Scottish Parliament scrutiny of the Scottish Government's draft Climate Change Plan

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.

Consumer principles

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

Electricity

Question 1: What are the most important policies needed to achieve the proposed carbon budgets level for 2026-40 in electricity? 

The energy system has changed markedly in recent years as increasing levels of renewably sourced electricity has been brought online. A key part of the reason for this has been support measures, most prominently the Contract for Difference (CfD) which provides revenue certainty to wind generators.  

However, the electricity network has not sufficiently expanded in parallel, leading to substantial increases in the level of balancing and constraint costs – these are expected to be around £4 billion in 2025 and could rise to £8 billion or more by 2030[1]. To continue reducing the carbon intensity of the energy system while maintaining affordability for consumers, and thus support for net zero goals, there is a need to ensure the network keeps pace with the energy transition. Ofgem have introduced the Accelerated Strategic Transmission Investment (ASTI) mechanism to ensure that certain critically important pieces of transmission network can be built ahead of need, enabling sources of renewable electricity to be connected to demand. This is a positive direction of travel that should continue over the coming years.  

It is also critical that other low or no carbon forms of generation are investible. The Nuclear Regulated Asset Base (RAB) and the Long Duration Energy Storage (LDES) cap and floor regime will help to support the deployment of both nuclear generation and long duration storage (primarily hydro pumped storage). Both of these technologies will play a key role in further decarbonising the energy system.  

 A specific area where Consumer Scotland identifies a particular need for further developments in future is in relation to flexible demand, both in the domestic and non-domestic space. As smart meters are rolled out and half-hourly settlement is introduced, there will be new opportunities to ensure that those consumers who can flex their demand to different periods of the day (avoiding the morning and evening peaks) can be rewarded for doing so. This will be of benefit to those customers directly, but also to the system as a whole – this is because, among other things, the need for new network build will be reduced.

However, for consumers to effectively engage with flexibility markets, they need confidence that they can make the right choice for them. Ofgem and the UK government should ensure there is a clear, robust, and future-proofed set of protections for consumers looking to flex their demand. The Scottish government has an important role in ensuring that consumers have access to the devices (such as EVs and heat pumps) that will maximise their potential to engage flexibly with the market. Without the right financial incentives and supports in place, many consumers may not otherwise be able to install the infrastructure they need to enable them to flex their demand.  

Question 2: When should these policies be introduced, and over what timeframe should they be implemented in electricity? 

Many of these policies are either already in place or are in the progress of being developed. Consumer Scotland would like to see meaningful progress towards developing a framework for demand flexibility from now.  

Question 3: What are the expected costs of implementing these policies in electricity? 

No response

Question 4: What are the expected benefits of these policies in electricity? Please include any wider benefits (e.g. environmental, equality, financial and health) you would expect. 

Achieving our net zero goals will not be cheap. Expanding the network and supporting the delivery of new generation plants will come at a significant cost, particularly at a time when other countries are seeking to decarbonise their own energy systems, creating supply chain pressures.  

At the same time, there are clear benefits to reducing our reliance on volatile international gas markets. The global gas crisis demonstrated how increases in the gas price can create pressure right through the energy system down to consumer bills.  

If Scotland can decarbonise its energy system while at the same time empowering consumers to take greater control of their energy use this will help to reduce bills, support our environment and better insulate consumers from external shocks.  

Question 5: What do you think the key challenges would be in delivering these policies in electricity? 

The primary challenge will be in ensuring that electricity, as an essential service, remains affordable for consumers as the network expands and investment in renewable sources of energy increases. As smart meters are rolled out and the pricing options presented to consumers become more sophisticated and complex, this presents opportunities to reduce the cost of operating the electricity system, both individually and at a collective level. However, to maximise the potential for this to happen, and for consumers to be able to effectively adapt their behaviour without harming their quality of life, will require them to be able to access devices such as EVs and heat pumps. Financial support to encourage take-up of such technologies is likely to be required for many consumers.  

Question 6: How could these policies support a Just Transition for workers and communities in electricity? 

Low carbon technologies such as EVs, heat pumps, solar panels, home batteries, electric heating and electric vehicles can and do deliver benefits to consumers through providing energy services for some consumers at significantly lower costs than fossil fuel alternatives and in doing so can help to bring down overall system costs by, for instance, reducing the need for new network build.  

Changes to the network and the sources of generation at a system level can help to reduce Scotland’s reliance on international gas markets, in the process better insulating consumers when there are external shocks such as those seen during the energy crisis.

Buildings  

Question 1: What are the most important policies needed to achieve the proposed carbon budgets level for 2026-40 in buildings? 

The energy efficiency of many of Scotland’s homes and buildings is still very low. Over half of all homes in Scotland do not have a good standard of energy efficiency where this is measured by the fabric efficiency of the building.[2] Improving this will be essential to maximise the benefits of low carbon heating systems. The Scottish Government’s heat in buildings strategy maintains a fabric first approach as a core tenet of Scotland’s approach to energy efficiency[3]. Supporting households and businesses to improve energy efficiency measures can help to play a key role in achieving proposed carbon budget levels in buildings, bringing down heat demand, helping to reduce high energy bills and tackling fuel poverty.  

Over last 3 years Consumer Scotland has built a robust evidence base to help us to understand consumer journeys and experiences of installing energy efficiency measures in their homes. Our recent investigation[4] examined issues in the green home heating market in Scotland, setting out the scale of the challenge. We made a number of recommendations to raise consumer confidence in this market and better enable consumers to make fabric improvements to their properties.

