Consultation – Scottish Proposals on a Circular Economy

Scotland are currently consulting on the potential for developing a more circular economy. This consultation opened on 7 November and will close on 19 December 2019

Comply Direct will be responding directly to the Scottish government and would advise that companies who are registered in, or trading in Scotland, also consider responding as the below areas may well affect your business activities in the future.

Key areas under consultation

Power to set charges for “environmentally harmful” items

The Scottish government are keen to reduce on the quantity of single-use packaging items placed on the market. By gaining powers to set charges on “environmentally harmful items” they would be able to add additional fees (such as those seen in the 5p plastic bag charge) to certain items which would (in theory) limit their marketability. Whilst this is something that we would support to some extent from an environmental perspective, we are concerned that this issue should be addressed on a UK wide basis rather than by individual devolved nations.

Mandatory waste reporting

The aim here is to introduce mandatory requirements for businesses to report publicly on waste (including food) and surplus stock. Whilst this is in line with a more circular economy, there are certain risks we would associate with it. Public reporting of surplus stock for example, could cause significant supply chain value issues. If a business is known to have surplus material, there may be an impact on the market value of their product. Once again, we would consider this an issue for UK-wide review rather than on a single devolved nation level.

Consistent recycling from local authorities

We are firmly in support of more consistent recycling from local authorities across the UK but this absolutely must be a UK-wide approach to enable a fair market for local authorities and ensure that “recyclability” can in the future have a transparent definition.

More mandated approach to household recycling for householders

Plans to put more pressure on consumers and householders surrounding recycling are not usually met with much public or political applause. That being said, there is a strong argument that consumers have the ultimate say as to what products they purchase and how they dispose of their waste, so this may well be a point for UK-wide consideration. As we move towards Extended Producer Responsibility for packaging and “full net cost” fees to be paid by producers, it is likely more will be expected from consumers and local authorities in terms of disposal of waste.

Powers regarding waste crime / littering

The planned implementation of powers to seize vehicles suspected of waste crimes, apply fixed penalties for littering from vehicles and hold registered keepers of vehicles responsible for litter in relation to their vehicle are all measures we support. As with the majority of this consultation, we believe this should be a UK-wide approach rather than specific to the devolved nations.

Single-use carrier bags

The outlined plan to raise the 5p bag charge to 10p is something we would support, there is relatively substantial evidence of the benefits to the bag charging scheme in terms of behavioural change which we believe supports this. There is also a question regarding the initial 5p charge and whether it has had a “positive impact on the environment”. We consider this too broad a statement to be able to agree with at present as there is not sufficient evidence of “positive environmental impact” and little information about the measurement of this criteria.


This consultation is likely one that members of the general public will be keen to engage with. For businesses, we would highlight the specific points above as areas for review as they may well have an impact on your activities if you are registered in, or trading in Scotland. For the most part we support a number of the proposals in this consultation, but would think it more fitting to manage as a UK-wide approach rather than in specific devolved nations.

Any Comply Direct members wishing to communicate their views on the consultation can either respond directly to the consultation via the below link, or feedback your views to us by emailing

Respond directly here: