Scotland’s Draft Climate Change Plan: 2026–2040

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.

The Consumer Principles are a set of principles developed by consumer organisations in the UK and overseas.

Consumer Scotland uses the Consumer Principles as a framework through which to analyse the evidence on markets and related issues from a consumer perspective.

The Consumer Principles are:

Access: Can people get the goods or services they need or want?

• Choice: Is there any?
• Safety: Are the goods or services dangerous to health or welfare?
• Information: Is it available, accurate and useful?
• Fairness: Are some or all consumers unfairly discriminated against?
• Representation: Do consumers have a say in how goods or services are provided?
• Redress: If things go wrong, is there a system for making things right?
• Sustainability: Are consumers enabled to make sustainable choices?

We have identified choice and sustainability as being particularly relevant to the consultation proposal that we are responding to.

Question 1 - What are your views on our approach to delivering a just transition for people and communities? 

Without a significant contribution from consumers it will not be possible to effectively respond to climate change in Scotland and protect people from the consequences.  The UK Climate Change Committee’s Seventh Carbon Budget estimates that household low-carbon choices will contribute to one-third of emissions reductions in 2040.

Too often, plans to reduce climate change emissions focus primarily on the technical changes, technologies and products involved, but do not give sufficient attention to the people who will use the heat, vehicles, electricity, or waste services, and to the changes that they will have to make in their lives.

Consumer Scotland’s evidence shows that most consumers are aware of and are concerned about climate change. However, while climate change matters to them, so too do many other issues. In particular, cost-of-living pressures mean that many households in Scotland face significant concerns in being able to afford the goods and services that they need across a range of markets.

Across Consumer Scotland’s work, people tell us that with busy lives and competing priorities, they value the convenience of the products and services they buy or use. But some of the choices which could support the climate transition can have significant up-front costs and be inconvenient or difficult for consumers to navigate.

The Climate Change Plan has to help change this. If people cannot afford sustainable products and services, or integrate them easily into their lives, consumers will not be able to respond to the climate emergency in the way that governments require. Achieving the level of consumer engagement that is needed will require innovation and thinking from government, regulators and businesses which go beyond engrained ways of providing and using goods and services.

A new, systemic approach is required to underpin fair and effective consumer engagement in a just transition to net zero. Consumer Scotland has published a climate change framework for policymakers which can inform the delivery of a new systemic approach, with consumers at the centre. 

The framework identifies Cost, Convenience, Clarity and Confidence (the 4 Cs) as the key consumer issues that decision makers must address when proposing policies to address climate change.[1]

In line with this, the final Climate Change Plan must clearly address the following issues:

• Cost: the Plan must ensure that measures are fully costed, including detail on any interdependencies with other policies, and ensure that costs are spread fairly between current and future generations
• Convenience: the Plan must prioritise the creation of an enabling environment, where it is more straightforward for consumers to make the changes being asked of them
• Clarity: the Plan must contain clear and measurable objectives that set out how the interventions and policies will deliver the five-year carbon budget
• Confidence: the Plan must communicate clearly what is being asked of consumers and identify where any additional protections are required to protect consumers during the transition. It must provide detail about the support available, particularly for actions that will have significant upfront costs, such as changes to home heating and vehicles

Consumers in vulnerable circumstances, including those on low incomes, will need targeted support such as specific advice and financial support to ensure that they are not left behind.

This is the first Scottish Climate Change Plan which is underpinned by statutory just transition principles and includes just transition indicators as part of the monitoring and evaluation framework. Having the ability to track progress through these indicators will help to secure a just transition to net zero.

In addition to publishing the plan itself, we recommend that the Scottish Government works with a range of stakeholders to publish an updated public engagement strategy to provide consumers with the clarity and confidence required to facilitate behaviour change.

Question 3 - The Plan will bring opportunities and challenges for businesses and employers. How can we best support employers across the private, public and third sectors to make the changes needed and seize the benefits of net zero?

The draft Climate Change Plan aims to create the conditions for investment by giving clear signals of where public money will be invested to grow markets, to meet Scotland’s decarbonisation objectives and transition the economy. We welcome this ambition, but consider that the final Climate Change Plan should provide more detail on timings and sequencing of investment to allow for effective business planning and to secure buy-in.

Question 4 - Our approach recognises that some of the Plan’s impacts will have greater implications for particular regions of Scotland. What are your views on our approach to supporting places where the transition presents particular regional impacts?

We welcome the acknowledgement of the particular implications of the transition to net zero for rural and island communities. Acknowledging these challenges and responding appropriately to them will be vital for securing a just transition to net zero for all consumers.

On waste, recent polling by Consumer Scotland has found that not having access to a suitable local facility is a commonly cited barrier for consumers not recycling some items:

• For food waste, not having a suitable local facility was the most frequently cited barrier (15%, rising to 18% of respondents from rural areas) to recycling
• For clothing and textiles, not having a suitable local facility was the most frequently cited barrier (15%), closely followed by respondents not knowing where to get items recycled (14%)
• For small electrical items, not having a suitable local facility was the most frequently cited barrier (17%), closely followed by respondents not knowing where to get items recycled (15%)

There are large areas of the country who do not have access to local recycling facilities for these materials and this inequitable distribution means that many are unable to access services. We note the Scottish Government consultation on strengthening the approach to household recycling collection which included consideration of the rural food waste exemption and options for kerbside recycling and the commitment for further engagement and consideration to be taken forward through the co-design of the new household recycling Code of Practice.[2]

There are significant transportation and infrastructure challenges faced by rural and island communities in relation to waste collection and processing. It will be important to ensure that the carbon impact of collecting and processing materials is proportionate to the savings achieved. Measures relating to recycling must take into account the different geographical and community needs that local authorities and residents across Scotland encounter, for example, the different considerations for an urban area with flatted properties compared to a sparsely populated rural area. The commitment to co-design of the new household Code of Practice should allow these differences to be explored with a view to ensuring that the needs of consumers, including those in vulnerable circumstances, are taken into account.

On transport, the draft plan acknowledges the greater reliance on car use and the challenges in delivering public electric vehicle charging facilities at scale on rural and island areas. The final Climate Change Plan should include specific, targeted, time-bound policies to address these challenges.

Buildings (Residential and Public)

Question 5 - How can we decarbonise homes and buildings in a way that is fair and leaves no one behind?

We are aware of the significant work being carried out across the Scottish Government to decarbonise homes and buildings. We are also aware of other related pieces of work to support the rollout of low carbon technologies, tackle fuel poverty and address climate change. To ensure that no one is left behind it will be important that different initiatives across government are aligned, coordinated and done in parallel. Examples include the forthcoming Heat in Buildings Strategy update and delivery plan and the fuel poverty strategy update. To fully realise the benefits of the energy transition and decarbonising homes and buildings it will be important that government takes a joined up approach and coordinated action. We would encourage the Scottish Government to ensure that the Climate Change Plan considers wider work to ensure that all of these different stands of work align to meet its objectives. 

Question 6 - How can clean heating systems (such as heat pumps) be made more affordable for everyone?

Consumer Scotland’s research highlights that upfront costs remain one of the most significant barriers to adoption of low carbon technologies such as heat pumps.[3] The Scottish Government has taken action to mitigate this through the funding of the Home Energy Scotland Grant and Loan Scheme administered through Energy Saving Trust. This has helped to bring down the cost of installation and make it more financially viable for consumers. However, even with considerable funding and support available, cost remains a significant barrier for consumers to overcome. 

We have identified a number of key actions that could be taken to make clean heating systems more affordable for consumers and which should be considered in the final Climate Change Plan:  

• Access to grants and incentives play a crucial role in enabling consumers to proceed with installations. The Scottish Government need to ensure that this support is easy to access and navigate as this will help to reduce cost related barriers for consumers considering the installation of low carbon technologies in their homes.  
• Consumer Scotland’s recent investigation into the green heating market[4] also recommended that the Scottish Government review consumer funding and financial support for energy efficiency measures to ensure that it accounts for impact, fairness, and effectiveness. This will help to ensure that funding is used in a fair and accessible way and can continue to meet demand. 
• Recent changes to the Grant and Loan Scheme have removed funding for solar PV and battery storage systems; both measures that when coupled with a heat pump can make it a more cost effective heating solution. The Scottish Government should review the current incentives that are in place to encourage consumers to consider complimentary technologies which could also help to lower bills and incentivise the installation of clean heating technologies.   
• Alternative financial offerings could also help consumers to overcome the higher upfront cost associated with purchasing a heat pump but these options are still limited.[5] The Green Heat Finance Task Force has produced a report which explores alternative finance models that could be considered in future. We would encourage the Scottish Government to consider how it can accelerate this work to provide consumers with additional options to overcomes higher upfront costs.
• There is still a lack of installers of low carbon technologies particularly in rural areas in Scotland and this is an area of concern. We are aware that the Scottish Government are taking action to mitigate this through the Heat in Buildings supply chain delivery plan.[6] A more competitive market is an effective measure to drive down prices to consumers. The Scottish Government should accelerate this work to ensure that supply chains are sufficient to meet consumer demand and also ensure a more competitive market.

Action to make these technologies more affordable must sit alongside the wider initiatives to support consumers to decarbonise their homes and access clean heating systems. It is also essential that consumers have clarity on the specific actions that they can take, which will make installation more straightforward and convenient to undertake.   

Transport

Question 7 - Which of the following would be most effective in enabling you to transition your vehicle(s) to zero emissions alternatives? Please rank your choices from highest to lowest priority, where 1 is the highest priority. Please only give one ranking to each option: If you’re responding for an organisation: you may want to consider car fleets as well as HGV fleets.

1.    All of the above

2.    Cost of new zero emissions vehicles needs to come down

3.    Cost of used zero emissions vehicles needs to come down

4.    Convenient access to public charging infrastructure

5.    Reliable infrastructure for vehicles (such as fuel or charging networks)

6.    Other (use box below) - ) Improved information about the cost and convenience of ZEV ownership

7.    Noticeably cheaper running costs (including electricity, maintenance and insurance)

8.    Ensuring an adequate number of trained mechanics available to perform essential maintenance and repairs

9.    Access to funding support /low cost finance

Question 8 - How can the Scottish Government support communities to participate in planning of local sustainable infrastructure (such as, walking, wheeling and cycling routes)?

Consumer Scotland recommends prioritising universal design practices when developing local sustainable infrastructure, to include expertise by consumers with lived experience of different challenges. Consumer Scotland research has shown that both accessibility and safety are key barriers to more sustainable travel choices for some, and especially disabled people. [7] For infrastructure to be inclusive to all, planning processes must take diverse experiences, including those of consumers in vulnerable circumstances into account.

Question 9 - What action by the Scottish Government would be most helpful in supporting you to live a more climate-friendly lifestyle?

As noted above, Consumer Scotland has identified cost, convenience, clarity and confidence (the 4 Cs) as the key consumer issues that decision makers must address when for consumers to participate fully in the transition.[8] 

Our research shows consumers are willing to adopt transport behaviours which create less emissions, but that there are barriers to behaviour change. In addition to concerns about cost and convenience, consumers may lack awareness of the impact of making changes and of the benefits of such changes.[9] In relation to transport, consumers are often more influenced by how their journeys can be made more affordable and convenient than by concerns about environmental impact. However, sustainability concerns can be a significant secondary factor in consumer motivations.[10] The final Climate Change Plan must take action to remove barriers to behaviour change in how consumers use public transport. Relevant actions include addressing affordability, accessibility and safety concerns, as well as action reduce public transport journey times and to ensure ticketing options are frictionless and convenient.

While each of the separate interventions proposed in question seven addresses at least one of the key consumer issues of cost, convenience, clarity and confidence, consumers would benefit from improved information on the costs, benefits and overall experience of EV ownership. As higher upfront costs for buying a ZEV can be a barrier to purchase for some, efforts to reduce the upfront costs of both new and used ZEV would also be helpful. Consumer Scotland research has also highlighted the importance of reliable access to affordable public charging infrastructure as being central to consumers’ ability to transition to zero emission vehicles.[11] Addressing concerns related to public charging networks should be prioritised, to ensure these are convenient, reliable, affordable and accessible.

We recommend that the Scottish Government should address transport issues as part of a consumer focused public engagement campaign. This campaign should highlight the co-benefits of public transport and active travel to highlight affordability, convenience and health benefits when compared to car use.

Waste

Question 10 - Are there any additional proposals to support waste sector emission reduction that should be considered across the following 5 areas:

• Strengthen the circular economy

• Reduce and reuse

• Modernise recycling

• Decarbonise disposal

• Other emission sources (including waste water and anaerobic digestion)

Overview

Around four-fifths (82%) of Scotland’s carbon footprint comes from the products and services we manufacture, use, and throw away.[12] Action to increase circularity could help to reduce emissions in Scotland by up to 43%.[13] Successful implementation will depend on individual consumers being enabled to make more sustainable choices and to understand which of their actions can have the most impact.

The final Climate Change Plan should focus on:

• Enabling consumers to more easily take action by addressing the key barriers of cost, convenience, clarity and confidence (the 4 Cs)[14] 
• Providing greater detail and clear timelines of policies so that consumers can better understand what is being asked of them and when they need to make changes
• Providing greater clarity in the final plan about the detail of the measures that will be taken, where the impact of policies will lie and providing targeted support to mitigate any disproportionate impact on consumers in vulnerable circumstances will enable all consumers to participate in the transition to net zero and a circular economy.

Many of the measures outlined in the draft Climate Change Plan are drawn from the existing Circular Economy and Waste Routemap. We recommend that the Scottish Government includes additional, time bound policy measures in the final Plan, such as:

• Provision of targeted support for small businesses to facilitate the transition to more circular models. This should include facilitating peer learning, financial support and targeted advice for businesses. Businesses must be supported to deliver excellent standards of service to consumers, including clear information about products and services and the development of swift and effective redress methods for where things go wrong, if they are to compete with more traditional linear business models.
• Action to ensure that more consumers across Scotland are aware of and have access to repair, reuse and recycling options that work for them, particularly in relation to high impact items such as food and textiles. Delivery should take into account the needs of consumers in vulnerable circumstances and those living in remote and rural areas
• Measures to reduce consumption of textiles to encourage business models that focus on responsible consumption and improve the quality of end products so that goods last longer

Strengthening the circular economy

Consumer Scotland has recently responded to the draft Circular Economy Strategy consultation. In line with our response here, we recommend that both the final Strategy and the upcoming priority sector roadmaps should include more specific measures and more detail on the timing and sequencing of these.

Consumer Views on repair and reuse of textiles and electricals

Consumer Scotland supports action on food and textile waste, as these have significant impacts.  The Scottish Waste Environmental Footprint Tool identifies these as two of the waste types that contribute the most to climate change, making it vital to support consumers to change behaviours in these areas.[15] Food waste is the largest contributor to biodiversity loss; and textiles and food are among  the most significant contributors to air pollution and water use impacts.[16]

Research carried out for Consumer Scotland in 2024 found that consumers are open to taking circular economy measures. There was support amongst consumers for products being made so that they are easy to repair and their components can be re-used, even if this impacts product quality (74% agreed) and for companies selling products being responsible for taking them back for recycling or disposal at end of product life (70% agreed). [17] Our research found lower levels of support amongst consumers for products which can't be repaired or recycled being taxed more, even if it increases their cost (49% agreed) and banning of products which can’t be repaired or recycled (40% agreed).[18]

More recent independent polling conducted by IFF Research for Consumer Scotland in 2025 shows that consumers need more support to move their actions further up the waste hierarchy, and to focus on reducing consumption and reusing items. The research asked consumers about how frequently they repair, recycle or throw away clothing and electrical items:[19]

• 33% stated that they frequently repair clothing with minor damage, compared to 44% stating that they frequently recycle and 12% stating that they frequently throw clothing with minor damage away
• 11% stated that they frequently repair clothing with significant damage, compared to 36% stating that they frequently recycle and 26% stating that they frequently throw away clothing with significant damage
• 23% stated that they frequently repair small electricals with minor damage, compared to 42% stating that they frequently recycle and 9% stating that they frequently throw away small electricals with minor damage
• 9% stated that they frequently repair small electricals with major damage, compared to 42% stating that they frequently recycle and 16% stating that they frequently throw away small electricals with major damage.

The findings show a relationship between the severity of damage and how consumers respond. Across both clothing and small electricals, recycling is more common than repair, indicating that many items are moving out of use prematurely. While recycling services are important for end of life materials, it is important to ensure that as little as possible reaches this stage in order to extract the maximum value from materials. Recycling emerging as the dominant behaviour for each item illustrates that consumers need more support to move further up the waste hierarchy to increase levels of repair. The final Plan should include a focus on the measures needed to increase levels of repair, such as improving access to and awareness of repair services and providing targeted business development to encourage greater number of repair businesses across Scotland.

On textiles, our recent polling asked about reasons for not recycling or repairing clothing and textiles:[20]

• When asked about reasons for not recycling clothing and textiles when they are no longer needed or usable, the most frequently cited reasons were ‘no suitable local service or facility (15%), ‘I don’t know where to get it recycled’ (14%) and ‘I don’t have time or it is inconvenient’ (13%)
• When asked about reasons for not repairing clothing and textiles, the most frequently cited reasons were ‘repair costs more than buying new’ (30%), ‘I don’t know how to repair it’ (18%), I don’t have time or it is inconvenient’ (16%) and I don’t know where to get it repaired or no local services’ (14%)

Consumer Views on food waste

On food, our polling research asked respondents about reasons for not recycling food waste. The most frequently cited reasons were:[21]

• ‘No suitable local service or facility’ (15%). This was higher for those in rural areas (18%)
• ‘I don’t have time or it’s inconvenient’ (12%)
• ‘I don’t know how to recycle it’ (8%). This was higher in younger age groups (14% of age 18-24 and 20% of age 25-34)

The role of environmental charges and incentives

There are specific policy measures which could be put in place to help focus on reducing consumption of problematic items such as single use plastics, or improving recycling of reusable items.  Measures under consideration include the introduction of a deposit return scheme for plastic bottles and cans and the implementation of a charge for single use cups.

When asked how they would respond to a deposit return scheme with a deposit of 20p, our research found that 66% of consumers in Scotland would frequently return their container to redeem their deposit. 38% stated they would always do so.

Consumer Scotland’s data shows that engagement with any such scheme would likely be higher when returning containers was convenient and could be easily integrated into people’s daily lives. Factors that would increase the likelihood of consumer engagement would include:[22]

• Close proximity to a return point – 85% reported that they would be likely to return containers if the return point was within a five minute walk (including 65% who stated they would be very likely to return containers). When asked about a return point within a 15 minute walk this drops to 61% (including 29% who stated they would be very likely to return containers.
• Convenience of returning containers – 84% reported that they would be likely to return containers if they could return them as part of a usual shopping trip (including 62% who stated they would be very likely to return containers)
• High volume of containers to return – 76% reported that they would be likely to return containers if they had more than 10 containers to return (including 50% who stated they would be very likely to return containers)

Factors that would be likely to discourage participation are:[23]

• Long waits, with 44% consumers reporting that they would be unlikely to return containers if they had to wait around 10 minutes at the return point (including 20% who stated they would be very unlikely to return containers).
• Inconvenient opening hours, with 27% stating that they would be unlikely to return containers if the return point was open only during 9am-5pm (including 12% who stated they would be very unlikely to return)

When asked about engagement with a potential 25p charge on single use drinks cups, 47% of respondents to our recent polling stated that they would frequently bring their own cup, including 16% who stated that they would always bring a reusable cup.[24] When asked about changes to purchasing behaviour if a charge was introduced, most respondents (29%) said they would not change their purchasing frequency, 20% of respondents stated that they would buy fewer drinks in takeaway cups and 13% stated that they would stop buying drinks in takeaway cups. Those aged 18-24 (19%) and those with a condition or illnesses that reduces their ability to carry out day-to-day activities a lot (19% were most likely to say that they would stop buying drinks in takeaway cups.

Strengthening the current plan

Our recent polling shows a need for further action to make recycling and repairing textiles more convenient and accessible for consumers across Scotland. This should include facilities for textiles and food recycling which take into account the needs of consumers in vulnerable circumstances and those living in remote and rural areas.

Action will also need to be taken to improve consumer awareness of repair and reuse options, along with work to remove barriers to uptake by addressing consumer concerns around safety, hygiene or quality of repaired goods.

Measures to make repair a more viable option for consumers, and to boost awareness of this, should also be prioritised by the final Climate Change Plan. We recognise that some of these measures have been recently consulted on and recommend that the final Plan contains a time bound delivery plan for implementation. The Plan should also address the need for targeted business development to encourage greater number of repair businesses across Scotland.

We welcome the work being undertaken with Zero Waste Scotland to develop measures to improve the reuse experience for consumers, and support alternative business models so that leasing, repair and refurbishment, and reuse of products is easier and more attractive for businesses. The final Climate Change Plan should contain further details on this, including detail on the targeted support available to businesses and the associated timescales.

Proposals to tackle the environmental impacts of single-use drinks cups may help consumers to understand the impact of product choices and allow them to make purchasing decisions which align with their sustainability preferences. Successful implementation will require that the impact on consumers in vulnerable circumstances is fully considered, so that those who are least able to pay are not disproportionately impacted. It is also important to acknowledge that introducing environmental charges is only one part of the solution. Facilitating greater consumer awareness and reduction in consumption through sustained behaviour change campaigns and continued engagement with manufacturers to develop more sustainable products will also be crucial.

Recycling plays an important role in helping to conserve natural resources, keep valuable materials flowing through the economy, and reduce the amount of waste sent to landfill and incineration. While we welcome action to improve the effectiveness of current systems and the proposal to introduce deposit return facilities, it is important to ensure that focus remains on action that results in as small an amount of material as possible reaching the recycling stage.

Energy Supply

Question 11 - What are your views on Scotland generating more electricity from renewable sources?

Scotland is a large net exporter of energy – over a third of the electricity generated here in 2024 was exported.[25] There are clear opportunities to exploit Scotland’s renewable energy resources, most notably of wind and hydro or pumped storage.  However, a significant expansion of generation capacity also presents challenges for the energy system. Significant investment is required in networks to ensure that sources of energy generation are connected to demand. The best sites for wind and hydro generation are not in the same place as older forms of generation like coal and gas. To date network investment has not kept pace with changes in locational changes of this type. The grid is often not capable of handling the power output from some of the largest Scottish windfarms – they are “constrained off” – and collectively consumers pay for them to not export. More grid is needed, but joined up thinking is also required to ensure new generation is, as far as possible, in the locations where it is most needed.

For Scotland this means making sure there is clear alignment between key stakeholders in relation to onshore and offshore generation build,  including Crown Estate Scotland and Forestry and Land Scotland and the National Energy System Operator (NESO). NESO are tasked with developing a Strategic Spatial Energy Plan, which will map out the future development of the grid and to a large degree dictate where new generation should be sited. If successful it will ensure that the system is designed in an efficient way. It will only be effective in doing so if there is collaboration between key stakeholders. Scottish Government can play a key role in helping to bring this about, and to ensure that all parties are ready to make choices in the wider interests.

A further way that the Scottish Government can support greater exploitation of our renewable energy potential is to ensure that the planning and consenting arrangements for development of both network and generation are as efficient as possible. Many of the most suitable sites for pumped storage generation are likely to be in sensitive environmental areas. And offshore wind developments can have an impact on marine and bird life. Clearly, steps should be taken to protect the natural environment. However, delays in relevant approvals add costs which are ultimately borne by consumers. A collaborative and constructive approach to development to ensure that generation and network facilities designated within NESO’s Strategic Spatial Energy Plan can be approved in an expedited manner may be appropriate.