Key policies that Consumer Scotland has recommended should be taken forward include:

• Maximising the impact of energy performance certificate reforms - The Scottish Government should make Energy Performance Certificates (EPC) clearer and more action-focused, supported by robust quality and enforcement systems. In developing a revised EPC framework, the Scottish Government should ensure that EPCs empower consumers to take informed action. This can be achieved by presenting clear, accessible information on the EPC itself, alongside effective supporting materials and strong signposting to advice and funding resources.
• Strengthening the enforcement landscape - The Scottish Government, working with sector partners, should deliver a robust Quality Assurance and consumer protection policy to build confidence and protect consumers. Given the anticipated expansion of home retrofit activity, the Scottish Government must act now within its powers to strengthen the enforcement landscape and protect consumers from substandard work, rogue trading, and scams. This requires a strategic focus on ensuring that enforcement bodies both locally and nationally are sufficiently equipped and resourced to tackle unfair trading and safeguard consumer interests. 

These actions will help to provide consumers with a more secure basis upon which they can act to raise the energy efficiency of their properties.  

Question 2: When should these policies be introduced, and over what timeframe should they be implemented in buildings? 

Poor energy efficiency is a driver for poorer outcomes for consumers. It is therefore essential that homes and buildings meet high standards of energy efficiency. To support achieving the Scottish Government’s ambitions from the Heat in Buildings strategy we would encourage the policies described above to be taken forward alongside the forthcoming Heat in Buildings Bill. This will help to support consumers to understand the choices and actions they can take, and the benefit this will have to their home.  

Question 3: What are the expected costs of implementing these policies in buildings? 

The Scottish Government’s Heat in Buildings Strategy published in 2021, estimated that it would cost around £33 billion to convert all building stock (domestic and non-domestic) to zero emissions by 2045[5]. Consumer Scotland has not costed the specific proposals suggested in response to question 1, which would support the delivery of the heat in buildings strategy. However these policies have a critical enabling role to play in supporting consumer investments in home energy efficiency measures. They are important, complementary actions which can help to maximise the value for money of expenditure in this area, by individual consumers and by public investment more broadly, by providing greater clarity and protection for consumers. 

Consumers need clear direction on what actions they need to take to improve the energy efficiency of their homes, which reforms to the EPC can help to achieve. Alongside this, ensuring that the enforcement landscape can sufficiently protect consumers from substandard work, rogue trading, and scams is an essential measure to protect consumers and build their confidence in the home heating and energy efficiency market. This can help to support the overall value of investments made in this area.   

Question 4: What are the expected benefits of these policies in buildings? Please include any wider benefits (e.g. environmental, equality, financial and health) you would expect. 

Energy efficient homes bring a wide range of benefits to consumers. Insulating homes to a higher standard will help to reduce the number of people with poor physical and mental health. It can also bring significant financial benefit by reducing consumer bills, in energy systems savings and also through savings to the NHS through lower treatment costs and reduced cases of severe illness associated with colder homes. [6]

The Scottish Government is currently working to reform EPCs to make them more useful and effective for consumers. By maximising the impact of EPC reforms it can help to provide consumers with a better understanding of the actions they can take to improve the energy efficiency of their homes.

Strengthening the enforcement landscape in the home energy efficiency sector can better enable consumers to make energy efficiency improvements to their homes with the confidence that if something goes wrong there is effective redress and support available to them.     

Question 5: What do you think the key challenges would be in delivering these policies in buildings? 

Consumer Scotland recently published a consumer framework for addressing climate change[7]. Our growing evidence base across multiple consumer markets and sectors identifies four key considerations when considering policies to address and mitigate climate change. Cost, convenience, clarity, and confidence as key issues for considering the role of consumers in progressing the transition to a more sustainable future:

Cost: Evidence indicates that cost is a significant determining factor for consumers to take action to decarbonise their homes. Upfront costs associated with making energy efficiency improvements, such as insulation or installing low carbon heating are still high and will be a significant barrier to many consumers taking action. Government support and incentives are vital to encourage and support consumers to make these changes.

Convenience: Where sustainable solutions are more complex this can create additional barriers for consumers to take action. Disruption can be one of the main barriers to consumers making energy efficiency improvements, such as fabric changes or installing a replacement heating system as this can cause significant disruption to the building. Research has also highlighted some of the challenges that consumers experienced through the funding application process, including the application paperwork being complex and time consuming[8]. Meeting Scotland’s low-carbon home heating goals at the scale required will be dependent on ensuring that solutions are convenient to adopt.

Clarity: Consumers need to understand the actions they can take. Consumer Scotland’s research looking at consumer perceptions of net zero highlighted that consumers are concerned about climate change but are less clear about what specific actions they can take to address it. Consumers require clear, targeted and easy to understand information to help them understand what action they need to take. Providing consumers with this clarity will empower them to act and install low emission technologies.

Confidence: Consumer Scotland’s recent investigation into growing confidence in the green home heating market set out the scale of the challenge in Scotland to reduce carbon emissions from home heating in Scotland[9]. The sector has suffered for many years from poor trading standards, misleading claims, and scams. This can damage consumer confidence and impede uptake. Consumers should enjoy strong protection and have access to secure methods of redress when things go wrong. Mechanisms for consumer advice, protection and redress need to develop quickly to reflect the innovative characteristics of many sustainable products and services. 

Question 6: How could these policies support a Just Transition for workers and communities in buildings? 

Supporting consumers to make energy efficiency improvements to their properties will bring a range of benefits to consumers. We know that over half of homes in Scotland do not meet a good energy efficiency standard, so there is a pressing need to address this and support consumers to live in warmer, more energy efficient homes.  In 2023, 34% of all households in Scotland were estimated to be in fuel poverty. Almost half of these households are in lowest EPC bands.[10] Improving the fabric efficiency of buildings can also help to address fuel poverty and reduce energy bills by lowering heat demand. Supporting consumers to have warm homes and access to affordable heating it can also bring a range of health benefits too. There is a significant opportunity to grow and develop the market in Scotland for insulation and energy efficiency measures. While this market already exists, demand for installing energy efficiency and fabric improvement measure will grow over the coming years bringing with it a range of potential benefits to the local economy. As noted above however, it is essential that this market is developed in a way that delivers effectively for consumers.

