Scottish Government consultation on the draft Circular Economy Strategy

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, information and sustainability as being particularly relevant to the consultation proposal that we are responding to.

Question 1. To what extent do you agree with the vision and outcomes for the strategy? [Strongly agree / Agree / Neither agree nor disagree / Disagree / Strongly disagree / Not answered]

Agree

Question 2. Do you have any comments on the vision?

We welcome the opportunity to respond to the draft Circular Economy Strategy. A clear and robust strategy can play a central role in the transition to a circular economy and support the achievement of net zero targets. Scotland's per capita material footprint is nearly double the global average and around four-fifths (82%) of Scotland’s carbon footprint comes from the products and services we manufacture, use, and throw away.[1] Increasing circularity could help to reduce emissions in Scotland by up to 43%.[2] Achieving this will require action at a number of levels, from Government, businesses, communities and individuals. Enabling individual consumers to make more sustainable choices and to understand which of their actions can have the most impact will be critical.

A systemic approach is needed to underpin fair and effective consumer engagement in the transition to a circular economy. Governments need to create an enabling environment where it is easier for consumers to make the changes which are being asked of them.

A review of key evidence, including Consumer Scotland’s growing evidence base, has identified Cost, Convenience, Clarity, and Confidence (the 4 Cs) as key issues when considering the role of consumers in the transition to a more sustainable future.[3] For the final Strategy to be a success, it must address these issues, making it as straightforward as possible for consumers to understand their role and take the necessary actions to support the transition to a circular economy.

For each of these four key consumer issues, Consumer Scotland has identified a set of key questions, or tests, that can be used to ensure that Scotland’s climate change mitigation and adaptation policy, regulation, and practice is consumer focused. By asking and addressing these key questions, or tests, policymakers, regulators, businesses, and other key decision-makers can take the actions that are required to place consumers’ priorities at the centre of the transition to a sustainable and resilient future. We recommend that the Scottish Government uses the Consumer Scotland toolkit to assess the consumer impact of policy measures in the Circular Economy strategy against the key consumer issues of cost, convenience, clarity and confidence.

We welcome the draft vision and the focus on Scotland having a thriving economy that meets societal needs, based on circular economy principles. Enabling consumers in Scotland to take action higher up the waste hierarchy, by tackling overconsumption, reducing use of raw materials and resources and promoting sustainable choices will be crucial to achieving the vision. However, we consider that the Strategy should provide more clarity for consumers through:

• • Setting a clearer and more explicit focus in the Vision on the need for an enabling environment. The current version of the Vision sets the goal of people, businesses and the public sector having the knowledge and skills they need to benefit from opportunities arising from a circular economy. While we agree that this is vital, other factors, beyond skills and knowledge will also be central to determining whether consumers are able to contribute to achieving the Vision. These factors include affordability and accessibility of opportunities and we recommend that the Vision recognises the importance of these being effectively addressed.
  • More explicit acknowledgement of the co-benefits that will come from the transition to a circular economy. Consumers have a range of motivators for taking action, with environmental factors often a secondary motivator.[4] A clear focus on these co-benefits in the vision will help to ensure the effective communication of these in measures to achieve a more circular economy.

Question 3. Do you have any comments on the outcomes?

We welcome the proposed outcomes and the four themes of social, economy, international and environment that frame them. It will be necessary to have a clear and robust delivery plan for achieving these outcomes, including clear timescales, to facilitate consumer and business clarity and confidence. We have set out below our views on how the approach to some of the outcomes might be improved.

Social

We welcome the ambition for the circular economy to be fair, inclusive and built on just transition principles, but we would suggest that targeted support for people will be needed to help address the key consumer issues of cost, convenience, clarity, and confidence.

The outcomes seek to capture the need for behaviour change across business, the public sector, charities, communities and householders. We support this ambition, however, it will be necessary to create a robust enabling environment to allow consumers, including those in vulnerable circumstances, to make the changes that are being asked of them. We know from existing research that in practice this will mean more than simply providing information about the need to change behaviour and instead providing targeted support as part of an enabling environment. This support may include targeted, specific advice or financial support for consumers.

