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Scottish Government Consultation - Changes to Waste Management Services

North Ayrshire Council · 3 June 2025
Back to Cabinet — 3 June 2025 and its agenda

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NORTH AYRSHIRE COUNCIL   
03 June 2025 
Cabinet
Title: Scottish Government Consultation: Changes to waste
management services and the Call for Evidence (CfE) on the
potential extension of the upcoming ban on landfilling
biodegradable municipal waste. 
Purpose: To advise Cabinet of the Scottish Government Consultation on
possible changes to household recycling collection services and
the Call for Evidence on the potential extension of the upcoming
landfill ban, and to seek Cabinet approval for the submission of
the proposed response. 
Recommendation: That Cabinet: 
a) Notes the ongoing consultation and Call for Evidence; 
b) Grants authority to the Head of Service (Neighbourhood
Services) to submit the Council’s response (Appendix 1
and 2); and 
c) Notes that responses to the consultation and Call for
Evidence are also being submitted by other local
authorities and COSLA; and 
d) Notes that further updates will be brought to Cabinet in the
event that the Scottish Government introduce a change to
the household recycling collection services detailed within
the consultation. 
1. Executive Summary 
1.1 On 25 March 2025 Scottish Government launched the Changes to Waste Management
Services online public consultation along with a Call for Evidence (CfE) on the potential
extension of the upcoming ban on landfilling biodegradable municipal waste. 
1.2 The Changes to Waste Management Services public consultation seeks to collect
views on: 
• The approach to textile recycling, including whether to make kerbside collection of
textiles by local authorities a mandatory service.
• The current approach to the rural food waste exemption and whether that should
continue in its current form, be amended or be discontinued.

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1.3 The Call for Evidence (CfE) on the potential extension of the upcoming ban on
landfilling biodegradable municipal waste (household and commercial) seeks to support
consideration of extending the landfill ban to include non-municipal biodegradable
wastes. 
1.4 This report seeks approval for submitting the draft response to the consultation
included at Appendix 1 and the draft Call for Evidence response provided at Appendix
2. 
2. Background 
2.1 The Scottish Government’s Circular Economy & Waste Route Map was published in
December 2024. The route map set out actions to develop a more circular economy in
Scotland, supported by new powers set out in the Circular Economy (Scotland) Act
2024. The Route Map sets out the strategic direction for delivering a system-wide,
comprehensive vision of Scotland’s circular economy from now to 2030. 
2.2 The measures in the Route Map are grouped under four strategic aims, which reflect
the span of the waste hierarchy: 
• Reduce and reuse;
• Modernise recycling; 
• Decarbonise disposal; and 
• Strengthen the circular economy. 
2.3 The Scottish Government Route Map contains 11 priority actions, which are: 
• Publish a Product Stewardship Plan to set out how to tackle the environmental
impact of priority products by 2025/26;
• Develop an intervention plan to guide long-term work on household food waste
reduction behaviour change by 2026/27;
• Develop with stakeholders effective options to implement mandatory reporting
for food waste and surplus by businesses from 2025/26;
• Support the development of a model for regional Scottish hubs and networks for
the reuse of construction materials and assets from 2025-2027;
• Facilitate a co-design process for high quality, high performing household
recycling and reuse services, 2024 – 2026;
• Review of compliance with commercial recycling requirements by 2026;
• Co-design measures to improve commercial waste service provisions,
commencing by 2030;
• Develop a Residual Waste Plan to 2045 by 2027;
• Facilitate the development of a Sector-Led Plan to minimise the carbon impacts
of the Energy from Waste Sector by 2027;
• Develop a circular economy strategy every five years, first one in 2026; and
• Set new circular economy targets by 2027. 
2.4 By 2030, Scottish Government aims to have a high-performing recycling system that
has modernised recycling services for households and businesses across Scotland,
optimised the performance of collection services, and can recycle most waste types to
maximise diversion of waste from disposal.