Transport

Question 1. What are the most important policies needed to achieve the proposed carbon budgets level for 2026-40 in the transport sector?

Consumer Scotland’s 2024 research on consumer attitudes to sustainable transport behaviours[11] found that while consumers are interested in reducing personal emissions by changing transport habits (as reported by 65% of respondents), there are significant barriers to doing so.

Policies which aim to encourage more sustainable transport habits should focus on addressing the key issues that are important for consumers: cost, convenience, clarity and confidence.

Cost

Reducing the cost of public transport and public EV charging where possible and improving its value for money should be a key priority for the Climate Change Plan. The cost of public transport was cited by respondents to a Consumer Scotland survey on consumer attitudes to net zero policy as one of the two biggest barriers to choosing public transport as a method of travel.[12]

Policies that support the reduction of the cost of sustainable transport relative to private car usage play an important role in reducing emissions in the transport sector. Measures such as the proposed £2 bus fare cap pilot may help to make public transport more affordable and accessible to low-income consumers and help entrench existing sustainable transport habits.[13]

Convenience

Improving the convenience of sustainable transport by increasing and improving connectivity between active travel routes and minimising the time it takes to complete public transport journeys and transfer between modes should be a key focus of the transport elements of the Plan.

Consumer Scotland’s research shows more than half (53%) of consumers view the time public transport or active travel journeys take as a barrier to choosing these methods of transport.[14]

Policies that make public transport services more convenient for consumers, for example through reducing journey time and integrating ticketing and modes of transport, will be important. Increasing integration between travel modes and across differing operators will improve outcomes for consumers. A recent survey from Transport Scotland showed that 79% of people had undertaken a multimodal journey in the previous year.[15] Mobility hubs can allow for simpler transfers between modes of transport, especially where timetables can be better aligned, potentially making public transport journeys more convenient, quicker, safer and more convenient for users.

In addition, a lack of availability of services was the most frequently cited barrier to use of sustainable transport options reported by consumers in Consumer Scotland research.[16] In areas where there is lower availability of public transport consumers may have less confidence in the capacity of the network to meet their needs, resulting in many remaining committed to private car use.[17] Targeting investment in either services or underlying infrastructures in areas that are currently underserved would improve the availability of services.

Clarity

There is a need to improve consumer understanding and clarity about how choosing more sustainable transport methods will both contribute to reducing emissions and deliver other potential co-benefits. 

Our research showed that, while many consumers wish to reduce their transport emissions, some lack understanding about how their transport choices impact wider emissions goals. 17% of consumers we surveyed did not know how to reduce their transport carbon emissions, while 15% didn’t think their actions would have an impact.[18]

The policies implemented in the transport envelope of the Climate Change Plan must also have clear linkages with the Just Transition Plan for Transport and other policy and legislative changes in this area.

Confidence

Improving consumer confidence in the safety and accessibility of active travel routes; in being able to utilise reliable public transport services, and in the ability to reliably charge and maintain electric vehicles should be key policy priorities.

Our research also showed that 11% of consumers felt a lack of safety was a barrier to adopting more sustainable travel methods. 38% of those with a disability or long-term health issue also considered accessibility issues to be a barrier.

More work is required to address these issues for consumers in vulnerable circumstances if they are to be able to safely and confidently access services. Consumer Scotland is planning to publish a report on safety and accessibility on public transport in 2026.

Improving consumer confidence in the EV market is also important. In particular, ongoing work to improve the availability and cost of public charging will be key to helping consumers build confidence to adopt EVs over petrol and diesel cars. Consumer Scotland research has shown that EV ownership is significantly less convenient and affordable for consumers without the ability to charge their EV at home,^[19] creating a significant barrier for EV adoption. The availability of EV chargepoints must improve, with the right type of chargers built in the right locations to support current and future consumers, particularly those who cannot charge at home.

Transport Scotland’s Draft Electric Vehicle Public Charging Network Implementation Plan sets out a strategy which recognises that certain locations may be considered less commercially viable to private chargepoint operators. These include rural and island locations and areas with demand for near-home and on-street slow charging [20] Ensuring reliable, well maintained and cost-effective charging options exist is crucial to encouraging EV uptake. The available infrastructure must include a range of fast and slow charging options, depending on how long cars will be left at a chargepoint.[21]

Question 2. When should these policies be introduced, and over what timeframe should they be implemented in the transport sector?

There is a need for rapid progress in the transport sector if emissions targets are to be met, however it will be important to consider the wide range of consumer needs when designing and implementing policies. Policies that will impact on consumers, particularly those in vulnerable circumstances, should incorporate the principles of inclusive design in order to meet a wide range of needs and be appropriately piloted or user tested to maximise the consumer benefits and minimise the risk of harm.

Question 3. What are the expected costs of implementing these policies in the transport sector?

No response

Question 4. What are the expected benefits of these policies in the transport sector? Please include any wider benefits (e.g. environmental, equality, financial and health) you would expect.

Effective policies in these areas have the potential to support the creation of a safe, accessible transport system which is easier to use.  This will bring benefits to all consumers, including those in vulnerable circumstances, such as an increase in accessibility and choice and a reduction of cost.

Our research has found that environmental concerns are often secondary for consumers at present, when compared to key priorities such as cost and convenience. There is a need to build consumer understanding and awareness of the wider benefits of changes to behaviours, to help encourage buy in and engagement. Modal shift from private car to public transport or active travel brings public health benefits related to better air quality[22] and lower rates of obesity and associated health issues.[23] Addressing consumer concerns about the safety, accessibility and convenience of the sustainable travel network, can help make consumers more confident that they can travel safely and efficiently. By highlighting the benefits, the Scottish Government can maximise the opportunity to engage consumers, particularly those who may be less motivated by sustainability concerns. We recommend an increased focus on public awareness of the range of co-benefits that can come from reducing transport related emissions. 

Question 5. What do you think the key challenges would be in delivering these policies in the transport sector?

The potential costs of pursuing these policies, especially at scale, would present a challenge in the context of current budgetary pressures faced by Government.[24] New transport projects and spending will need to be targeted to areas where the greatest impact is anticipated, or may require greater piloting initially to increase confidence that they will deliver intended benefits. There are a multitude of bodies with a responsibility for delivery of transport policies and a need for effective coordination and governance. Successfully delivering these policies will require clear delivery plans which articulate the expected contribution of each measure, clearly allocating responsibilities and budget and putting in place clear processes for monitoring and evaluation.

Achieving modal shift from private car to public transport and active travel requires significant shifts in consumer attitudes and behaviours.  Consumer Scotland’s research showed that while 65% say they would like to travel in a way that reduced their emissions, public transport usage has plateaued since the Covid pandemic.[25] If  policies in this area are to be successful, they will need to be accompanied by strong engagement with consumers to outline how sustainable travel can meet their needs and how changes in behaviour can benefit them and their wider communities.

Question 6. How could these policies support a Just Transition for workers and communities in the transport sector?

Investment that increases the number of active and public transport services has potential to create a number of jobs.  While cost is a significant challenge to delivering improvements to public transport, there may be opportunities to partially offset this through wider economic gains that such investment can generate.

For communities, the way local transport strategy is devised through RTPs and local authorities presents an opportunity for more region-specific policies to be pursued. The geographical differences between urban, rural, and island regions result in differing experiences for consumers in each respective area. In rural and island areas, which are more sparsely populated , lack of public transport services and infrastructure can render sustainable transport ‘out of reach’ for many consumers. More formal and consistent engagement with consumer panels featuring consumers and stakeholders from different geographical and demographic backgrounds would allow more local communities to be better represented and served by transport policy. This is in line both with Scotland’s current Public Service Reform Strategy[26] and also the Consumer Duty which places a statutory duty on local authorities and other public bodies to have regard to the impact and potential harm of strategic decision on consumers.[27]

Waste and circular economy

Question 1. What are the most important policies needed to achieve the proposed carbon budgets level for 2026-40 in the waste and circular economy sector?

The transition to a circular economy is one of the significant challenges of our time and achieving it will require substantial and sustained change. With around four fifths of Scotland’s carbon footprint coming from the products and services we manufacture, use and throw away,^[28] supporting consumers in Scotland to make changes to behaviours will be vital to achieving the carbon budgets level for 2026-40 in the waste and circular economy sector. The Climate Change Plan Monitoring Report notes the importance of accelerating action across society to reduce the demand for raw material in products and encouraging reuse and repair.[29] The changes in consumer behaviour must move beyond the well-established and lower impact behaviours such as recycling.

To achieve the levels of change needed to meet the proposed carbon budgets, policies must focus on supporting consumers to make changes higher up the waste hierarchy. This means focussing attention on reducing consumption, increasing re-use, and extracting maximum value from existing resources.

Consumer Scotland’s research has found that consumers are open to taking measures that will support the circular economy, such as buying second hand or repairing goods, but need more support. Our research found broad consumer support for a range of circular economy measures^[30]

• 74% agreed that products should be made so that they are easy to repair and their components can be re-used, even if this impacts product quality
• 40% agreed that products which can't be repaired or recycled should be banned
• 49% agreed that products which can't be repaired or recycled should be taxed more than those that can be, even if this increases their cost
• 70% agreed that 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

Ensuring that Scottish Government actions effectively support consumers to make more sustainable choices will be key to achieving the required carbon budget levels. Work by Consumer Scotland has identified cost, convenience, clarity and confidence (the 4 Cs) as the key consumer issues that decision makers must address when proposing policies where consumer behaviour change is necessary to ensure a more sustainable future.^[31] Waste and circular economy sector policies must acknowledge these key issues and ensure that the impact on consumers, including those in vulnerable circumstances, is fully considered. We recommend that the Scottish Government assesses the waste and circular economy policies included in the Climate Change Plan against this framework.

The timely publication of a clear, robust Circular Economy Strategy will be a vital first step to achieve the proposed carbon budgets level for 2026-40 in the waste and circular economy sector. The Circular Economy Strategy should link clearly with the Climate Change Plan and Circular Economy and Waste Routemap and 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.

A systemic approach to introducing circular economy and waste policies, backed by robust assessments of the individual and collective impacts of new and existing measures is needed to support effective consumer engagement. There is a need for a system-level design which fully considers the need for regulation, including the design of incentives, and the banning or taxing of problematic products, where appropriate, as part of the solution. This is consistent with the findings of the Climate Change Committee, who have called for more support for people to make sustainable choices, including through providing regulation and incentives, where powers are devolved.^[32]

There are a number of specific policy measures which could be put in place to help move action further up the waste hierarchy. These include:

• the adoption of a product stewardship approach,
• the introduction of environmental charges 
• more support for re-use and repair measures and business models

We provide further detail of each of these proposed measures below:

The development of a product stewardship plan to identify and tackle the environmental impact of priority products could potentially play a significant role in providing consumers with the information required to support changing behaviour. The Scottish Government confirming the three or more priority products for further action could assist consumers to understand the impact of products and support them to reduce consumption. We would welcome greater clarity about the timescale for producing a plan as part of the suite of measures needed to achieve the proposed carbon budgets.

The introduction of environmental charges, focussed initially on those products with the most problematic impacts, has the potential to support consumer behaviour change. In tandem with other measures, this can help consumers to understand the impact of product choices and allow them to make purchasing decisions which align with their sustainability preferences. Where this approach is taken, it is important that the impact on consumers in vulnerable circumstances is fully considered, ensuring that those who are least able to pay are not disproportionately impacted. Where any policies, including charges for single use items, are introduced, it is important to acknowledge that these are only one part of the solution. Facilitating greater consumer awareness and engagement with reducing consumption, especially of single-use items, through sustained behaviour change campaigns and continued engagement with manufacturers to develop more sustainable products will also be crucial.

