1. About us
Consumer Scotland is the statutory body for consumers in Scotland. Established by the Consumer Scotland Act 2020, we are accountable to the Scottish Parliament. The Act defines consumers as individuals and small businesses that purchase, use or receive in Scotland goods or services supplied by a business, profession, not for profit enterprise, or public body.
Our purpose is to improve outcomes for current and future consumers, and our strategic objectives are:
- to enhance understanding and awareness of consumer issues by strengthening the evidence base
- to serve the needs and aspirations of current and future consumers by inspiring and influencing the public, private and third sectors
- to enable the active participation of consumers in a fairer economy by improving access to information and support
Consumer Scotland uses data, research and analysis to inform our work on the key issues facing consumers in Scotland. In conjunction with that evidence base we seek a consumer perspective through the application of the consumer principles of access, choice, safety, information, fairness, representation, sustainability and redress.
2. Our response
Household collection of textiles
Question 1. Do you consider your current options for textile recycling to be efficient?
No response
Question 2. Do you consider your current options for textile recycling to be accessible?
No response
Question 3. If you do not consider your current options for textile recycling to be efficient and/or accessible, what improvements would you recommend?
No response
Question 4. Do you believe household collection of textiles would provide benefits to householders?
Yes
Question 5. What potential benefits do you consider household collection of textiles would provide to householders?
We welcome the focus on reducing the impact of textile waste and note the significant impact this waste stream has. Zero Waste Scotland found that 32% of the carbon impact of Scotland’s household waste was accounted for by clothing, despite it only making up 4% of the weight of household waste.[1]
Research commissioned by Consumer Scotland found that 76% of consumers are either ‘very’ or ‘fairly’ concerned about climate change but only 28% said they knew a lot about what they need to do to help Scotland reach net zero by 2045.[2] Our research found that many consumers want to reduce their personal emissions with 80% agreeing that they would like to reduce the carbon emissions from the household items that they buy.[3] However, this concern about climate change is not translating into action that matches the pace and scale of change required.
Our research asked respondents about how they disposed of specific items when they became damaged. When asked about what they did the last time an item of clothing became damaged, the most popular responses were: took it to my local authority’s recycling centre (19%), disposed of it at home in my general waste bin (15%), repaired it (15%), recycled it using my local authority collection service (13%), and gave it away for free (12%).[4] The proportion of respondents noting that they disposed of the item in their home general waste bin illustrates the need for measures to support consumers to change how they dispose of fabrics.
A review of evidence, including Consumer Scotland’s evidence base, has identified cost, convenience, clarity, and confidence as the key issues for consumers in taking action to reduce their emissions and making the transition to a more sustainable future. Removing the time and cost barriers of travelling to a household recycling centre or another location to recycle textiles is a potential benefit to households, making end of life textile recycling easier, cheaper and more accessible. This may be particularly beneficial for consumers who live in remote and rural areas, who do not have access to private transport or who have health conditions that may make it more challenging to travel or otherwise take action to dispose of goods.
While measures to improve kerbside recycling have potential benefits for consumers, it is equally important that action taken on textiles moves beyond a focus on recycling and focuses attention higher up the waste hierarchy. Tackling overconsumption and production will be crucial to a successful transition to a circular economy, particularly where materials are not yet at the end of life. We note that the Circular Economy Act contains the enabling measure for Scottish Ministers to introduce secondary legislation to prohibit or restrict the disposal of unsold consumer goods in order to prevent such goods from ending up in landfill.
Supporting consumers in Scotland to move further up the waste hierarchy will be a key part in achieving our net zero targets. We would welcome the upcoming Circular Economy Strategy and Product Stewardship Plan setting out a clear plan with specific measures which can assist in moving the focus up the waste hierarchy. In particular there is a need for measures that can support consumers to reduce consumption and incentivise reuse and repair, such as lending libraries and repair and refurbishment services.
Question 6. Do you believe household collection of textiles should be a service supplied by local authorities?
No response
Question 7. 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?
No response
Question 8. What is the estimated number of textile items you recycle/dispose of each year?
No response
Question 9. What services are currently available in your local authority area to recycle or dispose of textiles?
No response
Question 10. What services do you currently use in your local authority area to recycle or dispose of textiles?
No response
Question 11. Do you foresee any barriers or unintended consequences to local authority collection of textiles at the kerbside becoming a statutory service?
