May 2024

DOI: http://dx.doi.org/10.7488/era/4854

Executive summary

Project aims

The Scottish Government’s Heat in Buildings (HiB) Strategy commits all Scottish homes to be net zero by 2045. However, in line with the commitment to a Just Transition, the Government recognises that personal circumstances may, in some cases, make it more challenging for people to meet the requirements of the proposed Heat in Buildings Standard. Personal circumstances include vulnerability criteria related to the occupiers of the dwelling, such as disability, age, or low-income.

This study reviewed how regulations, both in the UK and internationally, have accounted for personal circumstances. Provision made for vulnerable groups for these circumstances included exemptions, extensions or abeyances, support mechanisms such as financial support, amendments or alterations to the standard.

This research will support the Scottish Government’s development of the proposed standard, through considering personal circumstances in domestic buildings, specifically focusing on owner occupied homes and the private rented sector.

We also investigated the impact of including personal circumstances in the regulation. The review has covered relevant low-carbon heating, domestic energy efficiency, housing and transport regulations. Flexibility is often provided within operational regimes without it being explicitly specified within the legislation, and this flexibility was not captured by this study. We also highlight new emerging policy areas to support consideration of how similar regulations could work in Scotland.

Summary of key findings

The study identified 18 international examples of personal circumstances being included in regulations. Six stakeholders from consumer organisations, professional housing sector, government departments and policy groups were interviewed to provide insight on regulations identified through the study. Our key findings are:

• There is limited evidence of including personal circumstances in regulations.
• The most common personal circumstances identified relate to those with a low income. Several regulations across Europe and Canada offer additional financial support for low-income households to undertake energy efficiency renovations or to upgrade to clean heating systems.
• Similar examples from the Netherlands, Switzerland and the USA exempt properties from upgrading to a clean heating system if the cost of doing so is prohibitive or if the lifetime savings were too low.
• Germany allows exemptions for clean heating regulation for owner-occupiers over 80 years of age, if they live in a building of up to six flats.
• Most stakeholders were aware of funding or support for low-income households, but several noted they had not considered including other personal circumstances within regulations.
• A proposal in Flanders aims to introduce a decision tree for personal circumstances, which includes significant life events to excuse residents for not meeting the standard. If implemented, this could allow application for a time extension to meet energy efficiency and clean heat standards in properties based on specific personal circumstances such as divorce or death in the family.
• Stakeholders were concerned that including personal circumstances in the proposed HiB Standard would risk people losing out on the benefits of the energy transition such as reducing energy costs, greater energy efficiency and warmer homes.
• There were concerns regarding a lack of clarity on how including personal circumstances would work in practice and the potential for an additional administrative burden on both residents and those administering schemes.
• Further examples of personal circumstances within regulation include Low Emission Zones across the UK, which provide exemptions for vehicles owned by those with a disability. However, drawing direct parallels to energy efficiency and clean heating regulations is challenging due to the specifics of how the regulation works.

Recommendations and value to a policy audience

Should the Scottish Government decide to implement new regulations that include personal circumstances, the key recommendations are:

• More thorough consideration of the potential benefits and risks associated with including personal circumstances – The benefits have largely been assumed but they require further investigation. The impact of including personal circumstances requires further consideration to understand which groups are most likely to benefit. Additionally, the needs of different vulnerable groups require greater clarity to ensure that the introduction of any flexibilities best meet these needs. This includes owner-occupiers, tenants in the private rented sector and communities connecting to heat networks to determine the likely positive impact. The risks of losing out on the benefits of the transition should also be considered.
• Consider additional support and flexibility – In addition to providing financial support to cover the cost of the measure, consider providing further support or alternative accommodation for low-income households during disruptive works.
• Ongoing monitoring of policy and regulation developments in similar countries, particularly in Flanders.

Glossary

Introduction

This report provides findings from review of a wide range of international regulations that include provision for personal circumstances. Some personal circumstances are legally protected characteristics such as age, disability and pregnancy. However, the definition of personal circumstances is broad and can include wide ranging factors such as income level, health conditions (including disabilities), ownership status of property, location (which can affect outside temperatures), household composition and different cultural practices. These characteristics could affect the ability of different groups to comply with regulations.

The aim of the review is to inform the Scottish Government’s decision-making on future regulations regarding decarbonising residential buildings in Scotland and what types of provisions could be made to take into account personal circumstances. The review covers a variety of regulations that make provision for personal circumstances within different countries and regions that are considered to have relevance for the Scottish Government.

Policy context

The Heat in Buildings (HiB) Strategy commits all of Scotland’s buildings, including residential, to net zero by 2045 (Scottish Government, 2021). A proposal for the HiB Standard (“the standard” for the purposes of this report), comprising a minimum energy efficiency standard and a prohibition on polluting heating systems, was recently consulted on by the Scottish Government (Scottish Government, 2023).

The consultation proposed a prohibition on polluting heating systems from 2045, thereby requiring all homes to switch to a clean heating system. A clean heating system is defined as one with zero direct emissions at the point of use. The Scottish Government’s consultation proposed that private landlords must meet the minimum energy efficiency standard by 2028 and owner occupiers by 2033. Owner occupiers that install a clean heating system will not be mandated to improve their energy efficiency, however it is preferable, for the reasons outlined below.

The benefits of improving the EE performance of homes, particularly regarding the insulation levels and the resulting improved thermal performance are well established. Residents are likely to experience improved comfort and lower bills. EE schemes have a long history in Scotland and the UK, with significant numbers of properties now having good levels of insulation. However, some properties are still behind, with over 37% of private sector homes in Scotland having minimal levels of loft insulation and 47% no form of wall insulation (Scottish Government, 2024).

Clean heating is essential to meet decarbonisation targets and for homes with an improved thermal performance (through meeting EE standards) the expectation is that residents will not experience higher bills following a change to their heating system. The consultation on a HiB Bill also proposed two early action triggers for upgrading a heating system ahead of 2045; these are after the purchase of a property (with a grace period of 2 to 5 years), and when a heat network becomes available (Scottish Government, 2023).

The Scottish Government recognises that there are numerous reasons why properties remain poorly insulated, including technical, cost, practical and personal circumstances. EE retrofit measures and clean heating system installations are sometimes associated with disruption in the home which can be a major barrier for residents. For example, a heat pump installation will typically take 2-4 days to complete (LCP Delta, 2022) and can be disruptive to residents. The associated disruption is the main barrier to upgrading to a heat pump (LCP Delta, Energy Systems Catapult, Oxford Computer Consultants, 2022). This disruption could potentially have a greater impact on those in vulnerable situations.

There is recognition that personal circumstances could make it more challenging for some people to meet the proposed standard due to real or perceived barriers. Personal circumstances are relevant for both energy efficiency (EE) and clean heating requirements.

To ensure fairness, the Scottish Government has proposed (in its consultation on a Heat in Buildings Bill) that the Bill (Scottish Government, 2023) will:

• Ahead of 2045, exempt those who can’t, or perhaps should not have to, meet the HiB Standard.
• Provide extra time for those who need it to meet the standard or require that people comply with a modified version of the standard which considers their building’s characteristics or unique circumstances.
• Make it simple for people to appeal where they believe the requirements are incorrect or unfair.

The new bill has been central to a consultation process which closed in March 2024 (Scottish Government, 2023)

Research aims and scope

This project sought to identify examples of regulation which incorporated personal circumstances from a broad range of international regulations, including energy efficiency and low carbon, housing and transport policies. Regulations were reviewed to determine how suitable alterations, extensions or exemptions have been included to accommodate personal circumstances in different types of regulation. This includes what measures have been used or proposed to provide support (such as financial, deadline extensions) to assist with full or partial compliance with the regulations. This will inform Scottish Government decision-making around future proposals, including if and how to incorporate personal circumstances into new retrofit policy.

Overview of methodology

The key focus of this project was to identify regulatory examples, both within the UK and internationally, that include personal circumstances as a basis for extensions, abeyances or exemptions. We anticipated the number of examples specific to heat and energy efficiency regulations would be low. Our approach therefore drew from a broad base that included other sectors. This approach ensured we cast a wide net to identify a diverse range of types of personal circumstances and different ways these have been accounted for in regulations. To ensure all relevant examples were identified, our approach included a comprehensive evidence search and multi-method approach:

• A desk-based study: We reviewed data from internal reports and databases, including a previous international review for ClimateXChange on heat and energy efficiency policy (LCP Delta, 2023). Additionally, we searched publicly available policy databases and conducted tailored internet searches to identify academic, policy and other research sources.
• Consulted with in-house expert colleagues: this supported our research and ensured we focused our searches in areas that were likely to provide value.
• An online call for evidence: This was posted to LinkedIn via our company page which has over 10,000 followers to encourage stakeholders to share relevant regulatory examples.
• Interviews with external stakeholders: We completed interviews with six external stakeholders to discuss how regulatory examples had been implemented and the impact of including personal circumstances. Stakeholders were from a broad range of sectors and countries including the UK, Europe and Canada. These are summarised in the table below.

