Response to Scottish Government Consultation on the Draft Circular Economy Strategy

Response to Scottish Government Consultation on the Draft Circular Economy Strategy

January 2026


Question 1: To what extent do you agree with the vision and outcomes for the strategy?

Neither agree nor disagree

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

No

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

Children and young people in Scotland tell us that environmental matters are of great importance to them. They have repeatedly voiced concern for the combined climate and nature emergencies and experience anxiety surrounding these issues. We have heard that they are frustrated by the lack of progress and that despite their efforts, those in power have not acted. They feel ignored and powerless.

Scotland has a legal target to reach ‘net zero’ greenhouse gas emissions and Moving to a circular economy is key if we are to tackle our overconsumption of natural resources.

We support the principles of the strategy and moving from a ‘linear “take, make and dispose” economic model to a circular economy where materials and goods are valued and kept in use for as long as possible’[1].

We stress that moving to a circular economy must be done in a way that achieves a ‘just transition’ and particularly that it is implemented in a way that aims to tackle inequality and child poverty and does not exacerbate it.

The latest Concluding Observations from the UN Committee on the Rights of the Child noted a ‘deep concern’ that 250,000 children are living in poverty in Scotland, which equates to around one in four children.[2] The climate and nature emergencies disproportionately affect the poorest and most marginalised children, exacerbating existing inequalities.[3]

Poverty is not an inevitability in Scotland, it is the result of political choices. We are disappointed that within the consultation document there is no mention of supporting households experiencing poverty or the impact on children, more should be done to address this.

At present, the proposed provisions have the potential to alleviate some issues which exacerbate child poverty, but this will only be achieved if care is taken to ensure a just transition. The focus of a move to a circular economy must be to reduce inequalities, not widen them. Policies must be in place to share costs fairly. We would like to see the principles of tackling poverty, become a more integral part of the strategy. It is important that such principles become part of the fabric of it from the start. We feel that an outcome of the strategy should be to alleviate poverty and inequality, bearing in mind that this is more complicated than just creating new jobs.

Poverty is a complex issue – it is not just a lack of income but also access to services. Care needs to be taken to ensure that those experiencing poverty have access to the benefits of the circular economy. This can include things like:

  • addressing the stigma of using second hand goods
  • making sure that reuse facilities are accessible and in areas people who need them can access easily
  • ensuring that additional costs aren’t passed on by manufacturers to customers
  • supporting those in poverty to meet any additional costs

The effects of climate change disproportionately impact those experiencing poverty – care should be taken not to exacerbate this.

Policy Mechanisms

Question 4: To what extent do you agree with the policy mechanisms identified? Agree

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

There is a strong need to link measures to tackle poverty and support those least able to mitigate against effects of climate change within the policy mechanisms. This should more strongly be reflected within the strategy. There are also some points specific to children and young people we feel should be given more consideration.

Behaviour change

Children and young people regularly demonstrate that they are willing to make personal changes. We have been inspired by some of the climate related activities we have seen in schools including clothing swaps, eco-clubs, school gardens. Many young people are involved in nature-based activities, some simply to enjoy a connection to nature or others to actively care for this such as through the Scouts, Woodcraft Folk or the Junior Rangers Project.

There are many children and young people taking personal actions where they can and demonstrating knowledge and care on issues like fast fashion, recycling, and the circular economy.[4]

A great deal of emphasis is placed on children and young people making personal changes, sometimes even when adults around them seem unwilling to make changes themselves. Personal changes are only one part of the process.

Most changes need to happen at a more systemic level by governments or industries. The power to make big changes and significantly reduce emissions lies with governments and industries. Those who make, or have made, the most emissions need to bear the most responsibility.

As discussed above there are additional challenges for those experiencing poverty which could make changing behaviour harder – this may be because of limited access to educational opportunities or resources.

