Consultation Response: Changes to waste management services (Scottish Government)
The Scottish Government has consulted to gather evidence in the development of a new Code of Practice for local authorities which will set out the new requirements for waste management and recycling services across Scotland in line with the Circular Economy Route Map. Visit the Scottish Government website for further information about the consultation and possible proposals for food and textile waste management.
Our full submitted response is included below but in summary:
East Lothian’s household recycling rate was 53.1% in 2022, making it the highest among the four Lothian councils and placing it in the top 10 of all Scottish local authorities [Awesome people, well done!]. This rate is significantly above the Scottish national average of 43.3% for the same year. Recent figures indicate that East Lothian continues to improve, with rates among the highest in Scotland.
However, about half of the waste collected from East Lothian’s general (residual/green) bins could still be recycled. Of this recyclable fraction, approximately 30% is food waste that should have been placed in food recycling collections [not so awesome]. This means a significant portion of what is currently sent for incineration or landfill could be diverted to recycling streams if sorted correctly
Across Scotland, textiles make up about 4% of household waste by weight but account for a much larger share of the carbon impact (32%). Zero Waste Scotland estimates that roughly 0.8% of the total residual waste tonnage is textiles, but because most textiles are not separately collected, up to 89% of textile waste is disposed of via household residual waste and therefore sent for incineration and energy recovery.
Whilst energy recovery is a step up from landfill in the waste & circular economy hierarchy, and recycling is a step up from energy recovery, reduction, reuse, and repair rank much higher up. These elements are little mentioned in the consultation document.
We have concerns that kerbside collection of useable textiles will encourage recycling as a disposal method in preference to reduction, reuse and repair but this very much depends on the design of the scheme and the journey of those textiles after collection. Co-design of local options for sorting and diverting materials to more circular uses is essential.
We would love to hear your views:
How do you currently dispose of unwanted textiles?
Would kerbisde collection improve this?
Let us know in the comments below
Lil response Submitted to Changes to waste management services
Household Collection of Textiles
Do you consider your current options for textile recycling to be efficient? No 2 Do you consider your current options for textile recycling to be accessible? Yes 3 If you do not consider your current options for textile recycling to be efficient and/or accessible, what improvements would you recommend? Please provide your answer here.: Clarity in language here would be useful. Recycling is specifically the collection of materials, for breakdown and reproduction of the same or very similar material. It’s unclear if you are including collection for reuse/ repair/ remanufacture in your definition. Efficiency challenges include:- Collection timing & management leading to inefficiencies in transport – digital bins can eliminate this but investment would be needed.- Late emptying of bins leads to textiles left out in the elements leading to contamination and reduced value – again digital bins could support more timely bin collection.- A lack of infrastructure to process complex mixed fibre materials Textile collection options are fragmented and not always obvious or easy for citizens to navigate. Many people are unaware of textiles recycling, unsure which textiles can be recycled and may inadvertently contaminate collections by including unsuitable items, leading to inefficiencies and frustration. Not all communities have easy access to textile recycling points. There is often little clarity for householders about what happens to their donated textiles after collection. Investigations have shown that clothes donated for recycling or reuse may be exported, destroyed, or not recycled as promised, undermining trust in the system. We recommend a more cohesive, accessible system that includes all types of textiles (not just clothing), with clear information and easy access for all residents, including those in rural areas. Community hubs and partnership with third sector organisations could improve both efficiency and accessibility through awareness raising, trusted messengers and community wealth building. 4 Do you believe household collection of textiles would provide benefits to householders? Yes 5 What potential benefits do you consider household collection of textiles would provide to householders? Please provide your answer here.: While reuse projects, charity shops and textile banks exist, they are not always convenient, and options for non-clothing textiles are limited. Kerbside collection would omit the need for effort, remembering and additional journeys to take items to specific locations, all of which are barriers to donation of textiles.
