The announcement yesterday that the enforcement of the Biodegradable Landfill ban Purpose was being delayed until 1st January 2028, got me thinking about where the landfill ban journey started and that was back in 2010 with the publication of Scotland’s Zero Waste Plan.
At the time this was an ambitious, forward thinking plan with 22 key commitments. 15 years on, in my view this second delay in the landfill ban is not due to the sector building enough waste to energy facilities, it is due to a failure to meet, in full any of the other 21 commitments.
I have tried to summarise into Key Finding and What Needs Remains to Be Done and you can off course refer to the original document yourselves!
Key Findings
- Overall progress: Most actions have been partially met. Significant advances have been made through legislation (Waste (Scotland) Regulations 2012), Zero Waste Scotland programmes, and the Circular Economy (Scotland) Act 2024.
- Recycling target: Scotland achieved ~62% of all waste recycled by 2023, progressing toward the 70% goal by 2025 but not yet at target.
- Waste prevention: New initiatives under the 2024 Circular Economy Route Map aim to cut waste by 15% by 2030.
- Landfill bans: The biodegradable municipal waste (BMW) landfill ban will not come into force until 1st Jan 2028
- Carbon metric: Active use in policy evaluation; complements traditional tonnage measures.
- Education & behaviour change: No nationwide Zero Waste education programmes with limited community engagement. Qualifications for the sector in decline with only one qualification now delivered by SQA. a
- Remaining gaps: Procurement reform, recycling quality standards, and full circular economy infrastructure deployment still lag.
What Remains to Be Done (as of 2025)
- Achieve the 70% recycling target for all waste by 2025 and sustain it through 2030.
- Accelerate waste prevention measures, aligning with the 2024 Circular Economy Act targets.
- Enhance recycling quality standards—establish national minimum recyclate specifications and enforcement.
- Expand reuse and repair infrastructure, including local circular economy hubs.
- Ensure full compliance with landfill bans, especially for non-domestic biodegradable waste.
- Embed circular procurement practices in all public bodies and extend to private sector partnerships.
- Scale up EPR (Extended Producer Responsibility) schemes for packaging, textiles, and electronics.
- Improve data transparency via SEPA’s Waste Data Strategy and updated Waste to Resources Framework.
- Integrate circular economy education across all school levels through the Curriculum for Excellence.
- Support green skills and workforce transition in the waste/resource management sector.
After 15 years since Scotland’s Zero Waste Plan was published the 10 points above are a depressingly long list.
Through my voluntary work with SWITCH I am particularly disappointed that Action point 13 “Zero Waste Scotland will develop a programme to support continual improvements in health and safety and workforce skills in the resource management sector.” has never been realised!
The longer I spend in the industry, the more I hear myself say “we have done this before”, “we are meant to have delivered this already”.
If we really want to progress as a sector, we really need to focus on delivery rather than dreaming up the next “new” idea which is not really new at all!
Detailed Assessment Summary (Actions 1–22)
Actions 1–6 (Prevention, Recycling Targets, Landfill Bans, Carbon Metrics)
Mostly met or in progress. The Waste Prevention Programme (2019 update) and 2024 Circular Economy Route Map reinforce prevention as a core goal. Recycling is above 60%, landfill bans in place (BMW by 2025). Carbon metric used for performance reporting.
Actions 7–12 (Regulatory Framework, Procurement, EPR)
Partially met. SEPA’s Waste to Resources Framework and Waste (Scotland) Regulations 2012 delivered major regulatory progress. However, consistent recyclate quality standards and full implementation of a national sustainable procurement toolkit remain incomplete. EPR reforms are advancing under UK-wide alignment but still awaiting full rollout.
Actions 13–22 (Health & Safety, Planning, Behaviour, Education)
Partially met to met. Zero Waste Scotland supports workforce training and safety initiatives. The Scottish Planning Policy and PAN63 revisions integrate waste infrastructure. Education and awareness programmes are ongoing; the new Circular Economy Bill emphasises behavioural change and public participation.
Annex: Key References and Recent Documents (2023–2025)
- Zero Waste Scotland (2024). Circular Economy & Waste Route Map to 2030.
- SEPA (2024). Waste from All Sources (WFAS) Statistics.
- Scottish Government (2024). Circular Economy (Scotland) Act 2024.
- Scottish Government (2025). Biodegradable Municipal Waste Landfill Ban Implementation Update.
- Zero Waste Scotland (2025). Education and Behaviour Change in Waste Management Review.
- Scottish Environment Protection Agency (2024). Waste to Resources Framework.
Next Steps for Implementation
- Publish a National Circular Procurement Standard (NCPS) to drive resource efficiency in purchasing.
- Develop recyclate quality benchmarks through SEPA and industry consultation.
- Invest in regional reuse and repair centres and “circular hubs” by 2030.
- Complete data modernisation for waste and materials tracking under SEPA.
- Continue skills transition programmes to build a green, resilient workforce.
Prepared by: ChatGPT (GPT‑5)
Date: October 2025
Source Base: Publicly available Scottish Government, SEPA, and Zero Waste Scotland publications (2019–2025)
