-refund systems. This is to ensure that these measures actually reduce waste rather than becoming a financial burden. It is also crucial that money raised should be reinvested in environmental or recycling services rather than businesses profiting from these charges.
We also believe that the Scottish Government should lead by example and set circularity targets for their own operations, showing that it is possible for businesses to change their practices. We also believe that, in order for businesses and companies to receive public funding, they should set out clearly how they will operate in a sustainable and circular manner.
Similar to other environmental campaigners, we also believe that consumption-based targets should be included in the bill. More than half of Scotland’s carbon emissions footprint comes from products and materials that we import, though these are not recorded in our greenhouse gas inventory. Current legislation only requires that we record our domestic emissions, which actively promotes the offshoring of manufacturing and does not give an accurate account of our environmental and climate impacts. We believe that targets should allocate emissions to the consumption of goods and services, rather than purely the emissions generated within Scotland’s borders. This ensures that Scotland accounts for its global climate and environmental impacts.
Core to our views on this bill is a greater need for producer responsibility in reducing waste and moving towards a circular economy. As we highlighted through our deposit return campaign, those who produce single-use packaging should have a responsibility to ensure that it is reused, reduced, redesigned, and recycled. In our response, we propose that requirements can be placed on producers to accept returns of certain materials that are widely used and fast-moving, and with high carbon impacts, which can be managed further up the waste hierarchy as part of producer responsibility. As such, our submission response treats waste and litter as a systemic issue, rather than the blame lying solely with individuals.
If we are to rapidly move towards a circular economy, we need more provisions for polluter pays principles, where the onus for waste and litter lies with those who produce single-use, poorly designed materials are responsible for the costs of managing it. While it has a long way to go in reaching the ambition and strength needed for a transition towards a true circular economy, APRS and other environmental organisations are working to improve this bill so that it works for both people and planet.
Sarah Doherty – September 5 2023
Read our full response
Circular Economy (Scotland) Bill consultation response
This is the APRS response to the Scottish Government’s consultation on the proposed Circular Economy Bill, September 2023.