We support the idea that ‘circular behaviours should be the norm across business and society’ and note the importance of mainstreaming these behaviours. A 2024 survey conducted by YouGov on behalf of Consumer Scotland found that, although many consumers express concern about climate change, this is not resulting in action that meets the pace and scale of the change that is required.[5] While more than half (52%) of respondents stated that they are very or somewhat likely to change their purchasing behaviour in the next year as a result of environmental concerns, only 10% of respondents stated they were very likely to do so. This further emphasises the need to improve cost, convenience, clarity and confidence to help consumers make the changes that are being asked of them. Examples of actions which could support consumer behaviour change include discounts or changes to increase the use of reusable cups, changes to household recycling to facilitate higher levels of textiles recycling and improved product labelling to facilitate greater consumer understanding of disposing of packaging.

We welcome the outcome ‘people and communities engage in and benefit from circular activities in a fair and inclusive way’. It is important that the transition to a circular economy is a just one. Consumers in vulnerable circumstances must not be disproportionately impacted by circular economy measures. Consideration should also be given to balancing the needs of both current and future consumers and addressing the question of what the fairest allocation and timings of costs should be, ensuring that future consumers are not disproportionately disadvantaged by unnecessary delay to taking action.

Recent polling conducted by IFF for Consumer Scotland shows that there is more that needs to be done to support consumers to move their actions further up the waste hierarchy and that clothing/textiles should be a priority, with a significant proportion of respondents in our research stating that they throw away clothes and textiles:

• • For textiles, 26% state that they frequently throw away clothing with significant damage and 12% frequently throw away clothing with minor damage
  • For small electricals, 16% state that they frequently throw away small electrical items with significant damage and 9% frequently throw away small electrical items with minor damage.[6]

We would welcome further details of measures to make it easier for consumers to help achieve a circular economy for textiles in the final Strategy and the upcoming textiles roadmap.

Our research found that item condition plays a strong role in consumer willingness to repair items. We asked respondents about the frequency of repairing, recycling and throwing away clothing and electrical items.:[7]

• • 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.

Economy

We welcome the ambition to have a circular economy that drives innovation, investment, and the creation of new business models and jobs and for the economy to be both sustainable and beneficial to people, communities and the environment. We welcome the outcomes ‘business and entrepreneurs have opportunities to develop circular economy innovations’ and note the importance of ensuring that businesses are well supported. We welcome the ambition to help circular businesses grow and note the benefits that this can have to both current and future consumers, such as greater availability of local services, more options for second hand and repaired goods and lower prices.

More needs to be done to mainstream repair and reuse businesses to give both consumers and businesses the confidence that circular economy models can be robust business models. Supporting these businesses to provide consumers with a service that is accessible, reliable and good value for money will be vital to transitioning to a circular economy. These businesses must be able to deliver excellent standards of service to consumers, including clear information about products and services and a swift and effective complaints procedure for where things go wrong, if they are to compete with more traditional linear business models. In line with the consumer principle of choice, it will be important for consumers to have a choice between different providers in order to encourage a competitive market.

Policy mechanisms

Question 4. To what extent do you agree with the policy mechanisms identified? [Strongly agree / Agree / Neither agree nor disagree / Disagree / Strongly disagree / Not answered]

Agree

Question 5. Do you have any comments on the policy mechanisms identified?

We welcome the identified policy mechanisms and agree that a successful circular economy will require action across multiple policy areas to deliver systemic changes to how we produce, use and consume goods and materials.

We welcome the inclusion of behaviour change as a policy mechanism. However, as highlighted above, this should not simply rely on the one-way provision of information. It will also require targeted support such as financial support or specific and tailored advice and action to address the barriers and motivators for consumers, including those in vulnerable circumstances. This will rely on policy mechanisms being appropriately impact assessed, using tools such as the Business and Regulatory Impact Assessment (BRIA), the Consumer Duty, the Fairer Scotland assessment or our Consumer Framework to identify impacts on consumers, and barriers to action.