Do you believe household collection of textiles should be a service supplied by local authorities? Extra note: A mandatory service would be a statutory requirement for all local authorities in Scotland to collect textiles separately as part of their waste collection services at household kerbsides. This may require a separate household recycling bin. Disagree Please provide your answer here.: While kerbside collection would increase convenience and participation, it also enables greater consumption. When household disposal is easy (and believed to be a ‘greener’ choice) the brakes are released on consumption. Kerbside collection would need to be part of a wider campaign that supports reduced purchasing, encourages textile and care & repair to increase the lifetime of materials. It would be essential for local authorities work in partnership with third sector organisations to ensure that high-quality textiles are diverted to reuse and repair before recycling. The service must be designed to move materials as far up the waste hierarchy as possible, prioritising reduction, reuse, and repair over recycling. There needs to be transparency in the lifecycle of the materials for householders.
If collections of textiles from households are not a service supplied by local authorities, do you think there should be a requirement for all local authorities to offer textile recycling through Household Waste Recycling Centres or other bring facilities? Yes Please provide your answer here.: A requirement for accessible bring facilities would ensure that all residents have an option for textile recycling, even if kerbside collection is not feasible. This should be complemented by education and support for reuse and repair initiatives at the point of donation.
What is the estimated number of textile items you recycle/dispose of each year? 1-5
What services are currently available in your local authority area to recycle or dispose of textiles? Local Textile Bank in supermarket / car park, Charity Shops – In Store, Charity Shops – Household Collection, Household Waste Recycling Centre
What services do you currently use in your local authority area to recycle or dispose of textiles? Other If other, please provide your answer here.: I have very little textiles recycling. Anything irreparable goes to the textile bank at our village hall which raises funds for the community association. Any good quality useable clothing The Lil Revolving Wardrobe for reuse. Worn out bedding and towels that we can’t reuse at home goes to a local animal rescue centre. We offer a Revolving Wardrobe (clothing & accessories library) which is free to use for everyone in our communities. Through this and Reuse Festivals and events we are circulating clothing amongst community members and supporting low income households whilst also raising the awareness of our community about the ways they can make good consumer choices, better care for their clothes and repair to extend the life of things they love.
Do you foresee any barriers or unintended consequences to local authority collection of textiles at the kerbside becoming a statutory service? Yes Please provide your answer here.: There is a risk that kerbside collection could divert high-quality textiles away from reuse and repair organisations, undermining their ability to operate and support community needs. It could also lead to increased costs for local authorities and reduce the incentive for householders to reduce textile consumption. The question of EPR for textiles should be further considered – if the public purse pays to treat the symptom without addressing the cause the flow of ‘waste’ materials may in fact increase. We need to find ways to turn off the tap. Careful co-design with the third sector is essential to avoid these unintended consequences
If your local authority offered household collection of textiles, how likely are you to utilise this service? Somewhat unlikely
Do you have any additional views, regarding household collection of textiles or what you would expect a useful service to look like? Please provide your answer here.: We strongly support efforts to reduce the environmental impact of textile waste, but we urge the Scottish Government to take every opportunity to move materials and resources—and therefore behaviours—up the waste or circular economy hierarchy. While reducing waste to landfill is positive, much of this reduction has been due to increased incineration, which is only one step up the hierarchy. Recycling is a further step, but it should not be the end goal. We know that recycling rates in East Lothian are higher than the Scottish average, but around 30% of the material in residual waste could still be recycled, including textiles. However, there is little mention in current policy of reducing the flow of materials through households that become waste in the first place. The most significant environmental and social benefits come from preventing waste, reusing, and repairing materials, rather than recycling or incinerating them.
A truly effective textile collection service would:
• Prioritise reduction, reuse, and repair over recycling and incineration.
• Work in partnership with third sector and community organisations to ensure high-quality textiles are diverted to reuse and repair.
• Provide clear education and incentives for householders to reduce textile consumption and care for what they have.
• Engage textile producers and retailers to increase the sustainability of fabrics and increase trustworthy takeback programmes
• Ensure transparency and traceability of collected textiles, so that materials are reused where possible and not exported unless to reputable, regulated markets.
