Response to Scottish Government Consultation on Charging for Waste and Recycling Collections
Argyll and Bute Council · 18 December 2025
Back to Environment, Development and Infrastructure Committee — 18 December 2025 and its agenda
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ARGYLL AND BUTE COUNCIL ENVIRONMENT, DEVELOPMENT AND INFRASTRUCTURE COMMITTEE ROADS AND INFRASTRUCTURE SERVICES 18 DECEMBER 2025 RESPONSE TO SCOTTISH GOVERNMENT CONSULTATION ON CHARGING FOR WASTE AND RECYCLING COLLECTIONS 1.0 EXECUTIVE SUMMARY 1.1 The council provides a wide range of waste and recycling services to approximately 42,000 households and 4,600 businesses throughout Argyll and Bute. Services include collection of residual waste and recycling for households and businesses, glass collection, food waste collection in the Helensburgh and Lomond Area, and the collection of items that are too large to fit into bins (bulky waste uplifts. 1.2 The council charges for bulky waste collections. The income budget for this service for 2024/25 was £43,101, and actual income was £44,689. 1.3 The council’s per capita costs for waste collection and disposal are already amongst the highest in Scotland. 1.4 The purpose of this report is to outline the response to a Scottish Government consultation that was launched on 13 October 2025 on its commitment to review the charging structure for certain waste and recycling services. The purpose of this review would be to - • understand whether existing charges for these services are appropriate, and • ensure that incentives are appropriately aligned to minimise waste and maximise the use of recycling and reuse services.
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1.5 The closing date for responses was 7 November 2025. Given the importance of ensuring that the council could express its concerns about the proposal, and that the deadline for responses was between meetings of the Environment, Development and Infrastructure Committee it was agreed with the Policy Lead for Roads, Transport and Amenity services, and the Executive Director for Development and Infrastructure services, that a response would be provided by officers, approved by the Policy Lead and retrospectively agreed by the Environment, Development and Infrastructure at its meeting on 18 December 2025. 1.6 The purpose of this report is to seek the retrospective agreement of the committee to the responses provided to the consultation questionnaire.
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ARGYLL AND BUTE COUNCIL ENVIRONMENT, DEVELOPMENT AND INFRASTRUCTURE COMMITTEE ROADS AND INFRASTRUCTURE SERVICES 18 DECEMBER 2025 RESPONSE TO SCOTTISH GOVERNMENT CONSULTATION ON CHARGING FOR WASTE AND RECYCLING COLLECTIONS 2.0 INTRODUCTION 2.1 The council provides a wide range of waste and recycling services to approximately 42,000 households and 4,600 businesses throughout Argyll and Bute. Services include collection of residual waste and recycling for households and businesses, glass collection, food waste collection in the Helensburgh and Lomond Area, and the collection of items that are too large to fit into bins (bulky waste uplifts 2.2 The purpose of this report is to outline the response to a Scottish Government consultation that was launched on 13 October 2025 on its commitment to review the charging structure for certain waste and recycling services. The purpose of this review would be to - • understand whether existing charges for these services are appropriate, and • ensure that incentives are appropriately aligned to minimise waste and maximise the use of recycling and reuse services. 2.3 The closing date for responses was 7 November 2025. Given the importance of ensuring that the council could express its concerns about the proposal, and that the deadline for responses was between meetings of the Environment, Development and Infrastructure Committee it was agreed with the Policy Lead for Roads, Transport and Amenity services, and the Executive Director for Development and Infrastructure services, that a response would be provided by officers, approved by the Policy Lead and retrospectively agreed by the Environment, Development and Infrastructure at its meeting on 18 December 2025.