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2.5 Increasing the number of materials recycled and the proportion of these recycled is
expected to deliver carbon reductions, reduce the environmental impacts associated
with extracting new raw materials, and create a range of important economic
opportunities to reprocess and reuse materials. 
2.6 The Circular Economy & Waste Route Map to 2030 prioritises the co-design of a
new Code of Practice for household waste recycling under the strategic aim to
Modernise Recycling. The co-design process to design the new Code of Practice will
include key stakeholders from Scottish Government, COSLA, SOLACE and the Local
Authority Waste Management Officers Network, as well as other relevant parties. 
2.7 Under the Circular Economy (Scotland) Act 2024, adherence to the new statutory Code
of Practice will become mandatory for local authorities, however, Scottish Government
and COSLA have agreed that the new Code of Practice will be subject to the prior
agreement of the COSLA Environment and Economy Board. 
2.8 The main goal of the co-design process is to ensure the new mandatory
Code of Practice sets out an approach to increase recycling that is practical, effective,
and feasible for local authorities and other service providers, rather than enforcing a
rigid, top-down model. 
2.9 The co-design process aims to ensure the new Code of Practice is adaptable,
considers differences in geography, demographics, housing, and existing
infrastructure, while providing access to consistent recycling services, but recognising
that different areas may require different approaches to service delivery. 
2.10 This consultation is only one part of the engagement to establish an evidence base on
which to co-design the new Code of Practice. The policy areas that are being consulted
on are being explored in the context of the development of the new statutory Code of
Practice and it may form part of the co-design process, depending on the findings of
this consultation. Depending on future policy decisions, legislative change may also be
required out with the new statutory Code of Practice. 
2.11 The Changes to Waste Management Services consultation focuses on the approach to
textile recycling, including whether to make kerbside collection of textiles by local
authorities a mandatory service and the current approach to the rural food waste
exemption and whether that should continue in its current form, be amended or be
discontinued, and the approach. 
Household Collection of Textiles 
2.12 The Council in partnership with a third-party organisation currently collects a wide
range of textiles (clothes, shoes, hats, towels, linen, curtains, belts etc.) via a network
of 38 textile banks throughout the area and the organisation that collects them also
works closely with charities who benefit from the textile banks. The service also
promotes the use of over 20 charity shops throughout the area for textile reuse, which
rely on donations from the public.

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2.13 There is no cost to the Council for the current service for the provision and collection of
textile banks across North Ayrshire. A small amount of income is also received from the
textile bank provider. 
2.14 A new requirement for local authorities to provide a mandatory kerbside collection of
textiles is proposed within the consultation. This new requirement could potentially add
significant unbudgeted capital and revenue costs to the Waste Service unless
additional funding was provided to support the introduction of a new textile collection
service. 
2.15 Additional capital costs would be incurred for vehicles, containers and any
infrastructure changes required at our waste sites to store textiles in a dry and clean
manner, to maximise their ability for reuse. Additional revenue costs would be incurred
for employees, fuel, vehicle maintenance costs, as the collection of textiles is not a
waste stream that could be easily integrated within our current kerbside collection
system. 
2.16 Consideration would need to be given to the collection method utilised, as most
councils already have a well-used network of textile banks and charity shops in place.
Research and modelling would need to be carried out to establish if a kerbside textile
collection service would be more efficient and effective than our current approach, and
what the net cost and net carbon impact of introducing a new kerbside textile collection
service would be, particularly in more remote areas. 
2.17 The proposal could potentially have a significant impact on local charitable
organisations and charity shops who rely on public donations of textiles for resale,
which promotes their reuse. Mixed kerbside collections could reduce the textile material
quality compared to donating to charity shops, impacting on textile reuse levels. 
2.18 The draft responses to the consultation questions that relate to the proposed
introduction of a new requirement for local authorities to provide a mandatory kerbside
collection service of textiles is provided in Appendix 1, Questions 1 to 13 for the
consideration of Cabinet. 
Rural Food Waste Exemption 
2.19 The Council currently provide a fortnightly comingled food and garden waste collection
service (brown bin) to all households on the mainland and Cumbrae. 
2.20 An exemption currently applies to remote rural areas and islands, which includes the
Island of Arran, as it was not deemed environmentally and economically practical to
provide a segregated food waste collection service to these areas across Scotland. 
2.21 The Environmental Protection Act 1990, amended by the Waste (Scotland) Regulations
2012, require local authorities to provide segregated food waste collections to
householders and separately requires all food businesses producing more than 5kg of
food waste a week to ensure they separate their food waste for collection, unless the
rural exemption applies. 
2.22 The proposals within the consultation relate to the current rural food waste exemption
and whether that should continue in its current form, be amended or be removed.