• Support local circular economy initiatives that create jobs, reduce costs, and build community resilience. We urge the Scottish Government to use this opportunity to co-design a service that moves beyond recycling and incineration, and truly supports a circular economy for textiles
Rural Food Waste Exemption
Are you located in an area with a rural food waste exemption? Yes
What is your preferred approach to the rural food waste exemption in the future? Other If other, lease provide your answer here.: We think the exemption should be on a case-by-case basis and local authorities should make the case for exemption. Our postcode is exempt, but we still receive a food waste collection service, however in many rural areas householders have sufficient space to manage their own food waste – reduction and composting (closed bin hot box composters) should also be promoted.
If you live or operate a business in an area in which the rural food waste exemption is used, what do you currently do with your food waste? Other If other, please provide your answer here.: Whilst we do have a collection service, the majority of our food waste is either fed to hens, composted or hot box composted (non veg food waste). We minimise waste by planning meals, only buying what we need and having a leftovers meal at least once a week.
Business and Regulation: Do you think that the proposals contained in this consultation are likely to increase or reduce the costs and burdens placed on any business or sector? Please provide your answer here.: We have concerns about the impact on business models that are built on the donation of textiles for reuse, repair or remanufacturing.
Children's Rights and Wellbeing Impact Assessment: Do you think that the proposals contained in this consultation are likely to have an impact on children’s rights and wellbeing? Please provide your answer here.: Many textile reuse initiatives support families on low incomes and are services upon which they rely. One of our service users said: “As a single mum, I’m always looking for ways to stretch the budget and still make sure my son has everything he needs – but that can be tough, especially with the cost of living being what it is. The Lil ReUse Project has genuinely been a lifeline for us. It’s helped take the pressure off in so many ways, and I honestly don’t know what I’d have done without it. Thanks to the project, I’ve been able to get clothes, toys, books, and household bits we’ve needed – all at incredibly affordable prices, and sometimes even for free. That’s made such a huge difference to our finances. I’ve even been able to sort birthday and Christmas presents for my son without the usual worry and guilt about how I was going to afford it. Being able to give him things I know he’ll love, without breaking the bank, has taken a weight off my shoulders.” Ensuring these types of services can still provide this support should be an integral element of the design of any new system.
Fairer Scotland Duty: Do you think that the proposals contained in this consultation are likely to have an impact in relation to the fairer Scotland duty? Please provide your answer here.: Yes, if services are designed to be accessible and inclusive, and support community-led initiatives.
Environment: Do you think that the proposals contained in this consultation are likely to have an impact on the environment? Please provide your answer here.: Yes, if services are designed to prioritise reduction, reuse, and repair, and not just recycling and incineration.
Your information
Organisation: Lower Impact Living (Lil) CIC
Further information about your organisation's response Please add any additional context: Lil CIC runs Reuse Project, which includes: The Revolving Wardrobe - a clothing and accessories library for our community The Reuse Festival - an annual exchange of all household items including clothing and household textiles Targeted events to support specific audiences eg the Families Fair (focussed on on baby and young child clothing and household textiles Other events and campaigns to raise awareness and capacity to reduce consumption, increase quality and skills in care & repair. In running this project, we have seen the value of reuse to a number of audiences, particularly those on low incomes and young people who are keen to find more sustainable options. As one of our service users put it “The financial side is a big help, of course – when money’s tight, being able to pick up good quality things for next to nothing (or sometimes free!) is a huge relief. But there’s more to it than that. It feels good knowing we’re not just buying into fast fashion or chucking things away. We’re reusing, giving things another life, and making more thoughtful choices without having to preach about it. The kids just get it now – it’s part of how we live." This is behaviour we want to support everyone to adopt. It goes beyond the issue of waste to sharing resources, mutual support and community wealth building A user survey into the motivations of both service users and non-users saw that 'saving the planet' of climate change were not primary drivers of behaviour. It was more about ease, convenience, nabbing a bargain, having an enjoyable experience and being part of something. As stated in 'Evidencing the Need for a National Citizens Clothing Circularity Strategy', there is no one solution across clothing acquisition, use and disposal that will work for everyone. It is important, therefore, that a range of routes to action are offered in these areas to reflect the diversity of consumer citizens in Scotland. It is vital that routes to action enable consumers to act with confidence when acquiring, using and disposing of clothing and other textiles.