Last week, the Hub submitted our response to the draft Circular Economy Strategy Consultation. This is a welcome strategy, however it is not nearly ambitious enough to drive the systemic change Scotland urgently needs. Below is our full response to the consultation (including a short version), but first a look at what this all means.
What is a Circular Economy?
The term Circular Economy is one that’s become increasingly common, yet still often misunderstood.
So, what is a Circular Economy? A circular economy is a system that shifts from the linear “extract-make-waste” model to one focused on eliminating waste and keeping resources in use for as long as possible.
It involves designing products that are built to last and easier to repair, as well as creating the infrastructure that makes this possible. Repair cafes, reuse hubs and community libraries of things, where people can borrow rather than buying new, are all examples of the types of infrastructure that contribute for a circular economy.
Oftentimes, recycling is the first thing that pops into people’s minds when they hear about the term, however reduce, reuse, share and repair are arguably more important.
What is the Circular Economy Strategy?
This draft circular economy strategy sets out the rationale and benefits of a more circular economy in Scotland. It describes the overall vision to 2045 and the outcomes the Scottish Government is working towards, as well as the policy mechanisms and priority sectors identified and their associated plans.
You can read our full response below, but here’s the short version.
TL;DR: Our response
We broadly support the vision and outcomes set in the strategy, especially the links between a circular economy, net zero, nature recovery, and social/economic benefits. The draft strategy has a positive recognition of reuse and repair, reducing reliance on virgin materials, and the global impacts of Scotland’s consumption.
However, the strategy is too broad and insufficiently ambitious to drive the systemic change we need.
- There is an over-reliance on voluntary action, rather than enforceable regulation.
- Major gaps include the absence of explicit action on plastics, planned obsolescence, and electronics and digital waste
- Stronger regulation and ambitious Extended Producer Responsibility are needed to shift responsibility from communities and local authorities back to producers. The strategy needs a stronger emphasis on Polluter Pays principle that ensures producers are responsible for the waste their products create
- Communities are under-valued. Communities are acknowledged but not empowered. The strategy fails to recognise community-led initiatives as drivers of change. Communities should be more strongly embedded with long-term funding and real decision-making power
- Behaviour change must be enabled by systems. It is unfair and ineffective to ask for behaviour change without creating a system that allows for it. The strategy should have a bigger emphasis on affordability and access as key enablers of behaviour change.
- Procurement, skills, and sector roadmaps must move from guidance to mandatory standards, while supporting local jobs, local supply chains, and community wealth.
Our full consultation response
Q1-3: Do you have any comments on the vision or the outcomes?
We broadly support the vision and outcomes of the draft strategy, which clearly links a circular economy to net zero, nature recovery, and social and economic benefits. It is particularly positive that the draft recognises the importance of reuse and repair, reducing reliance on virgin materials, and the global impacts of Scotland’s consumption.
However, the vision and outcomes remain too broad to drive the systemic change Scotland urgently needs. While it references reduced material use, minimised environmental impacts, and circular behaviours, the draft does not explicitly address some of the most critical drivers of harm, including single-use plastics, products designed for planned obsolescence, and high-impact materials, leaving a major gap in the strategy’s ambition. Without specific commitments in these areas, there is a risk that progress may appear more significant than it is in reality.
Similarly, while community benefits are acknowledged and reuse and repair are noted, the draft fails to recognise the role that community-led initiatives can and should play not just in benefiting from circular activities, but in actively shaping and driving them. Local, community initiatives and networks should be actively embedded in a vision of a circular economy for Scotland.
Outcomes should highlight these priorities, connecting reuse and repair not only to social benefits but also to economic opportunities, job creation, and a more resilient, local supply chain. Embedding community influence in the strategy is essential to ensure that change is meaningful and aligned with both local needs and broader system-level change.
Q5: Do you have any comments on the policy mechanisms identified?
Policy Mechanisms identified:
- Business support
- Behaviour change
- Place-based approaches
- Procurement
- Skills and education
- Circular economy data
- Policy alignment and systems thinking
It is positive that the draft recognises systemic thinking, local approaches, and business support, as well as the role of data in tracking progress.