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2.23 The proposed amendment to the exemption in the consultation relates to changing the
basis for the areas and post codes covered from the Scottish Government’s 6-fold
Urban/Rural Classification of 2009-10 to the Scottish Government Urban Rural
Classification 2022. The exemption operates by not requiring local authorities to
provide a receptacle for separate collection of food waste if properties are located in
areas designated as ‘remote small towns’, ‘accessible rural areas’ or ‘remote rural
areas’. 
2.24 The 2022 classification includes fewer postcodes classified as rural due to
demographic changes, such as population increase and areas of new building.
Adopting the 2022 classification would result in fewer postcodes being eligible for the
exemption. 
2.25 On review of the proposed use of the 2022 classification, this would not require any
changes to the current waste collection service provided by the Council. 
2.26 A proposal to remove the food waste exemption would require a separate food waste
collection service to be provided to all households on Arran. This would have significant
capital and revenue budget implications as well as ferry capacity issues for the Council,
which would need to be modelled and assessed for viability. 
2.27 Additional capital funding would be required for new vehicles and containers. The site
infrastructure that would be needed at the Arran Waste Transfer Station to facilitate the
separate storage of food waste in accordance with animal by-product legislation would
be challenging to create, due to space constraints within the site. A detailed feasibility
study would be needed to determine the cost and viability of the existing site, should
the proposal to remove the exemption be taken forward by Scottish Government. 
2.28 The proposal would potentially increase recycling performance, however, additional
revenue budget would be required for employees, fuel, vehicle maintenance costs and
transport costs, albeit there would be a net reduction from existing waste processing
costs. There is no current on-island solution for processing food waste, and this would
need to be transported for processing to the Council’s contractor in South Lanarkshire.
Additional funding would be needed for the capital and revenue costs required for
implementing the proposal if this service was required by Scottish Government, which
would need to be based on detailed modelling to assess the net cost and net carbon
impact of the proposed change. 
2.29 The draft responses to the consultation questions that relate to the proposals to retain,
amend or remove the current rural food waste exemption is provided in Appendix 1,
Questions 14 to 17 for the consideration of Cabinet. The draft responses to the general
consultation questions are provided in Appendix 1, Questions 18 to 23. 
Call for Evidence on Extending the Landfill Ban 
2.30 From 31 December 2025 a ban on landfilling biodegradable municipal waste comes
into force. When landfilled, biodegradable waste breaks down to produce methane, a
greenhouse gas that is around 28 times more potent than carbon dioxide. 
2.31 Municipal biodegradable waste includes waste from households, such as paper and
cardboard, food waste, wood etc, and waste that is similar in nature and composition to

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waste from households, which includes the commercial waste that the Council collects
from businesses. 
2.32 The Council has been prepared for the ban on the landfill of the biodegradable
municipal waste that it collects for many years and has not relied on landfill as a
disposal solution since before 2020, as we moved towards a more environmentally
sustainable solution through the Clyde Valley Residual Waste Partnership. The
Council’s own landfill site in Shewalton, Irvine closed for the acceptance of waste in
March 2018. 
2.33 The proposals within Scottish Government’s Call for Evidence on the potential for
extending the landfill ban to include non-municipal biodegradable wastes has limited
direct impact on the Council, as we only collect or manage a small amount of waste
that is defined as non-municipal biodegradable waste, which is more relevant to the
private waste management industry. The proposals include adding sorting residues
from the mechanical treatment of wastes to the ban, which the Council does not
manage, however the contractors that process our waste manage this as a by-product
from their processes. 
2.34 The non-municipal biodegradable waste types that are discussed in the Call for
Evidence that the Council collects or manages includes ‘mixed construction and
demolition wastes’, that can arise from activities carried out by Building Services.
Larger construction and demolition projects initiated by Property Management and
Investment carried out by private contractors may be impacted by extension of the ban,
however these types of contracts already include clauses and measures to maximise
the reuse and recycling of construction and demolition waste to minimise any waste
that goes to landfill. 
2.35 The Call for Evidence seeks to gather evidence on other wastes (such as mattresses),
including those that are non-biodegradable, that could be banned from landfill to move
the management of these wastes further up the waste hierarchy and to reduce the
environmental impact of their disposal. 
2.36 The draft responses to the Call for Evidence questions that relate to the potential
extension of the upcoming ban on landfilling biodegradable municipal waste is provided
in Appendix 2, Questions 1 to 24 for the consideration of Cabinet. 
3. Proposals 
3.1 That Cabinet: 
a)  Notes the ongoing consultation and Call for Evidence; 
b)  Grants authority to the Head of Service (Neighbourhood Services) to submit the
Council’s response; 
c)  Notes that responses to the consultation and Call for Evidence are also being
submitted by other local authorities and COSLA; and 
d)  Notes that further updates will be brought to Cabinet in the event that the Scottish
Government introduces a change to the household recycling collection services
detailed within the consultation.

