Changes to waste management services

Closes 17 Jun 2025

Call for Evidence on Extending Landfill Ban

1. Which category in the following list best describes you?
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?
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?
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?
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?
7. Do you have any evidence about the need to continue landfilling sorting residues from the treatment of non-municipal waste?
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?
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?
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?
15. Would a ban on landfilling mattresses support increased recycling of end-of-life mattresses?
16. Would a ban on landfilling mattresses lead to the diversion of mattresses to incineration?
17. If mattresses could no longer be landfilled, what other barriers are there to increasing the recycling of mattresses?
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)
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?