Policies to support reuse and repair market development will be required. Ensuring that reuse and repair businesses have the support and guidance that they need in order to succeed on a larger scale, including establishing strong links between businesses to facilitate peer learning will be key. Clear and targeted guidance and support will enable reuse and repair businesses to establish themselves in a more mainstream and profitable way, moving beyond the small-scale success stories that we currently see in this space. Supporting these businesses to establish a more significant market presence also has the potential to increase consumer confidence and buy in as these business models become more mainstream and barriers to using them are removed. 

In addition to these specific policy areas, while it will be important to focus attention higher up the waste hierarchy, ensuring that the Climate Change Plan also has robust policies in place to improve the recycling rate of higher impact materials such as textiles and food will be key. Policies to tackle the recycling of these materials should consider the key consumer issues of cost, convenience, clarity and confidence to ensure that the impact on consumers, including those in vulnerable circumstances, is fully considered.

In order to make the changes required to transition to a circular economy, there must be accessible alternatives to the unsustainable behaviours we are seeking to change. Where changes are made to services such as household recycling or charges are made to tackle problematic single use items, these should be accompanied by the necessary support for consumers. The policies included for the waste and circular economy sector should consider and address the need for accessible alternatives for consumers, including those in vulnerable circumstances.

Policies that seek to achieve the proposed carbon budgets level for 2026-40 in the waste and circular economy sector must draw on the willingness of consumers to consider these choices and provide consumers with clear information. Overarching policy frameworks must provide a robust enabling environment that takes the key barriers of cost, convenience, clarity and confidence into account in order to allow consumers to make the changes that are being asked of them.

Question 2. When should these policies be introduced, and over what timeframe should they be implemented in the waste and circular economy sector?

A clear, robust and well communicated Circular Economy Strategy and linked Circular Economy Targets to accompany the Circular Economy and Waste Routemap will be a vital next step to provide clarity to consumers and enable changes to behaviour. A focus on making sure that the range of interrelated strategies, plans and policies are well sequenced, joined up, coordinated and communicated will allow consumers to understand their role in the transition to a circular economy and give them the confidence to make the changes that are being asked of them.

We agree with the Climate Change Committee’s recommendation that the actions outlined in the Circular Economy and Waste Routemap should be delivered on time and build on previous waste reduction targets.^[33] We would welcome more clarity on the timelines and sequencing of the actions and priorities outlined in the final Circular Economy and Waste Routemap.

Question 3. What are the expected costs of implementing these policies in the waste and circular economy sector?

No response

Question 4. What are the expected benefits of these policies in the waste and circular economy sector? Please include any wider benefits (e.g. environmental, equality, financial and health) you would expect.

Given that many consumer purchasing decisions are more directly influenced by factors such as cost and convenience rather than sustainability,^[34] it is important to highlight the wider benefits of changes to behaviours to encourage buy in and engagement. By highlighting these benefits, government and other stakeholders can maximise engagement, particularly from consumers who may be less motivated by sustainability concerns.

Providing information to promote the range of positive benefits that sustainable consumption can generate, such as economic growth, cost savings and health benefits, will encourage more sustainable action by consumers.^[35] Polices to improve circularity can have a range of economic benefits, including opening up new market opportunities, improving productivity, maximising resources and increasing self-sufficiency and resilience by reducing reliance on international supply chains and global shocks.

Question 5. What do you think the key challenges would be in delivering these policies in the waste and circular economy sector?

As outlined above, we have identified cost, convenience, clarity and confidence (the 4 Cs) as the key consumer issues that decision makers must address when proposing changes designed to ensure a more sustainable future.^[36] Waste and circular economy sector policies must ensure that the impact on consumers, including those in vulnerable circumstances, is fully considered through the lens of the 4 Cs.

Consumer Scotland research has found that 80% of respondents agreed that they would like to reduce the carbon emissions from the household items that they buy.^[37] 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 a lack of clear labelling on the environmental impact of products.^[38]

Cost can be a significant barrier to consumer behaviour change. Policies must fully consider 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 circular economy measures. This will guide the provision of targeted advice and support, including any required targeted financial support. Policy makers need to understand the costs of proposals and identify when and where these costs are likely to fall.

Where charges for single-use items are introduced, it will be important to avoid potential detriment to consumers who are on low incomes or in vulnerable circumstances. To mitigate against this, full impact assessments must be carried out and there must be accessible, affordable sustainable alternatives available to consumers that fit their needs.

Our research showed that levels of net zero awareness and concern remain high, but consumers are less sure about what they can personally do to help Scotland meet net zero targets. Providing consumers with clear and well targeted information forms one necessary element of the targeted support that will be needed.  Consumers are currently receiving multiple messages from various sectors, using differing language and approaches. Consumers would benefit from the production of messaging that is simple, consistent across sectors and adequately targeted. With the range of current and upcoming consumer facing policies in the circular economy and waste sector, such as a deposit return scheme, measures to reduce use of single use cups and secondary legislation coming from the Circular Economy Act, including bans on the destruction of unsold consumer goods and measures to improve disposal of household waste, clarity and consistency of messaging for consumers will be important.

Question 6. How could these policies support a Just Transition for workers and communities in the waste and circular economy sector?

As outlined above, the transition to a circular economy has the potential to realise a range of benefits for society, including the creation of new, localised jobs and opening up new market opportunities, which can support a just transition for workers and communities in the waste and circular economy sector.[39]

Current consumer purchasing decisions are influenced by a range of factors, including convenience, speed of purchasing, ingrained behaviours and price. Sustainability considerations compete with these factors, and our research has shown that sustainability concerns do not currently appear to drive consumer purchasing decisions, with many consumers prioritising other factors such as cost and quality.