However, the strategy relies too heavily on voluntary action and guidance for business rather than regulations and enforceable legal requirements. This risks uneven implementation across sectors and weak accountability, particularly in sectors where voluntary action has historically failed to deliver meaningful change.
The strategy also needs a stronger focus on support for community-led initiatives and their role in a circular economy. It needs to emphasise stronger commitment for community funding and long-term investment for reuse, share and repair initiatives.
Place-based approaches are mentioned, but without guaranteed, sustained funding, local circular initiatives risk being short-lived or fully dependent on volunteers. Policy mechanisms should explicitly link community support to producers, ensuring they contribute funding, resources, and incentives to sustain repair cafés, tool libraries, or local share and reuse enterprises.
The strategy should be more firmly grounded in the polluter pays principle and supported by an ambitious Extended Producer Responsibility (EPR) programme, ensuring that the largest producers of waste, including single-use plastics and other non-recyclable or non-reusable materials, are legally required to fund prevention, reuse, recycling, and safe end-of-life management. Stronger policy mechanisms are needed to shift responsibility from communities, consumers and local authorities to those who create waste in the first places!
Q6: Do you have any comments on the associated plans and priorities?
Business support
Influencing business behaviours, models, and practices is positive, but the draft over-relies on voluntary uptake and guidance rather than enforceable requirements. The strategy could be strengthened by explicitly linking business accountability to Extended Producer Responsibility (EPR) frameworks: all businesses should be required to take responsibility for the full lifecycle impacts of the products they put on the market. This would create clear legal and economic incentives for circular design, waste reduction, and engagement with reuse and repair, ensuring that responsibility shifts from communities and local authorities back to producers, and that circular practices become standard across the economy.
Behaviour change
A systems thinking approach rather than focused individual change is positive, as well as acknowledging that many people want to reduce their impact but struggle to move beyond low-impact changes. It is unfair and ineffective to ask for behaviour change without creating a system that allows for it. The strategy should have a bigger emphasis on affordability and access as key enablers of behaviour change. Initiatives such as a Reuse Credits System or Repair Voucher Scheme, as suggested by the Circular Communities Scotland’s manifesto, are two examples of schemes that could help with behaviour change.
Place based approaches
Having a focus on place-based approaches and acknowledging communities across Scotland require local solutions is extremely positive and very welcome, however the draft fails to mention how local, community-led and grassroot groups will be involved in defining these approaches. Long-term funding and support for local initiatives could play a crucial role in ensuring approaches are truly led by local communities, but the draft fails to address how and if local communities will be empowered to influence or be actively involved in shaping place-based approaches. A clear mechanism for local places to learn from one another should also be defined to ensure every region in the country can share what has worked and what hasn’t effectively.
Procurement
Procurement is rightly identified as a powerful lever for change, given the scale of public sector spending. The intention to embed circularity into procurement and to prioritise reuse, repair, recycled content and future recyclability is extremely important. However, this potential will only be realised if these principles move beyond guidance and become clear, mandatory requirements with measurable standards. Choosing goods with recycled content or reusable and repairable products should not be optional. Stronger regulation and minimum criteria are needed to ensure consistency across public bodies and to give suppliers the confidence to invest in circular products and services. A stronger community lens should also be applied. Circular procurement can and should actively support local and community-based enterprises (including producers, repair services, reuse organisations, etc.) supporting local economies in the process. This requires procurement frameworks that are accessible to smaller providers and do not unintentionally favour large suppliers.
Skills and Education
The focus on skills and education as enablers of a just transition to a circular economy is welcome, particularly the intention to embed circular skills across the wider education and training system. However, the emphasis on supporting skills “in sectors important to economic growth” risks prioritising new or emerging green industries over the upskilling or reskilling of local workforce. Many of the most critical circular skills (repair, maintenance, refurbishment, reuse, etc.) are already being practised within community initiatives, social enterprises, and local reuse and repair hubs, yet these are not sufficiently recognised or supported. The strategy should place greater emphasis on strengthening and scaling these existing skills by investing in community-based training and on stable funding for local circular initiatives.
Q8: Do you have any comments on the priority sectors identified?