We welcome the recognition that a more circular economy cannot be achieved through isolated activities, and that a systems-based approach is required. We support measures to ensure policy alignment and recommend that the Scottish Government considers whether circular economy measures, and how well these deliver for consumers, can be incorporated into the National Performance Framework, in order to encourage this alignment. As noted in our response to question three, more needs to be done to mainstream repair and reuse businesses to give both consumers and businesses the confidence that circular economy models can be robust business models. These businesses must be able to deliver affordable, reliable and high quality services to consumers, including clear information about products and services and a swift and effective complaints procedure for where things go wrong, if they are to compete with more traditional linear business models.

Question 6. Do you have any comments on the associated plans and priorities?

Business support

We welcome the priority to support businesses to increase circular practices and business models. The upcoming Zero Waste Scotland Business Information Hub will provide businesses with useful information and guidance. However, these and other measures must also provide businesses with the necessary support and sufficiently tailored advice. More needs to be done to mainstream repair and reuse business models, both to provide the support and confidence for businesses to operate in this area, and also to facilitate consumer confidence in using these services.

The Scottish Government should consider providing targeted support such as financial support and specific advice and guidance to small businesses as a way to mitigate against any additional costs being passed on to consumers as a result of transitioning to a more circular business model.

Behaviour change

We welcome the priority to empower consumers and organisations to adopt circular behaviours. The consultation paper references research by Consumer Scotland which shows that many people want to reduce the carbon impact of the products that they buy, but can struggle to move beyond low-impact changes.[8] We welcome the acknowledgement that in order to adopt circular actions, people must have the capability, opportunity and motivation to act. We recommend that the Scottish Government uses the previously discussed Consumer Scotland toolkit to assess the consumer impact of policy measures in the Strategy against the key consumer issues of cost, convenience, clarity and confidence.

Place-based approach

We welcome the prioritisation of a place-based approach to the circular economy, recognising that the circumstances of consumers in Scotland differ from place to place, and may require local solutions. Acknowledging the impact of the differing challenges faced by different areas and the implications of differing levels of rurality in transitioning to a circular economy will be vital for securing a just transition, which delivers for consumers across Scotland.

Skills and education

Recent polling by Consumer Scotland found that cost is the biggest barrier to consumers when considering repairing items. [9] 30% of respondents selected ‘repairing costs more than buying new’ for clothing and textiles and 36% for small electrical items. Other commonly selected options were ‘I don’t know how to repair it’ (18% for clothing and textiles and 23% for small electrical items) and ‘I don’t have time or it’s inconvenient’ (16% for clothing and textiles and 12% for small electrical items).  

We welcome the priority to increase uptake of circular practices through improved skills and education and the acknowledgement that skills and education are vital to increasing the uptake of circular practices. We welcome the commitment to work with stakeholders to ensure circular skills are embedded within the programme of reform for our education and skills system.

While the draft Strategy does acknowledge the need for behaviour change, more needs to be done to support consumers to move their actions further up the waste hierarchy. The final Strategy and upcoming textiles roadmap must include a more in depth focus on the barriers to consumer behaviour change than is contained in the draft strategy and propose clear action to address these barriers.

Priority sectors

Question 7. To what extent do you agree with the priority sectors identified?

Agree

Question 8. Do you have any comments on the priority sectors identified?

While we welcome the development of roadmaps within the priority sectors within a year of publication of the final strategy, we urge the Scottish Government to provide as much detail as possible in the final Circular Economy Strategy to avoid unnecessary delay in action and funding of commitments. Consumers and businesses must be given clarity and confidence about what they will need to do. For these roadmaps to be impactful and support the delivery of the volume and speed of change that is required, they should contain clearly identified measures, complete with detail on sequencing and timings.

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 in these areas.[10] The Tool also identified food waste as the largest contributor to biodiversity loss and textiles and food as amongst the most significant contributors to air pollution and water use impacts.[11]

We would welcome the opportunity to contribute to the development of the roadmaps for textiles and food to support the inclusion of the consumer perspective, particularly ensuring that the key consumer issues of cost, convenience, confidence and clarity are adequately addressed in the roadmaps.

Question 8a. Do you have any comments on the plans and priorities for the built environment?

No response

Question 8b. Do you have any comments on the plans and priorities for the Net Zero Energy Infrastructure?

No response

Question 8c. Do you have any comments on the plans and priorities for textiles?