Table 1: Interviewees by sector and country

In our research, personal circumstances refer to a variety of individual or household factors that may affect the ability to comply with or benefit from such regulations. Depending on the personal circumstance, they can be transient by their nature or permanent. Specifically, we considered the following aspects of personal circumstances:

• Income level: Financial status is crucial as it affects an individual’s or family’s ability to invest in energy-efficient technologies or renovations. Lower-income households may require subsidies or financial incentives to afford necessary upgrades. Low-income households may also struggle to deal with disruptive works in the house, particularly if they need to find alternative housing during the work.
• Health conditions and disability: Health issues, especially those related to respiratory problems or illnesses exacerbated by cold or damp conditions, can make certain regulations more urgent or necessary for specific individuals. They can also make it particularly difficult to deal with disruptive works in the house.
• Property type: The type of property one lives in (e.g., detached house, flat, listed building, etc) can influence the feasibility of certain energy-efficient solutions or decarbonisation methods. A separate piece of research investigated building characteristics that may require exemptions is ongoing at the time of writing.
• Ownership status: Whether a person owns or rents their home significantly impacts an individual’s ability to make substantial changes to their property, such as upgrading heating systems. Renters often lack the ability to implement these improvements, as landlords retain the final decision-making power. Landlords might impose modifications that do not align with tenants’ preferences or fail to consider their personal circumstances adequately. Additionally, tenants may face the risk of eviction if they push for changes that landlords find inconvenient. Thus, protecting the interests of tenants becomes crucial, ensuring that energy efficiency improvements and clean heat installations do not result in undue cost or disruption for them.
• Location: Geographic location affects climate-related needs; for example, homes in colder regions might prioritise heating efficiency more than homes in milder climates. The reliability of the heating system is also crucial in colder regions. Additionally, rural or urban settings can influence access to certain technologies or energy sources and logistics.
• Household composition: The size of the household and the presence of vulnerable individuals (such as children, elderly, or disabled members) can affect energy needs.
• Cultural practices: Cultural or lifestyle factors might affect energy consumption patterns and openness to certain technologies or changes.

The project team built an Excel database to log all relevant regulations identified through the project and to include key information for each one. The database was a valuable resource when completing the analysis of findings for the project. Relevant criteria collected for each regulation included the enforcing authority to determine the eligibility and type of personal circumstance within the regulation, as well as the method of support available – such as extension, financial support, etc, and redress options (if relevant). The full list of database criteria is available in the appendix.

Research limitations

We acknowledge that the number of regulatory examples that include personal circumstances we have identified is limited. The researchers have endeavoured to identify regulatory examples to the extent that is possible. However, we acknowledge the limitation of finding all relevant regulations given the breadth of the project and the fast-developing nature of the heat and energy efficiency policy space.

We have not conducted full research into the reasons why governments have not included personal circumstances within regulations but suggest the following potential reasons for limited examples:

• Not considered viable: Inclusion of personal circumstances may have been considered, but the government determined that doing so was not feasible. This could either be due to the potential to limit effectiveness of the regulation or challenges associated with how including personal circumstance would work in practice. There may be an assumption that appropriate flexibility will be offered within the overall regime, without it being explicit in the overarching legislation.
• Low priority: Countries may have considered including personal circumstances at some stage during regulation design but deemed this a low priority resulting in no further action.
• Oversight: Countries may have neglected to consider the significance of personal circumstances within key regulation and the potential benefit of including them.

As the research focused on identifying regulations, the research on the type of personal circumstances that affect people’s ability to meet a regulation is limited. Additionally, we have not researched in detail how government intervention could best help different people meet the regulations as this is beyond the scope.

A further limitation of the research is the focus on regulation. There is a possibility that some countries are open to considering exemptions or extensions in practice on a case-by-case basis. This would require residents to reach out to the enforcing authority or body to request some flexibility on the regulation that considers their personal situation. The interview data suggests this possibility, but this was not investigated in detail in this report. It is also possible that Government funding is provided to people in vulnerable circumstances that is not linked directly with regulation; this was also not covered within the scope of the research.

Key findings: Personal circumstances in energy efficiency and clean heat regulations

We undertook a comprehensive review of heat, energy efficiency and other home decarbonisation-related regulations to identify the most relevant examples of regulations including flexibility in enforcement for personal circumstances. Through desk-based research, we identified 18 existing regulations relevant to this study that consider personal circumstances.

We conducted six interviews for this project. Most interviewees were not aware of examples of regulations that include provision for personal circumstances and responses to the idea ranged from neutral to negative. One interviewee who works for a professional housing sector body confirmed that within the housing sector, regulation usually involves meeting a minimum standard with funding available for those who cannot do this themselves. There are no exemptions from electrical and gas safety standards, so the interviewee questioned why decarbonisation measures should be treated any differently as the regulation is in part intended to benefit the resident. Discussions regarding personal circumstances within regulations focused on low-income residents struggling to meet standards due to lack of finance; most interviewees were familiar with such regulation. Most interviewees agreed the solution to this would be provision of additional funding and confirmed that they were only aware of such examples. This tallied with our findings from the desk-based research.

