Background – the new draft Climate Change Plan
The Scottish Government published its draft Climate Change Plan (CCP) on 6 November 2025, kicking off 120 days of parliamentary scrutiny. The draft Plan covers the period 2026-2040 across three ‘carbon budgets’, with the goal of reaching ‘net zero’ Greenhouse Gas (GHG) emissions by 2045.
This blog explores the waste chapter in the draft Plan, as part of a series of SPICe blogs on the CCP. It draws on the Net Zero Energy and Transport (NZET) Committee’s call for views ahead of the publication of the draft Plan and considers whether the Scottish Government has followed advice published by the Climate Change Committee (CCC) in May 2025.
Waste emissions to date – big gains, then a plateau
The waste chapter covers emissions from landfill (largely methane) which form the majority of emissions addressed by this chapter, and also emissions from composting, anaerobic digestion, water and sewerage treatment (not considered in this blog).
Emissions from Energy from Waste (EfW) are included in the energy supply chapter and discussed in a previous SPICe blog. However, there is further consideration of EfW in this blog given EfW emissions are impacted by waste management.
Waste sector emissions have fallen dramatically since 1990, by 73%. However, this was largely achieved between 1990 and 2013, with emissions plateauing since then (see Figure 1).
Figure 1: GHG emissions (MtCO2e) from waste in Scotland, 1990-2022. Source: Scottish Government
The overall waste generation trend (excluding construction) has been gradually downward for 2011 – 2023 (see Figure 2). However, there have been challenges in increasing recycling rates in recent years and in tackling carbon-intensive waste streams like food waste.
For 2023, the Scottish recycling rate was 62.2%, only a marginal increase from 2018 (see Figure 3 below). It remains to be seen whether the 70% recycling target by 2025 in the existing CCP will be met.
Figure 2: Scottish waste from all sources generation trend (excluding construction and demolition to show wider waste trends) 2011 – 2023, in tonnes: Source: SEPA
Figure 3: Waste from all sources recycling rate in Scotland, 2011-2023. Source: SEPA
The draft Plan, acknowledging that emissions reductions have stalled, sets out progress made in some areas, such as passage of the Circular Economy (Scotland) Act in 2024, banning unsustainable products (certain single-use plastics and single-use vapes), infrastructure improvements via the Recycling Improvement Fund, and development of UK-wide Extended Producer Responsibility (EPR) for packaging.
Tackling consumption emissions – the ‘bigger picture’ of waste emissions
The Scottish Government’s commitment to develop a circular economy also means tackling consumption emissions, emissions associated with imported goods and services consumed in Scotland (combined with territorial emissions, this is Scotland’s ‘carbon footprint’). The draft CCP recognises this, stating that whilst the CCP focuses on territorial emissions (as do Scotland’s climate targets), “in order to make our contribution to limiting global warming, we must also address the emissions associated with the goods and services we consume…”
Circular economy policy thus seeks to pull levers which relate both to consumption and territorial emissions – an important lens for scrutiny, given waste emissions only show a part of this picture. This is also particularly important given that whilst totalGHG emissions in Scotland on a territorial basis fell by 49.6% between 1998 and 2021, the carbon footprint only fell by 19.9% over the same period. Between 2020 and 2021, Scotland’s carbon footprint increased by 14.6% (see Figure 4).
Figure 4: Comparison of Scotland’s Carbon Footprint with territorial greenhouse gas emissions (MtCO2). Source: Scottish Government
Waste emissions pathway in the draft CCP
The draft CCP sets out that GHG emissions from waste will decline by 58% by 2040, driven by reductions in methane emissions from landfill (see Table 1).
Table 1: Waste Management emissions pathway by Carbon Budget (Table 28 of Annex 3)
MtCO2e | 2026-2030 | 2031-2035 | 2036-2040 |
Waste sector emissions Pathway | 5.9 | 4.3 | 3.4 |
Waste baseline emissions | 6.4 | 5.2 | 4.5 |
Waste total policy reductions | 0.5 | 0.9 | 1.1 |
Policies and proposals in the waste chapter are grouped under four ‘outcomes’ aiming to span the ‘waste hierarchy’:
- Strengthen the circular economy: including through a new Circular Economy Strategy and statutory circular economy targets from 2027.
- Reduce and reuse: including through publishing a Product Stewardship Plan, delivering the Deposit Return Scheme, reforms to Extended Producer Responsibility (EPR) schemes and actions to cut food waste.
- Modernise recycling: including via a new statutory Code of Practice, and statutory local recycling and reuse performance targets
- Decarbonise disposal: including through the forthcoming ban on biodegradable municipal waste going to landfill and increasing landfill gas capture.
Policies are generally drawn from the Scottish Government’s Circular Economy and Waste Routemap to 2030, published December 2024.
Assumptions made in modelling emissions reductions
Table 2 below shows how the draft CCP allocates emissions reductions to ‘sub-sectors’.