It will also be important to maintain consumer support for Scotland’s Net Zero goals. Consumer Scotland data shows that there is still strong support for action to tackle climate change. For this to remain the case consumers need to see how planned actions  benefit them. All else being equal, it is likely that there will be significant increases in energy bills between now and the early 2030s as a result of investment in network and renewable generation.[26] Many households in Scotland are already struggling to meet their energy needs. 33% can’t heat their home to a comfortable standard because of affordability concerns. 16% of households find it difficult to keep up with their bills. And 15% are in debt or arrears.[27] For these households, and those that are just about managing right now, further bill increases will not be welcome.

The existing financial supports, primarily the Warm Home Discount and the Pension Age Winter Heating Payment, need to be targeted better. These supports are currently cliff-edge and don’t link energy demand and financial need. This is a particular problem for those households with unavoidably high energy use – including the terminally ill and those with at-home medical equipment.

To improve the supports currently in place, or to replace them with alternatives such as a social tariff, there is a need for effective linking of government- and industry-held data. Scottish Government and particularly Social Security Scotland have a key role to play in ensuring the data is available to enable those households most in need of support to be identified and reached. We consider this should be taken forward as a priority.

Question 16 - Which groups or communities do you think will be most affected by the transition to net zero, and in what ways?

Consumers will experience the transition to net zero in different ways depending on their individual circumstances:

• Those on lower incomes may face greater barriers to engage in measures with higher initial and potentially ongoing costs, such as changes to home heating and vehicles
• Those living in remote or rural areas may face greater barriers accessing infrastructure such as recycling and repair and electric vehicle charging
• Disabled consumers may face additional barriers engaging with measures such as active and sustainable transport or deposit return schemes

As noted earlier in this response, cost, convenience, clarity, and confidence are the key issues for consumers participating in the transition to a more sustainable future.

The final Climate Change Plan must:

• Ensure that the costs of adopting policies are distributed fairly, considering both overall costs and also their type and timing. Policies must address the impact on consumers, particularly those on low incomes or in vulnerable circumstances through robust impact assessments and modelling of the individual and cumulative impact of measures
• Support sustainable products and services being designed in ways that fit easily into consumers lives, facilitating the creation of policies, products and services that are convenient and understandable for those using them
• Ensure that policies contain mechanisms for consumer advice, protection and redress

On waste, it will be important to consider the cost and availability of goods for consumers in vulnerable circumstances, including those on low incomes. By promoting and encouraging greater uptake of reuse and repair, policies may lower household costs through access to affordable second-hand goods, for example, through better access to reuse hubs and community repair schemes. However, it is important to acknowledge that better quality, longer lasting products are likely to have an initial cost, and that support may be needed for some consumers.

Question 17 - How do you think the Climate Change Plan aligns with existing local, regional, or national priorities that you are aware of or involved in? 

We welcome the acknowledgement within Adaptation: Delivering a Climate-Resilient Future of the need to improve water retention in the environment. While we recognise that water is not a prescribed topic area within the Climate Change (Scotland) Act 2009, water is fundamental to life, public health, and economic activity. A critical issue not fully reflected in the Climate Change Plan is that achieving key objectives—such as safeguarding public health, supporting business and the economy, and protecting the environment—depends on the availability of water.

Climate Change and Water Availability

Climate change is already influencing Scotland’s weather patterns. Increasingly frequent and widespread periods of insufficient rainfall are causing water shortages. Notably, some reservoir levels remain below normal in December 2025 despite recent heavy rainfall[28]. This situation heightens vulnerability for communities and businesses, as low rainfall and inadequate replenishment threaten supplies for drinking water and commercial use.

At the same time, demand for drinking water is rising due to the growth of water-intensive industries, such as data centres requiring cooling and the development of hydrogen as a fuel, which consumes significant volumes of water.

Current Gaps and Future Risks

Scotland currently lacks a comprehensive water resource plan—a standard feature elsewhere in the UK. A Water Resource Planning Ministerial Roundtable in 2024 recognised that climate change will place increasing pressure on Scotland’s water resources over the coming decades. Recent summers have seen more frequent water scarcity alerts issued by the Scottish Environment Protection Agency (SEPA). The last SEPA water scarcity report on 30 October 2025 showed that some river levels remained at Alert or Early Warning. Without proactive adaptation and improved water resource management, Scotland could face a daily water deficit of 240 million litres by 2050. This challenge will be compounded by population growth, particularly in eastern regions where renewable water resources may be more limited.