More can be done to highlight the potential for economic growth and community development that can come from the transition to a circular economy.

Negative Emission technologies  

Question 1: What are the most important policies needed to achieve the proposed carbon budgets level for 2026-40 in negative emission technologies? 

The Climate Change Committee estimates that between 2023 and 2040, CO₂ emissions from residential buildings will need to fall by 66%[40]. Achieving this objective will require a rapid increase in deployment of low carbon heating and energy efficiency measures in homes across Scotland. This will require consumers to engage with low carbon technologies, such as heat pumps and Solar PV, and consider the options best suited to their homes.  

Consumer Scotland has built a robust evidence base to understand consumer journeys and experiences of installing low carbon technologies. This includes commissioned qualitative research to explore the motivations, enablers, prompts and barriers to consumers taking up these technologies[41]. Through this work we have made a number of recommendations to Scottish Government and others about the actions required to better support consumers along this journey to install low carbon technologies and decarbonise their homes. Our recent investigation into consumer confidence in the green home heating market in Scotland also set out the scale of the challenge in this market and provided further recommendations for action. From this evidence base, important areas for policy development that Consumer Scotland would like to see taken forward include:

Strengthening information and advice: The Scottish Government should lead inclusive campaigns around benefits, choices, and support - to empower consumers around the home heating transition. Work is needed to raise awareness of the clean heat agenda, the options and choices available to consumers and the benefits this can bring.

Future proof provision of independent information and advice: As demand increases, the Scottish Government should ensure consumers have access to trusted, independent advice. The Scottish Government should commit to funding the Home Energy Scotland service, or an equivalent body such as the National Public Energy Agency, sufficiently so it can deliver that function to the appropriately high standard as volume in this sector increases.

Review existing funding support to ensure maximum effectiveness, reach and impact: by the end of 2026 the Scottish Government should review consumer funding for impact, fairness, and effectiveness and streamline processes to remove unnecessary barriers. A systematic review of funding will help to improve the offer to consumers is inclusive effective and fully supports them along this journey.

Strengthen the enforcement landscape: The Scottish Government, working with sector partners, should deliver a robust Quality Assurance and consumer protection policy to build confidence and protect consumers. Given the anticipated expansion of home retrofit activity, the Scottish Government must act now within its powers to strengthen the enforcement landscape and protect consumers from substandard work, rogue trading, and scams. This requires a strategic focus on ensuring that enforcement bodies both locally and nationally are sufficiently equipped and resourced to tackle unfair trading and safeguard consumer interests. 

Each of these actions will help to build more confidence in the sector and enable consumers to participate in this market.  

Question 2: When should these policies be introduced, and over what timeframe should they be implemented in the negative emission technologies sector? 

The Climate Change Plan Update sets out that emissions for homes and non-domestic buildings combined will have to fall by 68% between 2020 and 2030[42]. Carbon-intensive heating in buildings is the third-highest source of polluting emissions in Scotland and reducing them will be critical to achieving climate targets[43]. The sooner that action is taken, particularly to support consumers to install low emission technologies, the more likely achieving climate targets will be. Consumer Scotland would like to see action taken to introduce these policies alongside the forthcoming Heat in Buildings Bill. 

Question 3: What are the expected costs of implementing these policies in negative emission technologies? 

In the Heat in Buildings Strategy published in 2021, the Scottish Government estimated that it would cost around £33 billion to convert all building stock (domestic and non-domestic) to zero emissions by 2045[44]. Consumer Scotland has not costed the specific proposals set out in response to question 1, however we regard these actions as required to provide consumers with the information and advice they need and ultimately support better consumer experiences of installing these technologies. 

Question 4: What are the expected benefits of these policies in negative emission technologies? Please include any wider benefits (e.g. environmental, equality, financial and health) you would expect. 

Building consumer confidence in the sector can will help to accelerate the rollout of low carbon technologies across Scotland and enable consumers to have better experiences of installing and living with these technologies.

We know that one of the key motivations for installing low carbon technologies is environmental concerns[45]. Many consumers install these technologies because they understand the wider societal benefits from tackling climate change that they are contributing to addressing. However there is also a range of economic benefits that can come with installing these technologies. Saving money on energy bills is also another key driver for consumers when looking to install low carbon technologies. This can come from installing technology that can offset electricity costs, such as solar PV, or from moving away from volatile fossil fuels. By supporting and encouraging consumers to engage in these markets there is potential to help to drive growth, develop supply chains and create new jobs and opportunities for local communities.   

Question 5: What do you think the key challenges would be in delivering these policies in negative emission technologies? 

Consumer Scotland recently published a consumer framework for addressing climate change[46]. Our growing evidence base across multiple consumer markets and sectors identifies four key considerations when considering policies to address and mitigate climate change. Cost, convenience, clarity, and confidence are key consumer issues in progressing the transition to a more sustainable future: 

Cost: Evidence indicates that cost is a significant determining factor for consumers in considering installation of low emission technologies. Upfront costs associated with installing low carbon technologies are still high and will be a significant barrier to widespread adoption of technologies. Government incentives are vital to encourage and support consumers to install these technologies.

Convenience: Consumer Scotland’s own research which looked at consumer experiences of installing low carbon technologies found that convenience is often a barrier to the wider rollout[47]. The journey from enquiry to installation for low carbon technologies can be long, confusing and a cause of frustration to consumers. The disruption associated with installation is a significant barrier for consumers which makes installation less likely unless a consumer is moving property. Research has also highlighted some of the challenges that consumers experienced through the funding application process, including the application paperwork being complex and time consuming[48]. Addressing these challenges will make the installation process simpler and easier for consumers.  

