In 2022, Scotland set out a range of proposals across the resources and waste system through a Route Map consultation. Following the responses, a draft Route Map has been published outlining how they will deliver and coordinate these actions. IEMA's Policy & Engagement Lead on Circular Economy, Adam Batchelor outlines IEMA's response.

The circular economy vision is that by 2045 Scotland’s cultural, social and business norms will be driven by a focus on:

  • Responsible Production
  • Responsible Consumption
  • Maximising Value from Waste and Energy

The consultation states that the waste management sector now only directly accounts for around 4% of total Scottish greenhouse gas emissions and sustainable resource use is key to tackling climate change. Unfortunately, many of the priorities and further actions suggested in the consultation are focused on waste. Circular principles should underpin all proposed actions. Additionally, ambitious targets to reduce virgin material use by 2045 are needed to reduce unsustainable consumption and production and enhance resource security.

IEMA consulted with Circular Economy Network members to gain insights and identify gaps in these proposals. The response put forward several recommendations that IEMA believes would strengthen the proposals and help support the transition to a circular economy.

The accessibility of waste hubs and networks is crucial, especially for Small and Medium Sized Enterprises (SMEs). Physical hubs with an online portal will be vital to ensure users can remotely access stock availability, enhancing reliability in sourcing secondary materials.

A nuanced approach is recommended to accelerate circular construction practices using compliance levers like a voluntary ‘comply or explain’ framework. Mandatory compliance should be reserved for pivotal drivers, steering the transition towards a circular economy.

Extending the Reference Service Life (RSL) for building models beyond the standard 50 years is recommended, accompanied by policy measures addressing skills gaps and promoting the longevity of buildings and materials.

Incorporating the proposed hierarchy into the National Planning Framework is suggested to minimise soil and stone disturbance, prioritising biodiversity preservation and carbon sequestration.

Scotland can further their ambition to decarbonise disposal using a whole systems and life cycle approach by measuring the carbon intensity of materials in the waste stream, ensuring all recyclable materials are recovered from the waste stream and only sending pure residual waste for disposal.

We recommend that consideration be directed towards the quality of employment risks associated with the transition to a circular economy. Measures should be introduced to ensure that circular jobs are inclusive and equitable, adopting a strong foundation for circular economy education and skills development.

Read IEMA's full response here.

Photo of Adam 044
Adam Batchelor

Policy and Engagement Lead

Adam is the Policy and Engagement lead for Circular Economy and Environmental Management at IEMA. Adam has 15 years of experience in the environment field, from local government waste and recycling, auditing contracts and implementing improvements into local services; to working for the Greater London Authority/Mayor of London for the last eight years. Adam has been responsible for co-developing and delivering the Mayor of London’s Environment Strategy (Waste and Circular Economy) and has led many circular programmes from plastic reduction in the capital to food waste reduction for small business. Adam joined IEMA in December 2021 and is responsible for leading the circular economy network and environmental management group.


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