Consumer Awareness and Behavioural Change

Previous research by Consumer Scotland examined the extent to which consumers understand climate change impacts on water and wastewater services. Our findings showed that consumers know little or nothing about these impacts but were alarmed by the scale of the challenges once they were sensitised to them. There is clear support amongst consumers for collaborative action by the Scottish Government, Scottish Water, businesses, local authorities, and communities to tackle these impacts in a way that enables all consumers to adapt.

Domestic consumers and businesses have an important role in supporting improved water resource management. This will require significant awareness raising and effective engagement to enable behavioural change, with consumers using only what is needed and reducing waste. Water usage per person in Scotland is currently 180 litres per day, which is high compared to England (140 litres per day) and well above England’s target of 122 litres by 2038. Reducing water usage in Scotland should be seen as an integral measure within the wider transition to climate adaptation, alongside decarbonising homes and transport and reducing waste.

Recommendations for inclusion of water

We recommend that the final Climate Change Plan sets out stronger, clearer, and more joined-up thinking on the need to promote and protect water in Scotland to ensure sufficient supply for society, industry, agriculture, and the environment. Specifically, we recommend:

1.    Inclusion of Water Resource Planning within the CCP to address future water scarcity risks.

2.    Development of a National Water Resource Plan to ensure resilience and sustainability.

3.    Integration of Water Efficiency Targets for domestic and business use, aligned with best practice in other UK nations.

4.    Public Awareness Campaigns to drive behavioural change and reduce per capita water consumption.

5.    Cross-sector Collaboration to manage competing demands from industry, agriculture, and communities.

On waste, it will be important for the final Climate Change plan to link clearly with the final Circular Economy Strategy, Circular Economy and Waste Routemap, Environment Strategy and the upcoming Product Stewardship Plan and sector roadmaps. It will be vital to provide consumers and businesses with clarity required about the actions that should take and the targeted support that will be available to enable them to make these changes.

Question 18 - If you identified there could be negative impacts of the Climate Change Plan, are there any ways you think we could reduce that negative impact and if so, what would you recommend?

The Scottish Government should specifically identify and address the impact of policies on consumers who may find it difficult to take up measures such as those living in rural areas, on lower incomes or disabled consumers, as detailed in question 16.

The Scottish Government should undertake robust modelling and analysis of the impact of the measures included in the final Climate Change Plan on consumers. This is especially necessary where high volumes of consumers must undergo a process of change in a short timeframe and where these changes will have substantial costs, such as in relation to travel choices or the purchase of consumer goods. This modelling and analysis should pay particular attention to the needs of consumers in vulnerable circumstances or on low incomes. Impact assessments on measures in the final Plan should take into account both the individual and cumulative impact on consumers, including those in vulnerable circumstances.

As of April 2024, the consumer assessment section of the Business and Regulatory Impact Assessment has been replaced by the Consumer Duty. This places a duty on relevant public authorities in Scotland, including the Scottish Government, to improve the extent to which consumers are considered in strategic decision-making. A key principle of the Duty will be to ensure all public bodies are working towards improving outcomes for consumers as part of their strategic decision making process. The final Climate Change Plan must fully consider the strategic impact of measures. 

Question 19 - Please share any other quantitative data, or sources of this, to assist in developing the impact assessments:

Consumer Scotland (2024) Consumer perceptions of and engagement with the transition to net zero. 

Consumer Scotland (2026) Upcoming polling (currently unpublished)

Question 26 - What are your views on the proposed approach to reporting annual emissions output and how this could support public understanding of Scotland’s progress towards achieving our Carbon Budgets?

In order to ensure transparency and accountability, the final Plan must provide a robust framework to monitor emissions reductions alongside capturing the wider co-benefits of action. The final Plan should clearly identify the timescale for implementation of each policy and for the anticipated emissions reductions that will result from policy.

We agree with the Climate Change Committee that to enable effective scrutiny and to support collaborative efforts between the Scottish Government, businesses, and the public, the Scottish Government should be transparent in monitoring and evaluation.[29]