Making things last:
Consultation on creating a more circular economy
in Scotland
Response from FSB Scotland
Federation of Small Businesses Scotland
October 2015
Consultation Response
Introduction
The FSB is Scotland’s largest direct-member business organisation, representing
over 20,000 members. The FSB campaigns for an economic and social
environment which allows small businesses to grow and prosper.
FSB Scotland welcomes the opportunity to respond to this consultation on creating
a circular economy in Scotland. In our view, some of the proposals are likely to
present both opportunities and threats to the small business sector. Accordingly,
we have focused our response on issues which have a direct link to small firms.
We have worked closely with the Scottish Government, and others, in recent years
regarding the introduction of new waste regulations. In our view, these
regulations were the most wide-reaching environmental legislative change to
affect small businesses in Scotland for over 20 years. Pausing to consider how well
the new landscape is working should be uppermost in the Scottish Government’s
minds before it considers further changes.
Lastly, in considering its view on the various proposals, the Scottish Government
should reflect upon the current economic context. Evidence suggests that
economic recovery is still fragile and small businesses are facing significant cost
increases in coming years, particularly in relation to new wage levels and pension
requirements. Decisions about creating a more circular economy cannot be
divorced from the pressures facing firms in the existing Scottish economy.
B Reuse
Notwithstanding concerns about potential for criminal activity, the Scottish
Government should explore any barriers to trading previously-owned goods. The
current licensing regime for second hand dealers is managed by local authorities
but generally applied differently across the country. While largely intended to
prevent criminality (e.g. on high-value goods such as antiques), the regime is
probably not appropriate for the recent increase in second-hand /vintage goods
and places an additional, arguably unnecessary, cost on businesses. While we
have called for a more general review of the Civic Government (Scotland) Act
1982, in the interim the Scottish Government could consider how to get the right
regulatory regime for trading previously-owned goods.
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Consultation Response
C Repair
Repairing things more often is likely to offer opportunities to small businesses,
which often thrive because of the knowledge and service they provide on
products. However, the scale and cost pressures facing most small firms can mean
that the cost of repair is rarely able to compete with the price of buying new goods
from a larger retailer.
While it will be difficult to overcome this fundamental challenge, the Scottish
Government could consider how to support repair businesses, perhaps by reducing
the cost of business e.g. premises costs in town centres, or by helping to promote
businesses, by integrating their services into local accredited trader schemes e.g.
Trusted Trader.
While a range of actions are set out in the consultation, the Scottish Government
should also consider the differences between business to business and business to
consumer repairs, since different sectors and markets will require different
approaches.
E Recycling
The introduction of new waste regulations in 2014 was a significant change for
many businesses in Scotland, with many still in the process of adapting to the new
regulatory environment. We welcome the well-planned, consistent approach to
enforcement of the new regulations. However, the next stage of enforcement will
be a critical period in understanding compliance challenges facing small and micro
businesses.
While we note the comments about quality of recyclate, with the extension of food
waste recycling responsibilities still to come, we believe it is important to let the
current approach bed down before changing the rules again, particularly given the
early stage of enforcement of the current regime.
We also believe that it would sensible to review how well resource management
facilities are working for small businesses, since early indications are that the
competitive market envisaged is not yet offering benefits to small firms. As such,
we believe that the Scottish Government should hold back from introducing any
additional recycling obligations for businesses until this has been reviewed.
Understanding the impact on small businesses (particularly the availability and
cost of collection) must be central to any consideration to extend food waste
recycling to rural areas.
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Consultation Response
Lastly, given the considerable cost and disruption associated with the waste
regulations, it makes no sense to place further challenges on small businesses
with the introduction of deposit and return schemes. Rather than moving the
goalposts, the Scottish Government should focus resources on embedding the
existing regime; ensuring it works well for businesses, local authorities and waste
management.
F Producer Responsibility
We have concerns about expanding producer responsibility schemes in Scotland
which would almost certainly increase costs for affected businesses in Scotland,
compared to elsewhere in the UK and the EU. In exploring whether it wishes to
introduce such schemes, the Scottish Government must commit to using the BRIA
process to help determine the right approach, including widespread engagement
with small firms in the affected sectors.
J Communications
We agree that the right approach to communicate with small businesses about the
circular economy is by embedding the message in existing economic development
activity.
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The FSB is Scotland’s largest directmembership organisation. It campaigns
for a better social, political and economic
environment in which to work and do
business. With a strong grassroots
structure and dedicated Scottish staff to
deal with Scottish institutions, media
and politicians, the FSB makes its
members’ voices heard at the heart of
the decision-making process. It is
therefore recognised as one of
Scotland’s most influential business
organisations. The FSB also provides a
suite of services to help our members
reduce the cost and risk of doing good
business – from legal and tax protection
to business banking.
74 Berkeley St, Glasgow, G3 7DS
t: 0141 221 0775
f: 0141 221 5954
e: [email protected]
w: www.fsb.org.uk/scotland
Twitter: @FSB_Scotland