Priority Sectors identified:
- The Built Environment
- Net Zero Energy Infrastructure
- Textiles
- Transport
- The Food System
The priority sectors identified are broadly appropriate and focus on areas with high material use, emissions and waste. It is positive that the draft links these sectors to circular economy principles while considering opportunities for economic and social benefit. However, there are important gaps that limit the ambition of this strategy.
Most notably, plastics are not addressed as a priority, despite being a large source of waste across multiple sectors, particularly food packaging and consumer goods. In fact, the word plastic is not used a single time across the full strategy, which is a glaring omission. On top of many types of plastic being single-use and non recyclable, plastics have well-documented environmental and health impacts across their lifecycle, from fossil fuel extraction and production to pollution, microplastics and waste management. Only considering plastics indirectly risks diluted action and little accountability. A stronger, explicit focus on plastics as a material and on finding alternatives across sectors is needed.
Secondly, the strategy does not explicitly include electronics and digital infrastructure, which is one of the fastest growing waste streams globally and increasingly significant in Scotland with rising consumption of electrical and electronic equipment, as well as shorter products lifecycles. With the expansion of AI, data centres and digital services, this sector will only increase in material demand. It also carries significant international impacts through resource extraction and waste exports, which the strategy does not currently address. Yet, it presents clear opportunities for community-level action through repair, reuse, skills development and local e-waste infrastructure.
Effectiveness of these priorities will depend on the strength, ambition, and enforceability of the forthcoming sector roadmaps.
While the draft acknowledges the role of businesses, it places far less emphasis on the role of communities. Across all priority sectors, there is a missed opportunity to more explicitly support community-led circular initiatives, such as share and repair hubs, reuse initiatives, or local food projects. These initiatives already exist in many places, reduce material use directly, and deliver social benefits alongside environmental ones. Community input should actively shape the development of sector roadmaps, both at local and national levels, to ensure interventions reflect real place-based needs. Communities know their areas best and should have an active voice in creating these roadmaps.
Finally, the strategy relies too heavily on voluntary uptake and guidance, not providing clear enough incentive for sectors with strong commercial incentives. Enforceable minimum standards, combined with strong Extended Producer Responsibility schemes, are needed rather than relying primarily on voluntary adoption by businesses, local authorities or individuals.
Q8a: Do you have any comments on the plans and priorities for the built environment?
The emphasis on lifecycle assessment and prioritising activity further up the waste hierarchy is very positive. The focus on sourcing locally and increasing reuse through initiatives like regional construction material hubs is also welcome, as it has the potential to create local jobs and strengthen supply chains.
However, the draft could more explicitly embed community involvement in planning, decision-making, and ownership. Local residents, housing cooperatives, and community-led development groups should have a formal role in shaping new developments and easier access to retrofit options that are embedded in a circular economy. This could include community advisory boards, participatory design processes, and direct support for community ownership.
The roadmap should move beyond guidance and suggestions to include enforceable requirements for developers, ensuring that circular economy principles are applied consistently and benefit communities directly.
There should also be stronger support for local skills development, repair and refurbishment enterprises, and training opportunities linked to circular construction.
Q8b: Do you have any comments on the plans and priorities for the Net Zero Energy Infrastructure?
Recognising the material intensity of net zero infrastructure and linking it to circular economy principles is an important and positive step. Encouraging refurbishment and reuse rather than disposal is especially welcome.
Achieving net zero is vital, but the strategy must make it clear that decarbonisation should not come at the cost of creating large future waste streams or generating social and environmental harms elsewhere. There needs to be stronger emphasis on end-of-life planning for energy assets, prioritising repowering, refurbishment, and modular upgrades rather than full replacement. Circular economy principles should be embedded at every stage, from design and procurement to decommissioning, ensuring that materials stay in use as long as possible and that potential waste is minimised.
A stronger community lens is essential. Where assets are decommissioned before their natural end-of-life, components or materials should be offered to local communities, as well as technical, financial and governance support to ensure they can benefit from them. This ensures the transition to net zero also strengthens communities and helps build local wealth.
Q8c: Do you have any comments on the plans and priorities for textiles?
