Business zoning proposals ‘disastrous’ for Scottish recycling industry

Scotland has been ahead of many when it comes to developing the circular economy.

But I am concerned by the proposals in its new Circular Economy Bill when it comes to business waste collections.

In particular, the Scottish Government has proposed to pilot business waste zones from 2024, with full implementation to follow.

I strongly believe that this would be disastrous for the Scottish recycling industry, has the potential to make legitimate businesses have no choice but to close down, and is potentially contrary to competition law.

Indeed, we saw similar proposals under the Extended Producer Responsibility (EPR) consultation from The Department for Environment, Food, and Rural Affairs (Defra). The Recycling Association, and others including the Environmental Services Association, pushed strongly for Defra to drop the idea of business waste zones.

Instead, Defra has agreed to set up a taskforce to come up with new proposals for business waste under the EPR system. I’d urge Scottish Ministers to take an approach that improves on the current system through a similar taskforce.

One of the biggest problems with business waste zones is that it is anti-competitive. Those who win the contracts for these zones are likely to be those that have the deepest pockets. This will mean that smaller- and medium-sized businesses are likely to be excluded from this process, losing vital contracts that sustain their companies.

Often, many of the smaller companies provide niche services such as being specialists in collection and recycling of automotive waste, printing labels or recyclers of bulk packaging and waste in the food industry. Larger companies are more likely to provide a general collection service for these zones, meaning these specialist materials may not be recycled but instead may go to other treatment processes further down the waste hierarchy such as energy from waste or landfill.

Having generalist business waste zones also means that new and innovative companies are unlikely to enter the market. By preventing innovation and reducing competition, business waste zones will eventually mean collection prices will rise. At a time when costs are rising, it shouldn’t be for policymakers to introduce more costs for companies’ waste services.

One of the arguments for introducing business waste zones is that it would reduce vehicle movements. But even the arguments for this don’t stack up. Firstly, a Deposit Return Scheme (DRS) is being introduced in Scotland and other parts of the UK, inevitably leading to more vehicle movements to collect from DRS collection points, on top of domestic collections. Why is it okay to add more vehicle movements here but say they need to be reduced for business waste?

Additionally, with vehicle route optimisation software, efficient route planning, and the introduction of electric and alternative fuel vehicles, vehicle movements and emissions are being controlled anyway.

Finally, I’d argue that business waste collections are already achieving high recycling rates and producing high-quality material in many cases. This is while also offering low collection prices through competition.

Unlike local authority collections, which need reform to increase quality and recycling rates, the circular economy is best served by maintaining and improving the current system. There are no benefits to be had from dismantling it and starting it again.

The consultation on the Circular Economy Bill is open until 22 August, and I would urge all those who believe in maintaining successful Scottish business waste collections should respond to it.