There is an important distinction to be drawn between a foodbank and a ‘community fridge’ model. A ‘community fridge’ is where volunteers collect food that will otherwise go to waste and make this available to anyone who wants it. There have been suggestions that these fridges, which are open to all, could help to address foodbank shame.[5] However, they cannot replace foodbanks, which aim to ensure families receive the right types of nutritious food in sufficient quantities. This is especially important for children as they are developing. 

Challenging stigma is one of the most important elements. – Many families report that there are complex feelings of shame surrounding the use of foodbanks[6] and working to address this should be an important consideration.

This is also a dynamic which has been seen with school uniform. A great number of schools have ‘uniform banks’ where old items are brought in and donated and anyone can take new items. We have heard that those who are experiencing poverty and most likely to benefit from these initiatives are not accessing them in the same way as more middle-class families as there is shame in using hand-me-downs. Some schools have taken efforts to address this.[7]

We would like to see the strategy incorporate a stronger understanding of the impacts of poverty and the need to address the additional barriers faced. Moving to a circular economy needs to sit alongside other measures such as having a ‘cash first’ approach or increasing family benefits– we see these as an essential component in implementing a circular economy and changing behaviours.

Skills and education –

This section seems quite focused on skills needed for workforce and economy and while it references education reform it doesn’t specifically mention children and young people. We think this is an oversight in the strategy and that improving climate focused education of children and young people should have an important place within the strategy.

A survey by the Scottish Youth Parliament showed that nearly two thirds of young people had not heard of the circular economy.[8] Which shows the need for education in this area.

The lack of education on climate change is something which children and young people frequently talk to us about. Whilst there is a Learning for Sustainability Plan[9] more should be done to ensure its implementation.

Children and young people clearly want to learn more about environmental issues, including biodiversity loss and what they can do to contribute to improving this.  Our Young Advisors Group (YAG) wanted young people to be involved in decisions that were made on these issues and highlighted that it’s ‘our future land’. They felt they needed more information to be able to do this;

“There was not enough education provided so I went out and researched it, I didn’t get taught in school” (CYPCS Young Advisor).

They said that PSE could play a major role including teaching about social responsibility. They reflected that if you take higher level biology or geography then the subject will be covered but often this is not in a context applicable to Scotland, it might instead highlight species and habitat loss in other countries. In these subjects, we’re told things are treated as facts to learn for exams and our YAG comment that it is hard to share opinions on this in class. They want more education on what they can do in everyday life – ‘teach us how we can help’.

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

Priority Sectors:

The Built Environment        

We agree with plans to consider the functioning of a circular economy within the built environment, but we need to ensure that this is done alongside an understanding of the impacts this might have on the housing crisis. There is a desperate need for more affordable and public owned housing in Scotland. We need to consider the long-term impacts that the circular economy could have and mitigate against them from the start – consider what impact this will have on developers – will they be less likely to build affordable homes? Will costs be passed on to tenants? Could this further exacerbate the housing crisis? These questions should be addressed by the strategy.

Textiles

The Members of the Scottish Youth Parliament have done some really great work around the circular economy and sustainable fashion. They were concerned that less than 1% of clothing is currently being recycled. They found that young people would shop in a more sustainable way for clothes if this was more affordable and available.

One member stated –

‘Funding should be available to support the development of sustainable fashion and technology to make this an accessible and viable option, and to enable young people to shop in a more sustainable way.’[10]

‘It is interesting that many young people said they are restricted by the cost of items and that they would buy more sustainably if it was cheaper to do so – it’s important that sustainable fashion is made more accessible for young people as it allows us to be a part of a more environmentally friendly society.’ [11]

The Food System

Under Article 27 of the UNCRC children have a right to a decent standard of living which includes the right to nutritious food. In Scotland there is a great deal of food waste while children go hungry or do not get the right sort of food. Food is wasted from shops and restaurants, and we would like to see that there are obligations placed on businesses to limit waste. Again, when it comes to tackling poverty we believe that a ‘cash first’ approach is the best solution which allows families to make choices.