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4. Implications/Socio-economic Duty
Financial
4.1 There are no financial implications resulting directly from submission of the consultation
response or Call for Evidence response, however, there may be financial implications
for the Council if Scottish Government introduced a requirement for the mandatory
kerbside collection of textiles or removed the current derogation for the collection of
food waste in remote rural areas. 
Human Resources 
4.2 None. 
Legal 
4.3 There are no direct legal implications of the response itself, however, depending on
future Scottish Government policy decisions, future legislative changes may be
required out with the Household Recycling Code of Practice. 
Equality/Socio-economic 
4.4 There are no equality/socio-economic implications resulting directly from submission
of the consultation response. However, it is unclear if such implications could arise
from the proposals in the consultation and Call for Evidence. The Scottish
Government would be required to undertake the necessary impact assessments in
relation to the introduction of any additional legislation. 
Climate Change and Carbon 
4.5 There are no climate change and carbon implications resulting directly from submission
of the consultation and Call for Evidence response. However, potential benefits for
Climate Change and carbon reduction could potentially arise from the proposals in the
consultation and Call for Evidence. 
Key Priorities 
4.6 None. 
Community Wealth Building 
4.7 None. 
5. Consultation 
5.1 The proposed response has been informed through consultation with Officers of the
Council and COSLA.       
RUSSELL McCUTCHEON
Executive Director (Place) 
For further information please contact Thomas Reaney, Head of Service (Neighbourhood
Services) 
Background Papers
0

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Page 1 of 16 
Appendix 1
Scottish Government Consultation
Changes To Waste Management Services
Closing Date: 17th June 2025
Household Collection of Textiles - 13 questions
1. Do you consider your current options for textile recycling to be efficient?
☒ Yes
☐ No
☐ Don’t Know
2. Do you consider your current options for textile recycling to be accessible?
☒ Yes
☐ No
☐ Don’t Know
3. If you do not consider your current options for textile recycling to be efficient
and/or accessible, what improvements would you recommend?
Please provide your answer here. 
4. Do you believe household collection of textiles would provide benefits to
householders?
☒ Yes
☐ No
☐ Don’t Know 
Not applicable.

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Page 2 of 16 
5. What potential benefits do you consider household collection of textiles would
provide to householders?
Please provide your answer here. 
6. Do you believe household collection of textiles should be a service supplied by
local authorities? Extra note: A mandatory service would be a statutory requirement
for all local authorities in Scotland to collect textiles separately as part of their waste
collection services at household kerbsides. This may require a separate household
recycling bin. (Strongly Agree/Agree/Neither Agree nor Disagree/Disagree/Strongly
Disagree)
☐ Strongly Agree
☐ Agree
☐ Neither Agree nor Disagree
☐ Disagree
☒ Strongly Disagree
Where householders are disposing of textile waste through residual/general
waste, a separate household waste collection service for textiles would provide
additional capacity and space for non-recyclable waste material within their
residual/general waste containers, however this would potentially require
householders receiving another wheeled bin container, where many
householders do not want more wheeled bins, due to lack of storage space at
their properties.
The other option is to have a separate bag collection using a ‘milk-round’ type
collection approach, however this option is likely to be sporadically used and
therefore most likely to inefficient and not cost effective to operate, resulting in
higher costs. 
Research and modelling would need to be carried out to establish if a kerbside
textile collection service would be more efficient and effective than our current
approach, and what the net cost and net carbon impact of introducing a new
kerbside textile collection service would be, particularly in more remote areas.

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Page 3 of 16 
Please provide your answer here. 
7. If collections of textiles from households are not a service supplied by local
authorities, do you think there should be a requirement for all local authorities to offer
textile recycling through Household Waste Recycling Centres or other bring
facilities?
☒ Yes
☐ No
☐ Don’t Know
Please provide your answer here.
8. What is the estimated number of textile items you recycle/dispose of each year?
☐ I don't recycle my textiles
☐ 1 – 5
☐ 6 - 15
☐ 16 - 30
Most councils already provide a wide network of textile banks throughout their
area. Research and modelling would need to be carried out to establish if a
kerbside textile collection service would be more efficient and effective than the
current approach, and what the net cost and net carbon impact of introducing a
new kerbside textile collection service would be, particularly in more remote
areas of Scotland.
If this was a new requirement then it could potentially add significant unbudgeted
capital and revenue costs to local authorities, unless additional funding was
provided to support the introduction of a new textile collection service, potentially
through the widening of Extender Producer Responsibility to include textiles.
The proposal could potentially have a significant impact on local charitable
organisations and charity shops who rely on public donations of textiles for
resale, which promotes their reuse. North Ayrshire has areas of high deprivation,
and many people rely on charity shops for obtaining quality low-cost clothing.
Yes, as most local authorities already provide the ability for residents to deposit
textiles in their Household Waste Recycling Centres or at other bring facilities,
however, this may be more difficult and challenging in remote rural areas and
islands. The implications of this potential additional requirement on local
authorities should be explored further through the co-design process for the
Code of Practice on Household Recycling.

