Circular economy and waste route map to 2030

The Royal Society of Edinburgh (RSE) welcomes this opportunity to respond to the Scottish Government’s consultation on the circular economy and waste route map to 2030. Whilst the RSE recognises that the Scottish Government is moving in the right direction by setting out to develop a strategy for delivering a circular economy by 2030, this document does not provide sufficient detail on delivery, resources, or how to overcome present barriers to implementation. Further, it is unclear what this consultation aims to achieve by seeking views on “priority actions” already identified in previous consultations (see 2022 consultation), given the urgency of implementing these actions.

Executive summary

Moreover, the document does not clearly state the ultimate purpose of this route map. It lacks critical details of the timelines and resourcing needed to deliver confidence for public and private sector stakeholders and risks delaying much-needed action. There are dates included for some policies, and some actions that are identified as mandatory, but much of this strategy appears to be about preparing for the future rather than acting in the present.[1] Even if one agrees to the general premise of the document, it is not clear what this means in practice as the accompanying detail has been relegated to a future point in time. Therefore, the RSE would like to see more specifics regarding resourcing, regulation, and implementation, accompanied by a clear identification of who will be accountable for delivering the plan and what comes next. As it is presented, the route map is neither strategic enough nor underpinned by an appropriate programme of delivery. If stakeholders and industry are going to seriously adjust their processes and behaviour to move from linear to circular models, they will need a correspondingly firm commitment from government that their actions will be duly supported.

The route map shies away from addressing critical barriers to delivering a circular economy strategy in Scotland. For example, the document (page 24) calls for further action and ambition from the UK Government. Whilst this is an important point, there is no mention of how this cooperation might be achieved. In response, the RSE proposes setting up a UK commission for the circular economy (much like the Climate Change Committee) to determine how the UK and devolved administrations can work together to drive progress and avoid a repeat of the deposit return scheme. Whilst intergovernmental relations in the UK can be challenging to navigate at the best of times,[2] the Scottish Government must engage proactively with the UK Government and other devolved nations rather than remaining idle.

One element of the circular economy that is entirely left out of this route map is the potential for circularising the bioeconomy. The document instead focuses exclusively on a circular material economy (materials that are semi-permanent that we want to keep in use as long as possible). The RSE stresses that this is a significant omission. The environmental and economic opportunities within the bioeconomy are substantial. Scotland is uniquely placed to develop and benefit from a circular bioeconomy through its research institutions and thriving agriculture, food, and drink sectors. With this comes a need for thoughtful and proportionate regulation to avoid serious misalignment with England and other global markets. This is currently a blind spot within the document.

Overall, the RSE stresses that this document lacks ambition and urgency given that 2030 is very near, while failing to take a systems approach as stated in the consultation headline. The RSE is sceptical of whether a separate circular economy strategy should even be developed when principles of circularity should rather be embedded across all Scottish Government strategies and departments. By producing an individual strategy without clearly relating it to other relevant policies, the route map tries to do too much at once without presenting a clear path to any measurable action. The RSE would be keen to understand how it can support the Scottish Government in embedding circular economy thinking across government departments, drawing upon our multi-disciplinary expertise and ability to provide whole-systems analysis.

REFERENCES

1 Nearly all the concrete steps that are anticipated in the document are dated for the future e.g., statutory recycling and reuse local performance targets from 2030.

2 For example, see RSE Advice Paper “Intergovernmental relations: 25 years since the Scotland Act 1998.” Available here: https://rse.org.uk/expert-advice/advice-paper/intergovernmental-relations-25-years-since-the-scotland-act-1998/

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