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Susan Evans is Policy Lead at Resource Futures, a B Corp which supports governments, businesses and communities to bring about a circular economy. Richard Claxton is Principal Consultant at Aether, a small consultancy specialising in greenhouse gases and air pollutants.

Susan and Richard were part of the research team that worked on the ClimateXChange project ‘Scottish Landfill Tax: lower rate review’. In a recent podcast interview, they discussed the project report and findings. This blog post is a summary of that conversation.

Why was this research needed in the context of Scottish climate policy?

The Scottish Landfill Tax is a waste policy that has been around for a while. It has two rates. The higher standard rate is over £126 per tonne of waste landfilled. The lower rate is still only about £4 per tonne.

So, while the higher rate has gone up and up, the lower rate has stayed very low and there’s not very much disincentive to send lower-rate materials to landfill.

The original idea was that lower rate materials don’t cause problems in terms of pollution, such as generating a lot of methane emissions or leaching into waterways.

But Scotland’s environmental ambitions and how we look at our environmental challenges have changed. We now look at the whole life impact of the materials we use and we have different objectives through policies like the Circular Economy Act, the Circular Economy Route Map and our national net zero targets.

The vast majority of our carbon emissions are actually caused by the materials that we use. A lot of those impacts take place outside of Scotland, where materials are being dug out of the ground or made into products.

What were the main aims of the project?

The overarching aim was to assess the effectiveness of the lower rate in supporting Scotland’s wider environmental goals.

We also wanted to understand how policy could be changed. What are the options to prevent some of these waste streams getting to landfill in the first place or to divert them from landfill to better use?

How did you do the research?

Firstly, we wanted to understand what materials are mainly being landfilled at the lower rate. We needed to understand what they are, where they come from and which ones have the greatest environmental impacts.

We accessed data from Revenue Scotland on tax returns that private companies have to provide in terms of their waste handling, particularly if waste ends up in landfill. We also used data held centrally by the Scottish Environmental Protection Agency (SEPA) from waste transfer notes. Anyone in the UK producing waste and then sending it onward has to complete a waste transfer note specifying what the waste is and where it is going.

We were then able to unpick this data and classify the different waste types that we’re seeing entering landfills in Scotland.

Secondly, we were able to utilise a tool developed by Zero Waste Scotland called SWEFT (Scottish Waste Environmental Footprint Tool), which allowed us to do a very quick, high-level comparison of the environmental impacts associated with the different waste types that we’d identified.

When we had figured out the top three materials sent to landfill at lower rate, we looked at the options for diverting them from landfill.

We looked at what could be done before these materials become waste. Then, once it’s already become waste and is heading towards landfill, we looked at what can be done at that stage. Even sometimes after it arrives in landfill, it can still be diverted. We looked at those options and did a high-level feasibility assessment.

Finally, we assessed the potential policy options. The focus of this work was the fiscal policy options: how we could adjust taxes, especially here in Scotland with devolved powers, but also looking at wider options.

What are the main findings from the research?

We found that quite a lot of the waste materials going into landfill in Scotland are fairly inert. For example, they don’t degrade into methane, which would be our chief concern from a climate change perspective.

However, quite a lot of these materials or small particles have a broader environmental impact. That could be depleting resources from our natural environment, taking away land use from preferable alternatives or damaging water or air quality.

So, they may not be as obvious as the most polluting and hazardous materials that have been prevented from going to landfills, but there are still environmental concerns.

The main materials that we identified are non-hazardous soils, stones and other small particles. If you imagine getting a giant sieve or a grinder, it’s those types of really small, gritty particles that are ending up in landfills. It could be dust, sands and other minerals from construction sites or from skips when someone’s refurbishing their home.

One slightly concerning finding was that in some cases, there are materials landfilled under the lower rate that shouldn’t be there. Materials are being ground up in order to meet the classification.

Overall, we found that the Scottish Landfill Tax lower rate is only partially supporting Scotland’s current environmental objectives.

There are materials that maybe aren’t that bad in landfill, but further upstream in the production and extraction phases, they’re very damaging environmentally. We still need to pay attention to them as part of a circular economy. Within the report, we suggest quite a few potential diversion options for these materials.

The overarching picture is that there are limited opportunities to divert these materials once they’re already waste and headed to landfill; but many more opportunities to come in earlier and prevent waste from being generated in the first place. That really needs to be part of the future policy approach.

In terms of the fiscal measures to address these materials, especially once they’re already waste, there’s the potential to raise the lower rate of landfill tax. This is something that Wales has already moved on by a few pounds per tonne.

We could also target the more problematic materials, where things are deliberately processed into small particles so they can be landfilled at lower rate without too many questions. These could be targeted with higher taxes specifically to disincentivise that kind of behaviour.

There’s also concern that if one part of the UK raises its landfill tax ahead of the other parts of the UK, there could be materials moved across borders. Having specific measures, like fines, for people who misclassify waste and move it across borders is something that’s also being considered by other parts of the UK at the moment.

The key takeaway is that any fiscal measures would be much more effective as part of a broader policy package addressing how to achieve a circular economy.

Who apart from the Scottish Government might find this research interesting, and why?

We’ve already had some interest from policymakers working on similar topics in Wales. It makes sense other parts of the UK and EU countries would be interested because there are a lot of similarities in the policy environment from pre-Brexit times. Stakeholders managing construction waste might also find the report interesting.

From a data perspective, we’re at quite an interesting turning point. We’ve been reliant on handwritten waste transfer notes until now. But from April 2026 there will be a new digital waste-tracking service.

This new system will allow stakeholders to view and assess real-time data on waste production and waste transfers and their disposal routes. That should make a big difference to our ability to analyse this type of data in the future.

ClimateXChange podcast

This is an amended extract from episode 17 of our podcast: Evidence for climate policy in Scotland – CXC podcast

Project link

Scottish Landfill Tax: lower rate review