Table 2: Waste management sub-sector emissions pathway (Table 29 in Annex 3)
Source | 2026-30 | 2031-35 | 2036-40 |
Landfill | 4.2 | 2.6 | 1.7 |
Compost/Anaerobic Digestion | 0.7 | 0.7 | 0.7 |
Sewage and Water Treatment | 1.0 | 1.0 | 1.0 |
Other | 0.0 | 0.0 | 0.0 |
Total | 5.9 | 4.3 | 3.4 |
There is no further breakdown of reductions from more granular policy areas. The draft CCP sets out that it was not possible to do so, because of complex interactions between policies and also time lags between landfilling waste and the generation of methane from its decomposition.
Instead, an approach was taken where projections of waste streams and treatment were modelled “based on broad assumptions” around waste and recycling levels. The draft CCP does not provide further information on what those assumptions are.
Comparison to the CCC ‘Balanced Pathway’ published in May is also challenging because the CCC includes emissions from EfW in its waste pathway, which (as set out above) the Scottish Government does not.
Strengthening the circular economy – moving up the waste hierarchy?
The draft Plan sets out that the Scottish Government will seek to strengthen the circular economy, including by publishing a Circular Economy Strategy in 2026, and setting statutory circular economy targets by 2027 – both requirements of the Circular Economy (Scotland) Act 2024.
The Scottish Government published a draft Circular Economy Strategy for consultation on 21 October 2025. Under the 2004 Act, the strategy must be prepared with a view to achieving consistency, so far as practicable, with the CCP.
Responses to the NZET Call for Views: Many responses set out the need for the Scottish Government to prioritise circular economy policies which move further up the waste hierarchy i.e. focusing on waste reduction followed by reuse and repair, before recycling, recovery and finally disposal (see Figure 5).
Figure 5: the waste hierarchy. Source: adapted from Scottish Government
Reduce and reuse – tackling problematic waste streams
Key policies aimed at reducing waste and increasing reuse in the draft Plan include:
- A commitment to publish a Product Stewardship Plan for the most problematic products based on their impacts, by 2026. Annex 2 states that priorities for the next five years are anticipated to be textiles, mattresses and “at least one other” product.
- Actions to cut food waste – including introducing mandatory business reporting on food waste, and a new implementation plan.
(The Deposit Return Scheme and packaging EPR are not discussed further here as the detail of these policies was previously scrutinised in the Scottish Parliament during the consideration of secondary legislation).
Zero Waste Scotland told the NZET Committee on 6 May 2025 that it was leading on research supporting the Product Stewardship Plan, but also noted that some of the policy levers in this area e.g. fiscal measures, are reserved. A key question in the circular economy space also continues to be how devolved powers to tackle the sustainability of products can be best exercised under the UK Internal Market Act 2020. There is some further discussion of this in a recent SPICe guest blog on devolution and climate change.
Food waste is a key driver of waste emissions. Recent data shows food waste is also the leading cause of damage to biodiversity stemming from household waste, and second only to textiles for climate change impacts. (Halving global food waste by 2030 is also a commitment of the Global Biodiversity Framework). It is estimated that over 1 million tonnes of food was wasted in Scotland in 2021, accounting for around 6% of Scotland’s carbon footprint that year.
The 2018 CCP committed to reduce food waste by 50% by 2030, to align with UN Sustainable Development Goals. The CCP update in 2021 committed to reduce food waste 33% 2025 from a 2013 baseline. However, 2021 estimates indicate there has been a 5% increase in food waste since 2013.
The CCC May 2025 advice states, “Our UK pathway assumes a 39% reduction in total food waste per capita by 2030 compared to 2021 levels”.
It is notable that whilst the draft CCP includes policies on food waste, there is no specific food waste reduction target proposed, so it is unclear if the draft CCP pathway aligns with the CCC advice.
It is also worth noting that the Scottish Government recently also set out the need to reduce food waste in its first Good Food Nation Plan, published 17 December 2025, which states:
“To help reduce food waste for people and communities, we will work with Zero Waste Scotland to guide long-term work on household food waste reduction behaviour change by 2026/27, focusing on a test of change and improvement approach. This policy will support us in achieving the UN Food and Agriculture Organization (FAO) pledge to halve food waste by 2030”.
Responses to NZET Committee Call for Views:
- Responses called for various approaches to product stewardship e.g. through banning problem products, EPR, environmental charging, Deposit Return Schemes and better product design. Many responses called for action on plastics, food and textiles.
- Some responses emphasised that certain actions in this area would require UK-wide collaboration.
- Many responses called for policies to drive more reuse and repair e.g. supporting community-level infrastructure, skills development and business support.
Modernising recycling – how can Scotland boost its recycling rate?
Key policies in the draft CCP to modernise recycling include developing a statutory Code of Practice for household recycling (aiming to increase consistency of recycling services) and setting statutory local recycling and reuse targets from 2030 onwards.
The CCC May 2025 advice set out that “The Scottish Government should consider accelerating plans to introduce statutory recycling and reuse local performance targets, currently planned from 2030, to increase recycling and waste reduction efforts ahead of the elimination of biodegradable waste going to landfill.”
Responses to the NZET Call for Views: Common themes addressed were the need to harmonise recycling collections, tackle harder to recycle waste streams such as textiles and electrical products, improve food waste collections, and invest in recycling and reprocessing infrastructure.