Given the significant environmental impact of the textiles sector, we welcome the inclusion of this as one of the priority sectors, which will also feature in the product stewardship section. A recent report by Zero Waste Scotland has found that although textiles make up only 3.5% of household waste by weight, they account for 19.4% of climate change impacts from household waste in Scotland.[12]

We welcome the planned work with the sector to develop a roadmap to build an economic system that is designed for reuse and repair and enables industry to identify mechanisms for growth without environmental, social or economic harm. It will be important for this roadmap to fully consider the consumer perspective, including addressing how cost, convenience, clarity and confidence affect consumer decision making in this sector. Action in this sector should focus on effectively tackling the range of barriers that exist to consumer participation. These include:

• • concern about cleanliness and hygiene, particularly in relation to second-hand clothing,
  • the availability of accessible repair services and
  • the financial feasibility of repairs.[13]

Previous research carried out on behalf of Consumer Scotland in 2024 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%). [14]

This illustrates that there remains considerable scope for more action to support consumers to move behaviours relating to textiles further up the waste hierarchy. This should involve a greater focus on measures that make it easier consumers to reuse and repair, such as increasing access to repair services, improving consumer awareness of these services and work to mainstream reuse businesses that deliver good consumer outcomes.

We welcome the intention to support sustainable alternatives to fast fashion and the continued commitment to support work by Zero Waste Scotland to raise awareness about the environmental impact of textile waste, and to encourage and promote textile repair. Awareness raising and provision of information alone will not be enough, and more needs to be done to create an enabling environment where consumers feel able to confidently participate in the repair market, and for this to be a default choice.

Question 8d. Do you have any comments on the plans and priorities for the transport?

No response

Question 8e. Do you have any comments on the plans and priorities for the food system?

We note the importance of tackling food waste, given the high carbon footprint associated with it. Zero Waste Scotland have estimated that around one million tonnes of food is thrown away every year in Scotland, equating to 4.74 million tonnes of CO2.[15] We welcome the intention to develop an intervention plan to guide long-term work on household food waste reduction behaviour and to explore improvements to food waste collection systems.

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, while also ensuring fairness for consumers across Scotland.

Product stewardship

Question 9. Do you have any comments on the proposed approach to product stewardship?

We welcome the intention to adopt an evidence-based prioritisation approach to product stewardship. This approach will be used to identify additional priority products over the next five years.

The Product Stewardship Plan should be published as soon as possible, and it should include detail that will provide consumers and businesses with clarity about proposed actions and policy measures, together with the timing and sequencing of these. It will be important that the issues that matter to consumers – such as convenience, choice and cost – play a central role in assessing the evidence for determining future priority products.

Circular Economy Monitoring and Indicator Framework

Question 10. Are there any changes or additions that you would like to suggest in relation to the Circular Economy Monitoring and Indicator Framework to ensure it is fit for purpose?

Overall, the framework is credible, well-aligned with international approaches, and appropriately ambitious. We welcome the clarity in Section 6 of the draft strategy, particularly the recognition that the Circular Economy Monitoring and Indicator Framework is intended as a starting point, with further development and target-setting to follow. That said, while this intent is clear in the narrative, it is not always sufficiently explicit in how the indicators are presented, which creates a risk of misinterpretation by non-technical audiences. This is not a weakness of the indicators themselves, but it does highlight the need for clearer signalling of their intended use.

The framework would therefore benefit from explicitly distinguishing between:

• • indicators that may be suitable for future target-setting,
  • indicators intended for monitoring and evaluation, and
  • indicators included primarily for contextual insight

Greater clarity of this distinction would help avoid inappropriate use of certain indicators for accountability, particularly where changes cannot reasonably be attributed to Scottish Government policy in the short term. For example, short-term changes in Circular Material use Rate can be driven by fluctuations in overall material demands rather than improvements in recycling or reuse.

Question 10a. Question 10a: Do you have any comments in relation to the indicators proposed for outcome “The economic value derived from material use is maximised without increasing our environmental impacts”?

No response

Question 10b. Do you have any comments in relation to the indicators proposed for outcome “The Scottish economy is more resilient to disruptions in global supply of materials, including critical raw materials”?

No response

Question 10c. Do you have any comments in relation to the indicators proposed for outcome “Business and entrepreneurs have opportunities to develop circular economy innovations”?