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2.4 The purpose of this report is to seek the retrospective agreement of the committee to the responses provided to the consultation questionnaire. 3.0 RECOMMENDATIONS 3.1 It is recommended that the Environment, Development and Infrastructure Committee - a) Notes the content of the report, b) Notes the officer response to the recent consultation outlined at Appendix 1 to the submitted report, and c) Agrees to homologate the officer response and note that any additional substantive comments raised by the Committee will be submitted by email to the Scottish Government department that is responsible for the consultation. 4.0 DETAIL 4.1 Currently, local authorities in Scotland may charge for the collection of garden waste or bulky item uplift. The Scottish Government has indicated that they believe that this could potentially discourage recycling and lead to items being improperly disposed of. The proposed review will assess how the existing charges influence the desired behaviours according to the waste hierarchy and whether they provide the best value for local authorities, including achieving the highest quality recyclate. 4.2 Local authorities budget for the delivery of their waste and recycling services, and the Scottish Government understands that removing the ability to charge for some services could remove a revenue stream that supports the delivery of these services. It is possible that the ability to provide some services may be limited, were it not for the ability of local authorities to charge for these services. The interaction of the findings from this survey and wider review of service charging will need to be carefully considered with respect to the development of the new statutory household recycling Code of Practice and, depending on future policy decisions, there may be a need for separate legislative change. 4.3 Argyll and Bute Council charges for the collection of bulky items, but does not charge residents for access to Household Waste Recycling Centres (HWRCs) to drop-off this waste themselves. With regards to Bulky Waste Collections, the charge is for the convenience of collection, rather than on recycling, but also to support those who may not have access to transport or are not physically able to load and unload a vehicle. There are equity considerations to this dynamic, as well as considering whether the ultimate impact is to reduce recycling. During the passage of the Circular Economy (Scotland) Act 2024, these issues were raised, and the potential impacts on local authorities and residents were
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debated. In response, the Scottish Government emphasised the importance of balancing circular economy goals with the financial realities faced by local authorities. The Scottish Government also highlighted the need for a nuanced approach that ensures recycling and waste management services are accessible, equitable, and incentivise the desired behaviours without disproportionate burdens on any stakeholder. 4.4 Responses to this survey will be used to produce a report. Findings will be considered with local authorities and other stakeholders as a part of the co- design process of the household recycling code of practice and may be used to inform consideration of legislative change. 4.5 This survey concerned existing charges only and was not considering the introduction of any new charges for waste services. 4.6 The financial implications of any potential future policy changes that result in the removal of, or changes to charges for garden waste and bulky item uplift will be considered through the financial assessment of the household recycling code of practice and any related secondary legislation. 4.7 The responses provided at Appendix 1 relate to bulky uplifts only, as we do not provide garden waste collection services. They reflect the concerns of officers that the removal of charges for the bulky waste will lead to both loss of income and an increase in demand that could not be met without a significant increase in expenditure. It would also represent a significant shift away from the “polluter pays” principle that underpins many of the improvements that are being made in waste and recycling services in Scotland 5.0 CONCLUSION 5.1 The council already has some of the highest net costs for waste collection and disposal in Scotland. Charges for bulky waste collection services support the financial sustainability of these services. Removal of charges would negatively impact on this and potentially increase demand for this service to unmanageable levels 5.2 The responses to the Scottish Government’s questionnaire reflect our concerns regarding this and are intended to reflect the unique geography and demographics of Argyll and Bute 6.0 IMPLICATIONS 6.1 Policy – none.
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6.2 Financial – the budget for income received from Bulky Waste collection charges for financial year 2024/254 was £43,101, and actual income was £44,689. This would be put at risk if charges were to be removed. The financial implications of any increase in demand is not quantifiable at this time. 6.3 Legal - Councils have a statutory duty under the Environmental Protection Act 1990 to collect household waste. They are permitted to charge for special collections such as bulky uplifts under these regulations. The charges typically apply to large household items (e.g., furniture, mattresses) and do not cover construction or demolition waste from domestic properties. The legal basis for Scottish councils charging for bulky waste uplifts comes primarily from Section 45 of the Environmental Protection Act 1990, which places a duty on local authorities to collect household waste, and the Controlled Waste (Scotland) Regulations 1992, which allow councils to levy charges for certain types of household waste collections, including bulky items. Each council sets its own fees, which vary widely across Scotland (e.g., £15–£76 per uplift depending on the council and number of items). Charges typically apply to large household items (e.g., furniture, mattresses) and do not cover construction or demolition waste from domestic properties. 6.4 HR – none. 6.5 Customer Service – the removal of charges for bulky uplifts would require the redesign of existing business processes. It could also result in significant increases in demand for these services. Additional resources may be required to meet increased demand. 6.6 Risk – none. 6.7 Climate Change - the uplift and processing of municipal waste continues to be the single most carbon consuming activity equating to approximately half (51.4%) of all Council emissions. The council is committed to reducing waste at the source and improve recycling, shifting our focus from disposal to driving better behaviours in how we all produce and manage waste. 6.8 Fairer Scotland Duty – tbc. 6.9 Equalities - protected characteristics – none. 6.10 Consumer Duty – tbc. 6.11 Island Communities – none. 6.12 Children’s Rights and Wellbeing – none.
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Kirsty Flanagan Executive Director with responsibility for Development and Infrastructure Services Policy Lead Councillor John Armour 12 November 2025 For further information contact: Andy Summers, Head of Roads and Infrastructure Services Andrew.summers@arfgyll-bute.gov.uk APPENDICES Appendix 1 – responses to Scottish Government questionnaire