Decarbonising waste – avoiding ‘lock-in’ to Energy from Waste
The draft CCP notes the forthcoming ban on landfilling BMW from January 2026 as a key policy to reduce landfill emissions.
Biodegradable Municipal Waste (BMW) means waste capable of decomposing such as food, garden waste, paper and cardboard, and includes waste from households and businesses. The ban means that BMW will need to be disposed of through other means than landfill in Scotland – for example incinerated in an EfW plant or exported.
This ban was originally legislated to be from 2021, however, in 2019, the Scottish Government delayed this until the end of 2025, recognising the sector was not ready and enforcing the ban would mean increasing reliance on exports.
Apart from a spike in 2021, significant progress has continued in reducing the landfilling of BMW, with a 73.8% reduction since 2011 (see Figure 6 below).
Figure 6: Waste incinerated in Scotland 2011-2024 (in million tonnes) and total biodegradable municipal waste landfilled.
However, SEPA announced on 29 October 2025 that it will not fully enforce the ban until January 2028, delaying for a further two years, as “not all required treatment capacity and logistics will be in place by the end of this year” and additional EfW plants “are being built and are expected to begin operating between 2026 and 2027 alongside ongoing efforts to reduce, reuse and recycle more waste”.
This delay 2028 is not mentioned in the draft CCP and it is unclear how that might impact on any assumptions about emissions reductions in this chapter.
The CCC Balanced Pathway “assumes the near elimination of biodegradable waste to landfill by 2028 across the UK” including commercial and municipal sources. The Scottish Government has consulted on expanding the ban to commercial waste (a commitment of the 2021 CCP update), but has not yet published a response.
Energy from Waste: Whilst EfW emissions are included in the energy chapter of the draft CCP, EfW emissions are also driven by progress in the waste sector. Diverting waste from landfill to EfW may reduce emissions but does not eliminate them, resulting in emissions ‘moving’ between CCP chapters, meaning it is important to look across these sectors to understand waste emissions as a whole.
Figure 6 above shows how, as the landfilling of BMW has reduced, the incineration of waste has increased, giving an indication of the diversion of waste from landfill to EfW in recent years.
The draft CCP (Table 39 of Annex 3) projects no emissions reductions in EfW in the 2026-2030 (first) carbon budget, but then a 1.3 MtCO2e reduction in 2031-2035 and 1.6 MtCO2e reduction in 2036-2040 (more than the total emissions reductions expected from the whole waste chapter in the second and third carbon budgets)
Annex 3 states that EfW emissions are expected to peak in 2026 due to the landfill ban coming into force. It assumes that 45% of EfW sites (by emissions) install Carbon Capture and Storage (CCS) by 2032, and ignores potential new sites coming online, because the “timing and scale of these is unknown”.
Whilst diverting waste from landfill to EfW is expected to reduce emissions, there have been long-standing concerns that waste policy and procurement of EfW capacity. must seek to avoid ‘lock-in’ to (and potential over-supply of) EfW, in particular if there is uncertainty around when CCS will become viable at scale.
Recognising these concerns, the Scottish Government commissioned an independent review of incineration (the ‘Church review’), which made a number of recommendations in 2022, including:
- no further planning permission should be granted for EfW unless balanced by an equal or greater closure of capacity.
- developing an indicative cap for EfW that declines over time for the amount of residual waste treatment needed.
The Scottish Government accepted these recommendations and committed to integrating them into future waste and planning policy.
The CCC advice published in May 2025 however set out that:
- Emissions from EfW have increased rapidly in the last 10 years and are still on the rise.
- Despite restrictions on new planning permissions, there is scope for a significant increase in Scotland’s EfW capacity even if no further planning permission is granted.
Environmental Standards Scotland (ESS) has also recently published a report following on incineration capacity which found (similarly to the CCC) that:
- The volume of waste incinerated has increased rapidly, a 354% increase since 2011.
- Scotland may soon have an excess of incineration capacity. This has the potential to create ‘lock-in’ effects, where reliance on incineration undermines waste reduction, reuse, and recycling.
- Permitting controls are potentially ineffective, for example, as expansions in capacity can be approved without adequate consideration, alongside the failure of the Scottish Government to develop an indicative capacity cap (see above).
Based on its findings, ESS reached agreement with the Scottish Government (an ‘informal resolution’, published on 9 December 2025) for certain actions, including to publish an updated forecast of incineration capacity in Scotland, and develop an indicative ‘residual waste treatment cap’ in the forthcoming Residual Waste Plan (due in 2027).
This ‘informal resolution’ was published after the draft CCP was published – potentially creating a question of whether these commitments should be reflected in the final CCP.
Responses to the NZET Call for Views: Many responses set out views on the need to control emissions from EfW, alongside concerns about wider potential impacts of EfW on the environment and public health.
Conclusion
The above areas provide some potential areas of scrutiny of, and questions around the waste chapter of the draft CCP, and also seeks to show how circular economy policy extends beyond ‘waste emissions’, to tackling Scotland’s carbon footprint.
Alexa Morrison, SPICe research
Featured image by Professor Ed Hawkins, University of Reading.