Lil's response to the Scottish Government Draft Circular Economy Strategy Consultation
Whilst it’s not the most riveting read I thought we would share our thoughts on the proposals in the draft CE strategy. The consultation closes on 14th January 2025. Feel free to utilise anything on this response to make your own.
The short version? It’s a good start, but this strategy is a once-in-a-generation opportunity to transform Scotland's relationship with materials, nature, and communities. They seem to have forgotten the structure and purpose of the waste hierarchy! Without being bold and strengthening the strategy, it risks being a waste of an opportunity, and as you know, we hate those!
Read on for the long version. - a question by question copy of our response - and if you have any thoughts on it, please do comment below:
Vision and Outcomes
Q1: To what extent do you agree with the vision and outcomes for the strategy?
Agree
Q2: Do you have any comments on the vision?
Lil agrees with the overall ambition of a net zero, nature-positive Scotland by 2045, with circular economy principles fairly distributed across society. However, we have concerns that the strategy as drafted is insufficient to deliver these outcomes without stronger focus on the top of the waste hierarchy and robust accountability mechanisms.
The vision should explicitly embed the circular/waste hierarchy in order: prevention and reduction come first, followed by reuse, repair, remanufacturing, and recycling, with disposal (including incineration) only as a last resort.
The Circularity Gap Report for Scotland shows how urgently we must embed the circular hierarchy in practice, not just in principle. Scotland is currently only 1.3% circular, meaning more than 98% of the resources used are virgin materials, and just 1.3% are cycled back into the economy. Scotland’s per‑capita material footprint is 21.7 tonnes per person per year, nearly double the global average of 11.9 tonnes, and far above a sustainable level. This is fundamentally incompatible with Scotland’s climate and nature commitments and underlines why reduction in material use and waste has to sit explicitly at the top of the strategy’s outcomes.
The report’s scenarios show that applying circular strategies across key systems could reduce Scotland’s material and carbon footprints by around 43% and increase circularity almost nine‑fold, to about 11.8%. This is only achievable if policy, investment and monitoring are aligned with the waste hierarchy: designing out waste and reducing consumption first, then maximising reuse and repair before any recycling or residual treatment.
The vision should commit to reducing Scotland's material footprint to sustainable levels and to ensure that actions directly tackle resource overconsumption driving the nature crisis. The climate and nature crises are not separate challenges, they are interconnected, and circular economy action can, and should, address both simultaneously.
Q3: Do you have any comments on the outcomes?
The outcomes should:
Explicitly prioritise circular economy strategies in order of the hierarchy with reduction/reuse/repair over recycling and recovery.
Thread community wellbeing and community wealth building throughout. Social outcomes should highlight community wealth building more prominently, integrating just transition principles to support all groups in accessing circular green jobs and services, thereby improving wellbeing in rural and urban communities alike. A circular economy can lower household costs and enhance social cohesion such as through shared resource models and greater connection to local businesses and services.
Include nature-positive outcomes as a core measure of success, not just emissions reduction.
Address international supply chain impacts including human rights and environmental abuses, ensuring Scotland's circular transition does not export harm to the Global South.
Policy Mechanisms
Q4: To what extent do you agree with the policy mechanisms identified?
Agree
Q5: Do you have any comments on the policy mechanisms identified?
Lil agrees with the identified mechanisms but believes they require significant strengthening to drive meaningful change.
Behaviour change: Clear, accessible information is essential. Tools like Lil Loop demonstrate that digital platforms can empower communities to take action by answering personal, practical questions about reduction, reuse, and repair in a non-judgemental, positive way. The strategy should:
Mandate digital product passports aligned with EU standards to provide transparency on product lifecycles.
Invest in community-led behaviour change programmes that reach people where they are.
Recognise that behaviour change alone cannot solve systemic issues.
Lil strongly supports mechanisms like a well‑designed Deposit Return Scheme show how targeted policy can transform behaviour, cut litter by around a third and deliver 90% capture rates for specific materials. However, DRS primarily operates lower down the hierarchy. Scotland now needs an equivalent level of ambition for mechanisms that drive reduction, reuse and repair across a much wider range of products and sectors.
Other mechanisms that have worked elsewhere include piloting PAYT or hybrid PAYT models with strong safeguards for low‑income households, so that excess, avoidable waste is more expensive than reduction and reuse.
Business support: Business support and skills development are crucial, and we commend plans for Zero Waste Scotland's Business Information Hub. The support should prioritise business models built around reduction and reuse, not just recycling. Extended Producer Responsibility should be strengthened to hold businesses accountable for the full lifecycle of their products. A PAYT model with differentiated fees for businesses (i.e. higher fees for mixed/residual waste; lower fees for segregated reuse/repair activity) could be trialled to cut waste and increase recycling rates.
Plastic is omitted?: We echo the concerns raised by environmental scientist Laura Anderson and Friends of the Earth Scotland that the strategy "does not mention plastic once". Plastic production is a major driver of waste and pollution, and a credible circular economy strategy must set meaningful commitments to reduce plastic at source.
Place-based approaches and procurement should integrate community wellbeing metrics, such as local job creation through repair and share networks, to build wealth in areas like East Lothian.
Incineration: Lil does not consider incineration to be a sustainable waste disposal method. Energy-from-waste facilities produce significant carbon emissions that undermine net zero goals and contribute to air pollution. The strategy must enforce the hierarchy to phase out incineration in favour of higher-value circular activities.
Q6: Do you have any comments on the associated plans and priorities?
