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Scotland gets ahead of the CE pack

The European Commission’s consultation on its revised circular economy (CE) package has now closed, and an analysis of responses is expected within the next few weeks.

Responses from the main waste and resources industry trade bodies were broadly aligned, with key themes including:

  • Legally binding framework, rather than one based on voluntary agreements influenced by the current deregulatory agenda.
  • Demand side measures, designed to increase demand for recyclates, including introduction of an overarching green public procurement framework and fiscal incentives, including tax breaks, for the use of recycled content in products.  
  • Organic waste, with a call for mandatory food waste collections, as well as a requirement to measure and report on food waste, and to develop a national reduction strategy with a suggested target of 30%.

Interestingly, WRAP indicated that it preferred voluntary industry agreements to legally binding measures. But others are sceptical about whether such measures are sufficient to institute the far-reaching changes in the economy and regulation that will be required to shift to a CE model.

In particular, concerns have been expressed over the preference in the marketplace for the use of virgin materials where these are less costly than recycled materials, unless there are measures to promote the use of recycled materials and products.

Product Design

Just as the Commission’s consultation closed, the Scottish Government announced its own CE consultation, intended to strengthen the circular ‘loops’ in the Scottish economy, including the following key areas:  

  • Design. The aim is for products to be designed for longer lifetimes, optimised for disassembly, repair and recycling, and more companies retaining valuable products and c o m p o n e n t s through leasing, servicing, repair and re-sale models. A Scottish centre of expertise on circular design is proposed.
  • Reuse. The aim is for a strong and mainstream market in secondhand goods, and for major industrial sectors to optimise the value of used equipment and infrastructure. Proposals include building on the existing standard for reuse and to clarify regulation, as well as to improve the capture of items for reuse, especially in key sectors such as oil and gas.
  • Repair. The aim is to grow the repair sector and make this the first choice for an increasing range of items. Proposals include establishing a comprehensive repair-finding service or network and to engage more companies in offering repair services for their products.
  • Remanufacture. Fulfil the sector’s potential for growth. Proposals include enhanced support to companies in re-lation to remanufacturing, as well as measures to allow for the recognition of remanufactured products, improving the return of end-of-life products and increasing the use of remanufactured products in public procurement.
  • Recycling. The aim is to make recycling routine in every business and household, and to increase the quality of recyclate to maximise economic benefits. Proposals include collaboration with waste and packaging industries, exploring a deposit return system for Scotland and minimising contamination in recycling centres, as well as mechanisms to support investment in reprocessing, including in the chemicals sector, construction, agricultural plastics, tyres, furniture and mattresses.

This is not the first time Scotland has been first mover in terms of exploring ambitious policy proposals, and shows that the Scottish Government believes there are benefits in shifting to a CE.

The consultation documents make clear that Scotland will implement proposals following the consultation without waiting for the Commission’s CE proposal to come into force, although it will take the EU package into account in finalising legislation and other measures.

The consultation runs until 30 October. Based on the current timetable, it is likely that the EU package will be published before any proposals are implemented in Scotland.      

Fiona Ross is an associate at Pinsent Masons

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