Clarity: Consumers need to understand the actions they can take. Consumer Scotland’s research looking at consumer perceptions of net zero highlighted that consumers are concerned about climate change but are less clear about what specific actions they can take to address it. Consumers require clear, targeted and easy to understand information to help them understand what action they need to take. Providing consumers with this clarity will empower them to act and install low emission technologies. 

Confidence: Consumer Scotland’s recent investigation into growing confidence in the green home heating market set out the scale of the challenge in Scotland to reduce carbon emissions from home heating in Scotland[49]. The sector has suffered for many years from poor trading standards, misleading claims, and scams. This can damage consumer confidence and impede uptake. Consumers should enjoy strong protection and have access to secure methods of redress when things go wrong. Mechanisms for consumer advice, protection and redress need to develop quickly to reflect the innovative characteristics of many sustainable products and services. 

Question 6: How could these policies support a Just Transition for workers and communities in negative emission technologies? 

Supporting the growth and rollout of low emission technologies will come with a range of potential benefits for both workers and communities. The rollout of these technologies will require the development of new supply chains to meet demand and also to lower the cost associated with the rollout[50]. This is an opportunity to build and develop new local markets, which has the potential for wider economic benefits, including opportunities to create new jobs. New skills will be required to address the challenges presented by the climate crisis and the rollout of low emission technologies. The Just Transition Commission has recommended that clear roadmaps for the different technology options will help to provide confidence, direction and drive investment to support these benefits to be fully realised[51].

Non sector-specific questions

Question 1. How should the changes required to meet emission reduction targets be funded?

The measures set out in the Climate Change Plan need to be fully costed, and any interdependencies with other Scottish or UK Government policies or measures must be clearly set out. As noted by Environmental Standards Scotland, the cost associated with each policy in the Climate Change Plan should be clearly set out including the cost for each year, and how the cost is split between the public and private sectors.^[52]

Question 2. What governance arrangements are needed in the Scottish Government to ensure effective delivery of the CCP?

The Climate Change Plan must be credible, with clear and measurable objectives that set out how the interventions and policies will deliver the five-year carbon budget. As recommended by Environmental Standards Scotland, strong governance with effective scrutiny of delivery, and well-evidenced actions with defined timelines for implementation will play an important and essential role in delivering a successful Climate Change Plan. ^[53]

The Climate Change Plan needs to provide clarity about governance arrangements , setting out  effective oversight of risk management and performance management from the outset, as detailed by Audit Scotland.^[54] Audit Scotland notes that this will include having clear accountability arrangements for each policy and for the plan, including for reporting to the Scottish Parliament as required by the Climate Change (Scotland) Act 2009. In addition, we agree that a clear line of sight between the Climate Change Plan commitments and allocations in the Scottish Budget would be helpful to enable effective scrutiny.^[55]

A significant amount of time has passed since the last plan was published, with the Scottish Government producing the previous update in draft in December 2020 and finalising it without amendment in March 2021, due to time constraints before the 2021 Scottish Parliament election. We agree with Environmental Standards Scotland that that there must be sufficient time for scrutiny of the next draft Climate Change Plan and incorporation of feedback before the final version of the Plan is published. ^[56]

The Consumer Scotland Act 2020 places a responsibility on public bodies to carry out a consumer duty impact assessment when taking strategic decisions. Consumer Scotland published guidance for public bodies earlier this year[57]. The guidance explains how the principles set out at the start of this submission could be applied by the Scottish Government to the development of the Climate Change Plan and ensure the potential impact upon consumers has been fully considered.

Question 3. How can the Scottish Government ensure transparent monitoring and reporting on progress?

We support Environmental Standards Scotland’s call for effective monitoring and evaluation of the Climate Change Plan, which will be essential to support robust scrutiny.^[58] Environmental Standards Scotland notes the importance of the Climate Change Plan including sufficient detail in the form of SMART (specific, measurable, achievable, relevant and timebound) measures and targets that provide continuity of delivery against short and long-term outcomes.^[59] These targets should also be underpinned by appropriate indicators, including an assessment of consumer support for and participation in measures under the plan. We also support Environmental Standards Scotland’s call for clarity regarding both the contribution of individual policy measures towards emissions reduction and the cost of the interventions and policies to deliver these reductions.

Audit Scotland notes the importance of monitoring and evaluation of policies in the Climate Change Plan for assessing progress and cost effectiveness, supporting accountability for delivery, and identifying improvements to current and future activity.^[60] We agree with Audit Scotland that it would be beneficial to have interim milestones for judging early progress, to support assessment of whether there is any risk to achieving outcomes and to enable the Scottish Government to take corrective action early, if needed.^[61]

Question 4. What should the Scottish Government do to help the public contribute to climate action?

Consumer Scotland’s research has found that consumers are concerned about climate change but are unclear about how the journey to net zero will be achieved and how their actions can contribute to meeting climate targets. In a  survey conducted by YouGov on behalf of Consumer Scotland, three-quarters (76%) of respondents stated that they are either ‘very’ or ‘fairly’ concerned about this issue but less than a third (28%) said they knew a lot about what they need to do to help Scotland reach net zero by 2045.^[62] Although many consumers express concern about climate change, this is not resulting in action that meets the pace and scale of change that is required. While more than half (52%) of respondents to our survey stated that they are very/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.^[63]

The Scottish Government, along with other stakeholders, has a significant role to play in helping the public to contribute to climate action.  Consumers are seeking clearer leadership and guidance to help them to make the choices that will help to tackle climate change. A majority (63%) of respondents to our recent survey ranked the UK Government and the Scottish Government (60%) as most responsible for taking action to reduce emissions.^[64] Fewer (16%) of our survey respondents ranked consumers as most responsible for reducing emissions, with most ranking them last (59%).^[65] However, although consumers see themselves as having less responsibility than government or industry, they still want to understand how they can play their part and have a positive impact on climate issues. The Scottish Government needs to deliver consistent, insightful, and coordinated leadership, and a compelling and consistent national narrative through the Climate Change Plan, ensuring that consumers have clarity on their role.