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☐ 31 - 50
☐ Over 50
☐ Don't Know
This question is not relevant to a local authority. 
9. What services are currently available in your local authority area to recycle or
dispose of textiles?
☒ Local Textile Bank in supermarket / car park
☒ Charity Shops – In Store
☒ Charity Shops – Household Collection
☒ Household Waste Recycling Centre
10. What services do you currently use in your local authority area to recycle or
dispose of textiles?
☐ Local Textile Bank in supermarket / car park
☐ Charity Shops – In Store
☐ Charity Shops – Household Collection
☐ Household Waste Recycling Centre
☒ Other
If other, please provide your answer here. 
11. Do you foresee any barriers or unintended consequences to local authority
collection of textiles at the kerbside becoming a statutory service?
☒ Yes
☐ No
☐ Don’t Know
This question is not relevant to a local authority.

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Page 5 of 16 
Please provide your answer here. 
12. If your local authority offered household collection of textiles, how likely are you
to utilise this service?
☐ Very likely
☐ Somewhat likely
☐ Somewhat unlikely
☐ Very unlikely
☐ Not sure
This question is not relevant to a local authority. 
Yes. If this was a new requirement then it could potentially add significant
unbudgeted capital and revenue costs to local authorities, unless additional
funding was provided to support the introduction of a new textile collection
service, potentially through the widening of Extender Producer Responsibility to
include textiles.
Research and modelling would need to be carried out to establish if a kerbside
textile collection service would be more efficient and effective than the current
approach, and what the net cost and net carbon impact of introducing a new
kerbside textile collection service would be, particularly in more remote areas of
Scotland.
There over 20 charity shops in North Ayrshire which require a throughput of
good quality clothes/textiles as well as other saleable goods. Any statutory
service needs to ensure that these outlets which support the most vulnerable in
society are not unduly impacted by any new collection service.
As noted within the summary of the European Clothing Action Plan (ECAP)
report that is highlighted in the consultation document, there is a significant
element of textiles which would be of low value. Further research is required to
ensure that there are viable markets for any additional textile materials collected.

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13. Do you have any additional views, regarding household collection of textiles or
what you would expect a useful service to look like?
Please provide your answer here. 
Rural Food Waste Exemption - 5 questions
14a. Are you located in an area with a rural food waste exemption?
☒ Yes
☐ No
☐ Don’t Know
14b. What is your preferred approach to the rural food waste exemption in the
future?
☐ Keep it as it is
☐ Remove it
☒ Other
If other, please provide your answer here.
The Council would have concerns around the risk of collecting low value textile
materials with limited markets, which would impact the sustainability and
effectiveness of any service. Research and modelling would need to be carried
out to establish if a kerbside textile collection service would be more efficient and
effective than the current approach, and what the net cost and net carbon impact
of introducing a new kerbside textile collection service would be, particularly in
more remote areas of Scotland.
Our position with regards to the rural food waste exemption is that it should be
discussed as part of the co-design work on the new Code of Practice with local
authorities. There will be specific and potentially unique challenges of
implementing food waste collection services and animal by-product compliant
waste bulking and processing facilities in remote rural areas, such as islands. 
There will be significant additional revenue and capital costs for local authorities
by implementing food waste collections in remote rural areas and this would
need to be modelled, as well as the net carbon impact of any proposed change. 
Some remote rural areas may not have the necessary infrastructure to be able
to support managing an additional waste stream (bulking facility space, available
waste capacity and the ability to expand) and this would need to be explored
further with each local authority.