The draft rightly highlights the importance of reuse and the right to repair, which are central to building a circular textiles sector. The emphasis on restricting exports of textile waste and the consideration of kerbside collection of textiles are also welcome steps.
However, the strategy should place stronger focus on reducing, sharing, reusing, and repairing textiles at every stage of their lifecycle. Strong Extended Producer Responsibility schemes would be the most effective mechanism to achieve this, legally enforcing producers to fund and deliver systemic solutions rather than relying on voluntary action.
Greater support for local textile-based social enterprises, repair cafés, cooperatives, and community-led reuse initiatives could simultaneously enhance circularity, build skills, and create local jobs that build local wealth. Embedding community involvement in the development of sector roadmaps will help ensure interventions meet real local needs and strengthen local economies.
Q8d: Do you have any comments on the plans and priorities for transport?
The draft rightly recognises transport as both a major source of emissions and a highly material-intensive sector, and it is positive to see circular economy principles explicitly linked to the transition to electric vehicles.
However, there is limited consideration of demand reduction and shared transport as core circular strategies. While EVs are necessary for decarbonisation, a circular transport system must also prioritise reducing total vehicle numbers through better public transport, car sharing, active travel and goods transport. Without this, material demand for vehicles and batteries will continue to rise, undermining circular economy objectives even if recycling improves. Given transport is a key sector within the Climate Change Plan we hope the road map will emphasise creating a strong public transport network that not only reduces emissions, but also the amount of materials needed for new vehicles.
Q8e: Do you have any comments on the plans and priorities for the food system?
The draft does well in recognising the importance of behaviour change and business engagement to reduce food waste, and the proposal for mandatory reporting on food waste for businesses is a very positive step toward creating a clear, evidence-based picture of the issue
However, the strategy does not go far enough in addressing packaging waste, particularly single-use plastics, which remain a major environmental and public health concern. Much of this packaging is not recyclable or collected through kerbside services, and the draft does not address this gap. The strategy should include robust Extended Producer Responsibility schemes for food packaging, ensuring that producers are legally required to reduce, reuse, and take responsibility for end-of-life management of their products. EPR could also incentivise the design of refillable, reusable, and repairable packaging solutions, helping shift the system away from single-use plastics.
Local groups, food cooperatives, social enterprises, and community kitchens play a crucial role in reducing food waste and redistributing surplus, often with other social and economic benefits to the local area. The strategy should actively support these initiatives, ensure long-term funding, and embed local voices in the development of sector roadmaps. This would help ensure interventions respond to real local needs and strengthen local resilience.
Q9: Do you have any comments on the proposed approach to product stewardship
The draft’s emphasis on product stewardship grounded in the “polluter pays” principle provides a strong foundation, clearly recognising that producers should take responsibility for the full lifecycle impacts of their products. It is also positive that the strategy highlights key high-impact products such as packaging, electronics, batteries, vehicles, and end-of-life fishing gear, and commits to an evidence-based approach for prioritising additional products.
However, the approach needs to be more ambitious. Most importantly, the focus should be on an ambitious Extended Producer Responsibility programme. EPR has proven to be the most effective tool for holding producers accountable, driving product redesign, reducing waste, and incentivising reuse and repair. While voluntary measures, takeback schemes, and recyclability requirements have a role, they are insufficient on their own to transform the system. Prioritising EPR would provide clear legal and economic incentives for producers to reduce the environmental footprint of their products, embed circular design principles, and shift the responsibility (both financial and environmental) back to the producers who create the products, rather than leaving the burden on communities and local authorities.
Equally, the strategy should emphasise reusable and repairable products as the preferred solution. Reducing the overall need for new products should be central, supported by EPR frameworks. Without this focus, there is a risk of perpetuating linear consumption patterns and missing significant social, environmental, and economic benefits.
The draft also overlooks the important role that communities can play in effective product stewardship. Local reuse networks, repair cafes, and refill hubs are not only beneficiaries of stewardship measures but can actively shape demand, support behaviour change, and ensure that circular practices are adopted at scale. The strategy should recognise the influence of community-led initiatives and commit to providing long-term support and funding to ensure these initiatives succeed, remain sustainable, and deliver local economic and social benefits, keeping wealth and skills within communities.
