IEMA responds to Scotland’s circular economy strategy

Since publishing Making Things Last: A Circular Economy Strategy for Scotland in 2016, Scotland has shown a commitment to a circular economy via measures tackling single-use carrier bags and proposals for a drinks container deposit return scheme.

IEMA submitted a response, which can be found at Overall, IEMA welcomed the proposals, but felt that the restricted focus on sustainable waste management would not enable a complete transformation to the circular economy.

Resource efficiency is key to making the most of resources while minimising waste. Following the introduction of the Environment Bill, the UK government made it clear that resource efficiency puts sustainability at the heart of the economic model (Part 3, sections 47 to 48). It provides power for the relevant national authority to make regulations about the provision of resource efficiency information and resource efficiency requirements (Schedules 7 and 8). These provisions could shift the focus from consumers to producers. The proposals for a Scottish Circular Economy Bill are silent on resource efficiency, so any secondary legislation should integrate these perspectives. 

Some other recommendations set out in our response are:

  • We would call on any future proposal for circular economy legislation to embed product standards that incentivise resource efficiency in product design.
  • Resource utilisation could be set against economic indicators, showcasing the business case for minimising resource use while promoting productivity.
  • To support a UK-aligned extended producer responsibility (EPR) scheme on packaging, it is important for the Scottish government to be inscribed into proposals for a Scottish Circular Economy Bill. Once inscribed into legislation, the EPR scheme and any fiscal measure such as a plastic tax should stimulate the circular economy.
  • A UK plastics tax could help incentivise recycled content in new goods. Funds raised should directly support infrastructure investments needed to promote recycling and reprocessing.
  • To avoid the risk of applying a double charge to the same items, the Scottish government should carry out further impact assessments. The proposal currently recommends the introduction of charging on items such as plastic straws. IEMA has advised the government to assess which charging option it should implement, as single-use disposable beverage cups could equally be caught by an EPR scheme, a deposit return scheme or a plastic tax.
  • The Scottish government should clarify the timeline for implementation of the bill and how it interacts with the timeline for implementation of the EU single-use plastics directive, Scottish deposit return scheme legislation and UK-aligned EPR schemes.

The IEMA Circular Economy network steering group will continue to engage with members as the Scottish government develops its proposed Circular Economy Bill. Updates on the next consultation will be released in due course. For further updates on IEMA’s circular economy activity, email [email protected]

Find IEMA’s consultation responses to the Resources and Waste Strategy at

Read about IEMA’s engagement on the UK Environment Bill at

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