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15. If your local authority were to offer a kerbside food waste collection service,
would you be likely to opt-in?
☐ Very likely
☐ Somewhat likely
☐ Somewhat unlikely
☐ Very unlikely
☐ Not sure
This question is not relevant to a local authority.
16. If you live or operate a business in an area in which the rural food waste
exemption is used, what do you currently do with your food waste?
☐ At-home composting
☐ Take it to local recycling centre
☒ Other
If other, please provide your answer here. 
This question is not relevant to local authorities. As a local authority we promote
and provide a comingled food and garden waste collection service except in
areas which have an exemption from food waste collections, which only relates
to the Island of Arran. 
In these exempt areas business will mainly dispose of their food through their
residual/general waste collection services, although there may be some
businesses who have implemented other adaptation or mitigating systems to
reduce and manage their food waste, such as internal composting equipment for
coffee grounds, plate waste from small-scale hotels, cafes and restaurants. 
The Council has been working with 3rd sector organisations and local
businesses on Arran to explore and support options for both food waste and
organic waste treatment on the island, however the cost of implementing on-
island facilities has been prohibitive.

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Page 8 of 16 
17. Do you have any other views regarding the rural food waste exemption?
Please provide your answer here. 
Adopting the Scottish Government Urban Rural Classification 2022 would result
in more postcodes being eligible for service in rural areas, although on review of
the map provided within the consultation, all islands would still be exempt.
If the rural classification was to be further altered, or the exemption was
removed, additional animal by-product compliant waste treatment facilities would
be required across rural and Island areas, whilst taking into consideration that
the original exemptions were created to prevent the positive impact of food
waste recycling being offset by negative impacts of collecting and transporting
waste (including ferry transportation) from rural locations and islands.
There will be significant additional revenue and capital costs for local authorities
by implementing food waste collections in remote rural areas and this would
need to be modelled, as well as ferry capacity and the net carbon impact of the
proposed change.

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All Consultation Topics - 7 questions
18. Equality: Are there any additional likely impacts the proposals contained in this
consultation may have on particular groups of people, with reference to protected
characteristics?
Please provide your answer here.
19. Business and Regulation: Do you think that the proposals contained in this
consultation are likely to increase or reduce the costs and burdens placed on any
business or sector?
Please provide your answer here.
20. Children's Rights and Wellbeing Impact Assessment: Do you think that the
proposals contained in this consultation are likely to have an impact on children’s
rights and wellbeing?
No additional impacts are evident.
Charitable organisations and charity shops may be negatively affected by the
proposed changes to introduce the mandatory collection of textiles at the
kerbside, as they rely heavily on donations from the public. This would also
affect users of charity shops who may rely on them for low-cost clothing. The
proposal would pass on significant additional costs to local authorities to provide
a kerbside collection service for textiles, which instead should be covered
through the extension of existing Extended Producer Responsibility to implement
the ‘Polluter Pays Principle’.
Businesses within an area that is affected by altering the rural food classification
and therefore removing the current exemption, are likely to have the opportunity
to recycle more of their food waste, however access to services in remote rural
areas may be challenging, and this requirement would pass on the additional
costs of providing additional food waste collection services to local authorities.
Whether this increases or reduces their costs may depend on their location, their
existing suppliers and the distance to a licensed waste treatment facility.
There may be on Island solutions which deliver growth opportunities to Island
businesses across food and textiles as well as other waste potentially being
diverted from landfill. The Council are keen to work with and support businesses
within our Islands, although the net carbon impacts of these opportunities along
with the potential costs would require to be modelled.

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Page 10 of 16 
Please provide your answer here.
21. Islands Communities Impact Assessment: Do you think that the proposals
contained in this consultation are likely to influence an island community significantly
differently from its effect on other communities in Scotland?
Please provide your answer here.
22. Fairer Scotland Duty: Do you think that the proposals contained in this
consultation are likely to have an impact in relation to the fairer Scotland duty?
Please provide your answer here.
23. Environment: Do you think that the proposals contained in this consultation are
likely to have an impact on the environment?
Please provide your answer here.
24. Conclusion: Do you have any other comments that you would like to make,
relevant to the subjects of this consultation, that you have not covered in your
answers to other questions?
Please provide your answer here. 
No additional impacts are evident.
A proposal to remove the existing rural exemption for separate food waste
collections in remote rural areas and islands may encourage investment
opportunities for treatment facilities, if capacities and tonnages are appropriate
for investment. This could support the delivery of on-island treatment solutions,
although additional capital and revenue investment would be required to deliver
appropriate collection services.
No additional impacts are evident.
The wider environment potentially could be improved by recycling more food and
textiles, however the net impact of this would need to be modelled, as well as
the net carbon impact of the proposed change.
No further comments.