Only 28% of our survey respondents said they know a lot or completely about what they need to do to help Scotland reach net zero by 2045, illustrating the challenge faced if these ambitious targets are to be met. We need a systemic approach to underpin fair and effective consumer engagement in the transition to net zero. Governments need to create an enabling environment where it is easier for consumers to make the changes which are being asked of them. Making sustainable choices more cost-effective and convenient for consumers is central to a successful transition, as our climate targets are unlikely to be met without this.

A review of key evidence, including Consumer Scotland’s growing evidence base on consumers in relation to climate change and net zero legislation and policies, has identified cost, convenience, clarity, and confidence (the 4 Cs) as key issues for considering the role of consumers in progressing the transition to a more sustainable future. For the Climate Change Plan to be a success, it will be vital for it to consider these key issues.

With regards to cost, it is important that the costs of adopting policies in the Climate Change Plan are distributed fairly. The Climate Change Plan must ensure that the impacts across all groups of consumers are considered, and ensure it reflects how climate change is being experienced by different groups. This includes ensuring affordability of new policy measures for all consumers. This must involve thinking both about overall costs and also their type and timing and how consumers are exposed to the risk of rising costs in the future. Where costs are prohibitive to particular groups, the Climate Change Plan needs to address how appropriate support will be provided. It is essential that Scotland’s overall climate plans are costed at a consumer level, as well as at a system level.

With regards to convenience, the Climate Change Plan should support sustainable products and services being designed in ways that fit easily into consumers lives. The Climate Change Plan should consider the role of the Scottish Government, along with other stakeholders such as regulators, businesses and the wider public sector, in creating policies, products and services that are convenient and understandable for those using them.

Confidence is another key issue for consumers, it is important that consumers trust sustainable products and services, have strong protections and have access to redress when things do go wrong. The policies within the Climate Change Plan should ensure that mechanisms for consumer advice, protection and redress develop quickly to reflect the innovative characteristics of many sustainable products and services.

Finally, consumers need clarity about what they will need to do, when, and why. Building collective understanding through a robust Climate Change Plan will help consumers understand how they can contribute to meeting our carbon budgets. Consumers need clear and targeted information and support to enable them to take action, and a clear, well considered Climate Change Plan will support consumers to act and be confident that they are doing the right thing, at the right time, and in the right way.

Our consumer framework for addressing climate change also acts as a policymaker’s toolkit. For each of the issues outlined above, a set of key questions, or tests, have been identified that can be used to ensure that Scotland’s climate change mitigation and adaptation policy, regulation, and practice is consumer focused. By asking these key questions, or tests, policymakers, regulators, businesses, and other key decision-makers can be more confident that the consumer perspective has been placed at the centre of the transition to a sustainable and resilient future.^[66]

The Scottish and UK Governments should undertake robust modelling and analysis of the impact of the measures included in the 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.

We agree with the Climate Change Committee that it is important that the revised Climate Change Plan is detailed, credible, robust and commits to tangible measures, backed by fully costed budget commitments, which can be delivered within the relevant timeframes.^[67] This will allow consumers and other stakeholders to have clarity and confidence in targets put in place to achieve net zero, along with a clear understanding of what their role in the process is.

Developing effective and targeted measures to support the consumer transition to net zero requires those who design and implement policies to have a clear understanding of consumers’ attitudes, experiences, beliefs, behaviours and perceptions. In order to fully understand the changes consumers will need to make it will be necessary to map out the consumer journey. The needs and priorities of consumers and the barriers to taking action must be kept at the heart of the policy design process if the transition is to be successful.

Public engagement and information strategies need to be tailored to recognise the range of factors that may encourage consumers to engage in the transition to net zero. It will be important to build consumer literacy on the topic of climate change, helping consumers understand the impact of individual actions. Further action is also needed to highlight the wider range of benefits that can flow from taking action through highlighting co-benefits of making changes. This can be particularly impactful for those who are less motivated by traditional sustainability messages.

Behaviour change models, such as the Scottish Government’s ISM tool, should be used to support the development of interventions to help remove barriers to consumer action.[68] The Scottish Government should consider this in the new Climate Change Plan. This should include consideration of recommendations from the Just Transition Commission along with considering the provision of targeted support, including financial assistance for those who may otherwise be unable to make changes, to ensure that all consumers can be part of the transition.

Water is a further area that must be included in the Climate Change Plan and its contribution towards responding to the climate emergency fully acknowledged. In addition to focusing on the natural environment and its dependency on adequate supplies of raw water, we would support a strong and clear emphasis on the role that water plays within Scotland’s public health and economy. Greater emphasis is needed on promoting the value of water within society to ensure that wastage is minimised and there is enough for everyone.

The Statement to Accompany The Climate Change (Scotland) Act 2009 (Scottish Carbon Budgets) Amendment Regulations 2025 refers to ‘clean water and sanitation’ and ‘reducing emissions associated with wastewater, reflecting steps to align with relevant EU Directives, and Scottish Water’s commitment to net zero emissions by 2040’.[69] We would therefore have expected to see water listed within the sectors asked to inform the scrutiny of the Climate Change Plan. Whilst there is one outcome relating to water, many of the remaining outcomes and objectives, for example protecting peatland and wetland or supporting farming and food production, do not recognise that without water, they cannot be achieved. With a declining availability of water in Scotland, particularly during times of low rainfall, we recommend that the importance of water and the role it plays, is given greater focus.

Question 5. What other factors could affect whether Scotland meets its climate change targets? Please share any ideas you have. These could relate to workforce planning and skills, devolved and reserved powers, social and cultural factors, international aspects, or other areas you think matter.

No response