Plans should:
Mandate a "reduction first" approach with measurable targets for decreasing Scotland's material footprint.
Invest meaningfully in reuse and repair infrastructure as the priority before expanding recycling capacity. A significant reduction in Scotland’s resources is needed. Repair incentives like those utilised in Germany, France and Austria have shown strong uptake and satisfaction. Behaviour change in Scotland could be influenced with a Scottish Repair Voucher, halving the cost of repairs for households (with higher support for low‑income groups) and supporting local repair businesses by channelling more work to them.
Support community organisations like Lil as delivery partners, recognising the third sector's unique reach and expertise in behaviour change. Ring‑fence part of EPR funds for community reuse and repair infrastructure (revolving wardrobes, sharing libraries, repair hubs) to support growth in this sector, aligned with Community Wealth Building.
Include indicators for community wellbeing and wealth building, tracking jobs created in reuse/repair, access to affordable goods, and health outcomes linked to circular access.
Priority Sectors
Q7: To what extent do you agree with the priority sectors identified?
Agree
Q8: Do you have any comments on the priority sectors identified?
Lil agrees these sectors are high-impact priorities. Textiles, built environment, and the food system are particularly relevant to community-led circularity.
Q8a – Built Environment:
Plans must require lifecycle assessment and minimum reuse quotas for construction materials. Supporting local supply chains creates green jobs and reduces embodied carbon.
Q8b – Net Zero Energy Infrastructure:
Prioritise reuse and domestic reprocessing of critical raw materials. Scotland must not build its clean energy transition on environmentally harmful extraction elsewhere.
Q8c – Textiles:
Textiles are a priority for Lil. We run a self-serve revolving wardrobe and have experience in community-led textile reuse. The roadmap should:
Set reduction targets for textile consumption, such as caps or bans on fast fashion imports (a la France) not just recycling rates.
Support repair and resale networks before expanding kerbside recycling.
Address the global harms of fast fashion: textile waste exports to the Global South are causing environmental devastation, forever chemicals in poorly produced textiles are a health hazard for us all.
Ensure mandatory kerbside collection, if introduced, is accompanied by investment in the top of the hierarchy.
Q8d – Transport:
The transition to electric vehicles must embed circularity from the start, with local repair capacity and critical material recovery to reduce supply chain risks. The loss of these materials from the supply chain and future availability may jeopardise the transition timescale
Q8e – Food System:
The strategy lacks delivery plans to reduce the one million tonnes of food waste thrown away in Scotland annually. Production to retail waste reduction and community-led surplus sharing and redistribution should be a priority, enhancing local food security while minimising wasted food.
Q9: Do you have any comments on the proposed approach to product stewardship?
Product stewardship must:
Enforce the circular hierarchy, with incentives for designs enabling easy repair and reuse.
Ban incineration pathways for end-of-life products.
Mandate donation of unsold goods to community organisations rather than destruction.
Align with the EU's approach, including the ban on destruction of unsold textiles.
Monitoring and Indicators
Q10: Are there any changes or additions to the Circular Economy Monitoring and Indicator Framework?
The framework must:
Measure reduction, not just recycling rates. Recycling alone will not address the scale of the crisis.
Exclude incineration from positive circularity statistics, counting "energy recovery" alongside recycling creates false progress.
Include indicators for:
Material footprint per capita (target: 8 tonnes by 2045)
Jobs and economic value from reuse/repair
Resilience indicators could track community access to circular services
Health and wellbeing outcomes linked to circular economy participation
Track nature-positive outcomes, ensuring the strategy delivers for biodiversity as well as climate.
Q10a-h: Comments on specific outcome indicators:
Economic value: Include jobs in repair, reuse, and community enterprise sectors.
Resilience: Track critical material recovery rates and local supply chain development.
Innovation: Measure growth of community-led initiatives and social enterprises.
Environmental: Focus on hierarchy-driven outcomes; measure virgin material reduction.
International: Ensure Scotland's consumption does not cause harm elsewhere; include supply chain transparency metrics.
Social/fairness: Evidence that all communities, including low-income households, benefit equitably from circular services.
Circular behaviours: Assess actual reduction and reuse behaviours, not just recycling participation.
Impact Assessments
Q11 – Equalities Impact Assessment:
Community circular economy tools and services lower costs for households, enabling people on low incomes to access quality clothing and goods through reuse, reducing financial barriers to sustainable living.
Q12 – Fairer Scotland Assessment:
Community wealth building through circular economy creates local jobs in repair, reuse, and redistribution—keeping money in local economies and building skills.
Q13 – Island Communities Impact Assessment:
Place-based, community-led models are essential for fair access in rural and island communities, where centralised infrastructure may not reach.
Q14 – Business and Regulatory Impact Assessment:
SMEs and social enterprises should receive tailored support to comply with the hierarchy and develop circular business models. The current strategy does not adequately hold large businesses accountable for wasteful practices.
Q15 – Consumer Duty Impact Assessment:
Transparent labelling and digital product passports empower consumers to make informed choices aligned with the hierarchy.
Q16 – Child Rights and Wellbeing Impact Assessment:
Education on reduction and sustainable consumption builds future resilience. Children have the right to inherit a healthy environment, which requires urgent action on the nature and climate crises.
Q17 – Strategic Environmental Assessment:
Unidentified environmental impacts include:
Continued reliance on incineration, which undermines net zero and local air quality.
Microplastic pollution from waste processing.
Overseas extraction impacts from Scotland's consumption (scope 3 emissions).