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Page 11 of 16 
Appendix 2 - Scottish Government
Call for Evidence on Extending the Landfill Ban to non-municipal
waste
1. Which category in the following list best describes you?
☒ Local government
2. If you are replying on behalf of a business or representative organisation, please
advise where your business is located, and an approximate size/number of staff
(where applicable). 
3. Do you produce or handle/dispose of EWC (European Waste Catalogue) 19 12 12
wastes?
☐ Produce from non-municipal sources
☐ Produce from municipal sources
☐ Produce from mixed non-municipal and municipal sources
☐ Handle/dispose of EWC191212 waste produced elsewhere
☒ No, I do not produce or handle/dispose of EWC191212 wastes 
4. If you produce waste from mixed non-municipal and municipal sources, can you
provide data on the proportion of EWC 19 12 12 wastes coming from non-municipal
sources?
☐ Yes (please provide information in the box below)
☒ No 
5. Do you have any data on the composition or characteristics (e.g., biodegradability)
of EWC 191212 wastes sent to landfill at any point over the past 10 years?
☐ Yes (please provide information in the box below)
☒ No
Not applicable.
No, the Council do not produce or handle or dispose of EWC 19 12 12 (sorting
residues from the mechanical treatment of wastes), however our contractors will
handle this waste type as a by-product of their mechanical treatment processes. 
Not applicable.

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6. Are there alternative treatment options available to you for sorting residues
(EWC191212 wastes) that could reduce the environmental impact of managing or
disposing of these wastes? Are there any barriers to adopting alternative treatment
options?
☐ Yes (please provide information in the box below)
☒ No 
7. Do you have any evidence about the need to continue landfilling sorting residues
from the treatment of non-municipal waste?
☐ Yes (please provide information in the box below)
☒ No 
8. Do you agree with the list of non-municipal waste that are likely to be
biodegradable and maybe biodegradable wastes, are there other wastes you
consider biodegradable and do you have evidence on the biodegradability of any of
these wastes that you can share?
☐ Yes (please provide evidence if possible in the box below)
☒ No (please provide details and evidence if possible in the box below) 
9. Are there biodegradable wastes, from Tables 6.2.1 (pg.11) and 6.2.2 (pg.12) or
otherwise, that you think will need to be landfilled in the future? 
No.
Not applicable.
The Council has no evidence of such but is aware that some materials may still
be required to be disposed of at landfill, due to their inability to be directly treated
in an Energy from Waste (EfW) plant, such as items containing harmful, or
hazardous material.
The Council has no direct experience of managing the waste types noted in
Table 6.2.1 of the Call for Evidence.
The Council has no direct experience of managing the waste types noted in
Table 6.2.1 and 6.2.2. of the Call for Evidence.

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10. Our Circular Economy and Waste Route Map noted an intention to identify
priority waste streams to mitigate environmental impacts. Which waste streams
would you consider to be the priority waste streams to divert from landfill? 
11. Are there treatment options available for biodegradable wastes, from Tables 6.2.1
(pg.11) and 6.2.2 (pg.12) or otherwise? Do you have evidence or thoughts on why
these materials continue to be landfilled? 
12. What are the potential positive and negative impacts of not including soil in an
extended landfill ban? 
13. Do you have any views and/or evidence on the suitability of TOC (Total Organic
Carbon), AT4, Dynamic Respiration or loss on ignition tests to determine the
biodegradability of non-municipal wastes? 
14. Do you currently carry out biodegradability testing of non-municipal wastes and if
so, are you able to share any evidence or information on the testing that you carry
out?
☐ Yes, carry out testing and can share evidence/examples
☒ No
15. Would a ban on landfilling mattresses support increased recycling of end-of-life
mattresses?
☒ Yes (Please provide further information in the box below)
☐ No (Please provide further information in the box below)
Mattresses, carpets and furniture, should all be considered as priority waste
streams to be diverted from landfill, due the value they can create within a
Circular Economy.  These waste types should also be considered for inclusion in
an extension to existing Extender Producer Responsibility (EPR) requirements
to implement the ‘Polluter Pays Principle’. 
The Council has no direct experience of managing the waste types noted in
Table 6.2.1 and 6.2.2. of the Call for Evidence.
Continuing to encourage the reuse and recycling of soils is essential due to the
associated carbon benefits as noted within the consultation, however, soil will
still be required for engineering purposes on landfill sites and therefore the
proposal not to include soil in the ban seems a reasonable approach.
The Council has no direct experience around data or evidence of the non-
municipal waste types noted.