We welcome the indicators for the outcome businesses and entrepreneurs have opportunities to develop circular economy innovations. On ‘number of circular economy patents’, we welcome the proposed innovations in areas such as resource efficiency, waste reduction and recycling, re-use and repair models, and the development of sustainable materials/secondary raw materials or processes.

On ‘number of circular startups’, we the support the inclusion of startups focused on practices including waste reduction, resource efficiency and product life extension as well as recycling. Having this focus on activities further up the waste hierarchy will help to give businesses the confidence to operate in these areas and support consumers to engage in these markets. It will be important for circular start ups to deliver effectively for consumers and we would welcome the addition of a measure that would capture this.  

Question 10d. Do you have any comments in relation to the indicators proposed for outcome “Non-renewable resource extraction is minimised and renewable resource use is sustainable”?

No response

Question 10e. Do you have any comments in relation to the indicators proposed for outcome “The negative environmental impact of our production, consumption and disposal is minimised”?

No response

Question 10f. Do you have any comments in relation to the indicators proposed for outcome “The negative impacts experienced internationally from production, consumption and disposal are reduced”?

No response

Question 10g. Do you have any comments in relation to the indicators proposed for outcome “People and communities engage in and benefit from circular activities in a fair and inclusive way”?

We welcome the inclusion of the indicator ‘population with access to circularity options’ which will measure the proportion of the population that has reasonable access to reuse, repair and sharing services. It will be vital to have a clear definition of ‘reasonable access’ and note the importance of ensuring that the needs of those living in remote and rural areas and those in vulnerable circumstances are taken into account when defining this. We would be happy to work with the Scottish Government and other stakeholders to support the development of this definition.

Question 10h. Do you have any comments in relation to the indicators proposed for outcome “Circular behaviours are the norm across business and society”?

We welcome the inclusion of an indicator on societal behaviours for a circular economy. This will aim to measure public understanding and attitudes toward the circular economy and uptake of circular behaviours in society. We note that this indicator is currently under development and we would welcome a focus on consumption and purchasing behaviours and re-use, repair and recycling behaviours.

It is important to acknowledge the attitude-behaviour gap and ensure that any indicator is designed in a way which will measure actual consumer behaviour and not rely on stated attitude alone. The Scottish Government should utilise a behaviour change model to inform the development of a suitable indicator.

Consumer Scotland research

Research conducted on behalf of Consumer Scotland in 2024 found that 80% of respondents would like to reduce the carbon emissions from the household items that they buy.[16] When those who agreed with this statement were asked about why they are not currently taking more action, the most frequent reasons were:

• • The cost of products with lower environmental impact
  • Lack of choice of products with lower environmental impact, and
  • Lack of clear labelling on the environmental impact of products.[17]

Our research found that consumers are open to circular economy measures, but they require more action from businesses, government and regulators, to enable them to move beyond lower impact changes such as recycling. There is some consumer support for measures relating to reducing consumption, buying second hand, or increasing repair and re-use.

We asked respondents if they had engaged in the following behaviours in the prior year: repairing goods when they were worn or broken, buying second hand rather than new goods, and leasing and borrowing products rather than buying. Of these behaviours:

• • repairing goods when they were broken is the most common action that consumers report having taken, with three in four (76%) saying they have done this in the last year. Just over half (52%) say that environmental concerns were a factor in their decision to do this, including one in five (19%) saying this was the main reason for repairing goods when they were broken.[18]
  • Around two-thirds (68%) of consumers in Scotland reported having purchased second hand rather than new goods in the past year. Almost half (49%) stated that environmental concerns were a factor in their decision to do this, including 17% stating that environmental concerns were the main reason for buying second hand rather than new goods.[19]
  • Leasing and borrowing products rather than buying is less common, with just over a third (35%) reporting having done this in the past year. Just over one in five (22%) stated that environmental concerns were a reason for doing this, including just under one in 10 (9%) stating that environmental reasons were the main reason for leasing and borrowing products rather than buying.[20]

Our research found broad consumer support for a range of circular economy measures. Respondents were asked to what extent they agreed with the following statements:

• • ‘Products should be made so that they are easy to repair and their components can be re-used, even if this impacts product quality’ (74% agreed including 39% who strongly agreed)
  • ‘Products which can't be repaired or recycled should be banned’ (40% agreed including 11% who strongly agreed)
  • ‘Products which can't be repaired or recycled should be taxed more than those that can be, even if this increases their cost’ (49% agreed including 18% who strongly agreed)
  • ‘Companies that sell products should be responsible for taking them back for recycling or disposal at end of product life, even if the consumer is responsible for sending the product back to them’ (70% agreed including 30% who strongly agreed)[21]

We welcome the proposed indicator measuring household spending on product repair, maintenance and re-use services and the intention to create a parallel indicator on reuse service transactions, including spending on second hand goods. This will provide valuable insight on changing levels of consumer engagement with repair and reuse services. It is important that these services are affordable for consumers, and while we recognise the value of increasing consumer spending on repair, maintenance and re-use services, it is vital that this is done in a way that delivers good value for money for consumers, and a positive customer experience.

We also welcome the inclusion of the business behaviours indicator for a circular economy which aims to measure how businesses adopt circular practices. We note that this indicator is currently under development but we would welcome a focus on investment in circular economy activities, adoption of circular business models, circular economy training interventions and on how businesses ensure that their circular practices deliver affordable, accessible, good quality services for consumers.

Impact assessments

Question 11. Please provide any further information or evidence that should be considered in the accompanying Equalities Impact Assessment.

The Equalities Impact Assessment states that the publication of the Strategy itself will not directly impact people or communities. However, as individual interventions related to the Strategy priorities are developed and implemented, these will potentially affect everyone in Scotland. The development process for these measures, including those in the upcoming roadmaps, must identify and mitigate potential detriment being caused to consumers, or certain groups of consumers such as those in vulnerable circumstances, including those on low incomes.

The Scottish Government should undertake robust modelling and analysis of the impact of these measures on consumers. This will be especially necessary where high volumes of consumers must undergo a process of change in a short timeframe and where these changes will have associated costs.

This modelling and analysis should pay particular attention to the needs of consumers in vulnerable circumstances or on low incomes. The impact on consumers should be considered for individual measures, however it is important that impact assessments also take into account the cumulative impact of multiple circular economy measures on consumers.

Question 12. Please provide any further information or evidence that should be considered in the accompanying Fairer Scotland Assessment.

No response

Question 13. Please provide any further information or evidence that should be considered in the accompanying Island Communities Impact Assessment.

We note from the Island Communities Impact Assessment that the nature of the Strategy means that it will not have a direct impact on islands communities. We acknowledge that this Impact Assessment does not offer full insight into potential issues that will come from the development of interventions linked to the priorities set out in the Strategy and instead identifies and considers broader issues.

It will be important for these issues are fully explored and considered prior to development and implementation of individual interventions that come from the final Strategy and upcoming roadmaps.

Question 14. Please provide any further information or evidence that should be considered in the accompanying Business and Regulatory Impact Assessment.

No response

Question 15. Please provide any further information or evidence that should be considered in the accompanying Consumer Duty Impact Assessment.

The Consumer Duty represents a significant opportunity to improve outcomes for consumers in Scotland, by requiring public bodies to consider consumer interests when they take strategic decisions.

We agree with the identified impacts and harms identified in the Consumer Duty Impact Assessment and note that it will be important for the impact of subsequent measures on consumers in vulnerable circumstances to be fully considered.

Question 16. Please provide any further information or evidence that should be considered in the Child Rights and Wellbeing Impact Assessment

No response

Strategic Environmental Assessment (SEA)

Question 17 Do you have any views on whether there are likely to be any positive or negative environmental impacts from the draft Environment Strategy that have not been identified in the Strategic Environmental Assessment?

We welcome the priority areas set out in the Strategy, particularly textiles and food, as a result of the significant impact of their waste streams. 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.[22]

There are a wide range of co-benefits that may come from measures in the final Strategy or subsequent roadmaps, including reducing biodiversity impacts associated with resource extraction, pollution associated with production and consumption and improved air quality. We know that consumers are motivated by a wide range of factors and it will be important for the final Strategy and upcoming roadmaps to clearly communicate the range of co-benefits that can be achieved by transitioning to a circular economy.