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

While we agree it makes sense to prioritise certain sectors and then move to other sectors. We think that the next most important sector to focus on would be electrical goods and technology reuse[12].

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?

We would like to see additional focus on the impacts of the policy on those experiencing poverty and the ways that any negative impacts can be mitigated. This should include monitoring and evaluating feedback from children and young people experiencing poverty to understand the impacts that the policies have on them.

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

Moving towards a circular economy has a number of interactions and impacts on the rights of children and young people.  A child’s rights impact assessment (CRIA) of the strategy should be so that these interactions can be properly identified. Where there is potential for a negative impact on rights mitigations should put in place.

We note that the Scottish Government have stated that they ‘do not anticipate specific impacts from the publication of the Strategy on the rights and wellbeing of children and young people’. We disagree. A similar statement was made when the Circular Economy (Scotland) Bill was introduced.[13]

The strategy will serve as the guiding principles of transition to a circular economy it is right that best practice is followed and that rights interactions and potential violations are properly explored at the outset and every stage, particularly with regard to what we have said throughout in relation to the impact on child poverty. The strategy sets the standards and key considerations for implementation – it guides implementation and must be done in the right way.

Scotland (along with the rest of the world) faces a nature-climate crisis this is a children’s rights issue and as such a rights-based approach should be taken.

The UN Committee on Rights of the Child highlighted the importance of these issues in its most recent General Comment No. 26 (2023)[14] which focused on children’s rights and the environment:

‘The extent and magnitude of the triple planetary crisis, comprising the climate emergency, the collapse of biodiversity and pervasive pollution, is an urgent and systemic threat to children’s rights globally.’

An example of where we see that the strategy could have unintended consequences is the proposal that there may be the creation of a ‘right to repair’ for textiles. This may mean that items become more expensive and less affordable if the costs of are passed on to consumers, with a disproportionate impact on those in poverty. A CRIA could identify this and consider mitigations such as clothing vouchers or grants etc.

We also feel that it is important the voices and views of children are properly incorporated in this process. The participation of children and young people should be part of the strategy.

As stated by one MSYP –

‘I also believe it is important that young people are involved in general discussions about the circular economy. I was surprised by how few young people have an understanding of the term considering its importance in the environmental actions our government is currently debating.”

We believe that this is important for the successful implementation of the strategy and they should help to inform the strategy so that it can work in a way that is realistic and meaningful for young people.


[1] draft-circular-economy-strategy-scotland.pdf

[2] Official child poverty statistics: Nearly a quarter of Scotland’s children still in poverty  | CPAG

[3] On fairness and a low carbon economy: a statement – Just Transition Commission

[4] 12 ways out of fast fashion – Scottish Youth Parliament (syp.org.uk), Delivering-Scotlands-circular-economy-Scottish-Youth-Parliament-response-August-2022.pdf (syp.org.uk)

[5] ‘Dignity and choice’: community pantries spring up as UK cost of living soars | UK cost of living crisis | The Guardian

[6] ‘Counteracting Stigma-Power: An Ethnographic Case Study of an Independent Community Food Hub’ – 2023 – Counteracting Stigma-Power: An Ethnographic Case Study of an Independent Community Food Hub – Kerry Brennan-Tovey, Elisabeth M. Board, John Fulton, 2023

[7] School and cluster run uniform banks | CPAG

[8] Delivering-Scotlands-circular-economy-Scottish-Youth-Parliament-response-August-2022.pdf

[9] Learning for sustainability: action plan 2023 to 2030 – gov.scot (www.gov.scot)

[10] #WhatsYourTake report: Circular Economy – ‘Disposing of a Disposable Society’ – March 2020

[11] Fashion is costing our Earth – Scottish Youth Parliament

[12] A deep dive into E-waste | How to Waste Less

[13] Child Rights and Wellbeing Impact Assessment (CRWIA) For Circular Economy (Scotland) Bill

[14] CRC/C/GC/26: General comment No. 26 (2023) on children’s rights and the environment with a special focus on climate change | OHCHR

Back to top