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16. Would a ban on landfilling mattresses lead to the diversion of mattresses to
incineration?
☒ Yes (Please provide further information in the box below)
☐ No (Please provide further information in the box below) 
17. If mattresses could no longer be landfilled, what other barriers are there to
increasing the recycling of mattresses? 
Yes, this would allow this material stream to be diverted from landfill or Energy
from Waste through mattress reuse, or through the recycling of the materials
which make up mattresses, such as metals and textiles. 
This approach should be led by the relevant sector which placed the items on
the market, through potentially an Extended Producer Responsibility (EPR)
system, to apply the ‘Polluter Pays Principle’.
Consideration is required around the composition of future mattress waste, as
the sector pivots from using existing materials, such as metals and textiles to
foams, which will require suitable treatment facilities and end markets to enable
them to be recycled.
There are several mattress reuse initiatives in Scotland, including a successful
project in North Ayrshire operated by Cunninghame Furniture Recycling
Company that successfully divert mattresses away from disposal and would
continue to divert from incineration. There are also several third parties, though
limited, who provide recycling solutions for mattresses. 
However, given the vast numbers of waste mattresses produced in Scotland, it is
likely that final disposal at Energy from Waste facilities would be required, as
well as improved reuse and recycling solutions.
The sector which placed the items on the market, should be responsible for
developing reuse, recycling and disposal solutions, through Extended Producer
Responsibility to apply the ‘Polluter Pays Principle’.
Final disposal routes for mattresses would still need to be considered, as it is
unlikely that all, or the majority of mattresses, could be reused or recycled by
third parties, due to the low value of the materials when recycled. Limited
capacity to treat the significant number of mattresses produced in Scotland
would require various solutions to manage that waste stream. Support would be
required to enhance the value and markets for the recyclable materials within
mattresses, to enable the recycling supply chain to deliver a sustainable service
and business model.

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18. What other policies should be considered to encourage the continued diversion
of waste, particularly biodegradable waste, away from landfill? 
19. Are there changes to the Scottish Landfill Tax, or other fiscal leavers such as the
forthcoming Scottish Aggregates Tax, that could incentivise the diversion of wastes
away from landfill, particularly biodegradable wastes that will not fall under the landfill
ban? 
20. What could the Scottish Government do to incentivise investment in alternative
treatment infrastructure? 
21. If further waste streams were to be included in the landfill ban, what timescale for
implementing the ban would allow for industry preparations? 
22. Are you able to share information about the potential costs associated with
diverting waste to alternative treatment options for the wastes detailed here
(including for example costs of testing)? (Please provide details and impacts if
possible) 
End markets require to be developed in Scotland to deal with the additional
recyclates. This would support the reduction of emissions by treating locally,
enhancing local investment opportunities and also improve employment
opportunities in Scotland, contributing to a more circular economy.
The Council has limited exposure to Scottish Landfill Tax (SLT), due to having
previously secured a more environmentally sustainable Energy from Waste
solution through the Clyde Valley Residual Waste Partnership, however, the
continuation of the SLT scheme could further incentivise innovative solutions to
divert more waste away from being landfilled. 
Research and pathfinder projects could be funded to secure an understanding of
the benefits both financially and environmentally of new alternative treatment
solutions. These solutions should be considered for utilisation in urban, rural and
island settings.
The Council does not rely on landfill for the management of its waste. The wider
Scottish waste industry that still relies on landfill would need to provide views on
the timescales required for them to find alternative solutions to landfill.
The Council has no information available relating to the potential costs of
diverting the waste types detailed in the consultation to alternative treatment
options.

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23. Do you have any evidence of other, unintended consequences of diverting
waste, particularly biodegradable wastes, away from landfill (such as flytipping)?
(Please provide details and impacts if possible) 
24. Do you have any other comments or evidence that you would like to share on the
potential expansion of the ban on landfilling biodegradable municipal waste? 
The Council does not have any direct evidence of the unintended consequences
of diverting other types of waste away from landfill. There could be a cost impact
for producers of waste, as processing to remove recyclable material and then
sending the non-recyclable elements of waste to Energy from Waste facilities
tend to be more expensive than landfill, although this margin may be reducing
through recent increases in landfill tax, which incentivises producers to find more
cost effective and environmentally sustainable solutions. The availability of
sufficient alternative treatment capacity in Scotland would need to be considered
through capacity modelling.
Waste tourism should be considered if the landfill ban were to be extended,
where the outcomes are that waste types that have limited markets, or they are
of low value, are then diverted from landfill in Scotland to being landfilled in other
parts of the United Kingdom.