We note that different areas of the country face varying challenges with kerbside recycling and it will be vital to take these differences into account when making changes to household recycling services. In some areas there may be a case for shared services for collection or disposal of textiles. We agree with the proposed approach which recognises that while everyone should have access to consistent recycling services that make environmentally friendly choices easy, different areas may take different approaches to service delivery. We would welcome further explanation of how this may look in practice as part of the development of the new statutory Code of Practice.
Where changes to household recycling do take place, it will be important to ensure that these changes are clearly communicated to households in a timely manner, including any differences within or between local authorities. We note that standardisation and consistency of measures may enhance consumer understanding and engagement and allow for clearer and simpler information to consumers, helping to reduce contamination levels of materials collected.
Question 12. If your local authority offered household collection of textiles, how likely are you to utilise this service?
No response
Question 13. Do you have any additional views, regarding household collection of textiles or what you would expect a useful service to look like?
No response
Rural food waste exemption
Question 14. Are you located in an area with a rural food waste exemption?
No response
Question 15. What is your preferred approach to the rural food waste exemption in the future?
No response
Question 16. If your local authority were to offer a kerbside food waste collection service, would you be likely to opt-in?
No response
Question 17. 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?
No response
Question 18. Do you have any other views regarding the rural food waste exemption?
We note the importance of tackling food waste, given the high carbon footprint associated with it, with Zero Waste Scotland estimating that around one million tonnes of food is thrown away every year in Scotland, equating to 4.74 million tonnes of CO2.[5]
It will be important to ensure that the carbon impact of collecting and transporting food waste is proportionate to the savings from recycling it. We note that different areas within and between local authorities face distinct challenges with kerbside recycling; it will be important that approaches can respond to regional differences rather than taking a one size fits all approach.
All consultation topics
Question 19. Equality: Are there any additional likely impacts the proposals contained in this consultation may have on particular groups of people, with reference to protected characteristics?
By removing the barrier of travelling to recycle textiles for consumers, the proposals contained in this consultation may have a positive impact for some consumers who may find it challenging to access textiles recycling points at household recycling centres or other locations. This may be of particular relevance for the protected characteristic of disability.
Question 20. 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?
No response
Question 21. 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?
No response
Question 22. Islands Communities Impact Assessment: Do you think that the proposals contained in this consultation are likely to influence an island community significantly differently from its effect on other communities in Scotland?
We note the distinct challenges faced by island communities, including lower population density and relatively limited waste and recycling infrastructure. Any major change to kerbside recycling has the potential for these areas to face high costs in establishing new infrastructure or significant costs, and associated emissions, for transportation to the mainland. It is important that these financial and carbon costs are carefully balanced against the benefits of the collection of materials.
Question 23. 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?
No response
Question 24. Do you think that the proposals contained in this consultation are likely to have an impact on the environment?
We welcome attention being given to food and textile waste and note the significant impact that these waste streams have. The Scottish Waste Environmental Footprint Tool has identified textiles and food as two of the waste types that contribute the most to climate change, making it vital to support consumers to change behaviours to reduce waste.[6]
As noted above, it will also be vital to focus attention on measures higher up the waste hierarchy. Tackling overconsumption and production will be crucial to a successful transition to a circular economy, particularly where materials are not yet at the end of life. Supporting consumers in Scotland to move further up the waste hierarchy will be a key part in achieving our net zero targets and we would welcome further measures that support consumers to reduce consumption and incentivise reuse and repair for textiles.
Question 25. Conclusion: Do you have any other comments that you would like to make, relevant to the subjects of this consultation, that you have not covered in your answers to other questions?
3. Endnotes
[1] Zero Waste Scotland (2023) How do our clothes impact the climate crisis? Available at: How do our clothes impact the climate crisis? | Zero Waste Scotland
[2] Consumer Scotland (2024) Consumer perceptions of and engagement with the transition to net zero. Available at: xm24-02-consumer-perceptions-of-and-engagement-with-the-transition-to-net-zero-final-report.pdf
[3] Consumer Scotland (2024) Consumers and the transition to a circular economy. Available at: https://consumer.scot/media/fyqohozv/consumers-and-the-transition-to-a-circular-economy-report.pdf
[4] Consumer Scotland (2024) Consumer perceptions of and engagement with the transition to net zero. Available at: xm24-02-consumer-perceptions-of-and-engagement-with-the-transition-to-net-zero-final-report.pdf
[5] Zero Waste Scotland (2024) Reducing Food Waste at Home. Available at: Food Waste Reduction Bitesize Training Course
[6] Zero Waste Scotland (2024) Scottish Waste Environmental Footprint Tool. Available at: mf-melt3roo-1716290167d