To facilitate the analysis, we have grouped our findings into two categories based on the personal circumstance considered. Our first category considers income levels and highlights eight policies providing additional support to lower-income households, using different methods. Our second category considers the high cost of the work mandated by the policy / regulation and highlights three examples of policies supporting owner-occupiers with the costs incurred for energy efficiency improvements or replacing their heating system with the mandated clean and renewable technology. A third section focuses on other exemptions and considerations, in which we highlight three other policies. In our analysis, we have merged two policies (implemented in France) together as they effectively work together and left out other policies identified which related to legal requirements and were thus out of scope. At the end of this section, we provide a detailed summary and analysis of the six interviews we conducted for this project. Interviewees came from different sectors to ensure a wide range of views.

Income level

Overview

Out of the 18 regulations identified which considered personal circumstances, nine considered income level. More particularly, the regulations had a specific provision for low-income households. These regulations, covered in more detail below, focus on the renovation of existing residential buildings to increase their energy efficiency, and on the replacement of inefficient or high-carbon heating systems for hot water and space heating. These regulations were identified in Europe for the most part (France (3), Italy, the Netherlands, the UK and Poland) as well as in Canada. They include minimum standards setting out how renovation should be conducted and which appliances to install, as well as other regulations encouraging the uptake of energy efficiency measures.

In our research, we identified two distinct phases—initial and advanced— in the evolution of regulatory approaches aimed at promoting energy efficiency and reducing environmental impact. The initial phase is characterised by non-binding, voluntary measures designed to encourage the adoption of clean heat technologies. This phase relies heavily on incentives such as grants, subsidies, or tax rebates to motivate owner-occupiers to implement energy-efficient solutions without the pressure of legal mandates. Most of the regulations highlighted in this section are part of governments’ first step in driving the transformation of buildings on the way to decarbonisation and net zero objectives. In contrast, the advanced phase introduces legally binding regulations that include minimum standards setting out how renovation should be conducted and which appliances to install, as well as other regulations encouraging the uptake of energy efficiency measures. The Scottish Government is specifically interested in the regulations falling in the advanced phase, as funding (initial phase) has already been implemented in Scotland. Two of the regulations highlighted fit into this advanced phase as they include minimum standards, which could show a potential path for the evolution of existing or future clean heat measures. Minimum standards create a legal requirement for specific appliances or energy efficiency measures to be installed, which is then enforced by local planning authorities. The City of Vancouver’s Zoning and Development by-law (City of Vancouver, 2022) mandated the installation of zero emissions heating systems in all new low-rise residential buildings in 2022 and will extend this mandate to all new and replacement heating system installations in 2025. The second example is Poland’s Clean Air 2.0 (Ministry of Climate and Environment, 2022) in which Polish regions have implemented emissions standards for heating appliances in all new and existing single-family homes.

Policymakers across these six countries recognise the urgency in renovating their housing stock and turning them into clean, efficient and comfortable homes. However, they are also aware of the cost implications of these updates and retrofits. As a result, they have developed support schemes and policies to incentivise and help all households to undertake these works, with specific, additional support for low-income households. The definition of a low-income household depends on local economic conditions and is country specific. However, the support provided to low-income households has commonalities across the regulations identified:

• Grants and subsidies: the regulation offers a free contribution to owner-occupiers who undertake an energy efficiency renovation in their home. The contribution usually only covers a share of the total cost of the renovation and is capped up to a certain amount. As an example, the French PrimeRénov’ (Republique Francaise, 2024) is an incentive to help owner-occupiers replace their heating system; in addition to other incentives, it can cover up to 90% of eligible expenses for very modest households, 75% for low-income households, 60% for intermediary households and 40% for high-income households. Eligible expenses include a large-scale renovation of a home leading to an improvement of at least two EPC labels, a specific renovation of the heating system or insulation, or the renovation of a multiple occupancy building.
• Low-interest loans: the regulation offers access to a low-interest loan for owner-occupiers to undertake the renovation and / or retrofit. Depending on countries, the loan can cover part or the total of the renovation work. The Dutch Energy Saving Loan provides a 0% rate on the total cost of the renovation for owner-occupiers with an aggregate income below €60,000. (Nationaal Warmtefonds, 2024).

In our review, we did not identify examples of regulations providing exemptions or abeyances related to income levels. Similarly, redress options weren’t mentioned on the websites reviewed.

Analysis of effectiveness and success

All nine regulations accounting for income level as a personal circumstance proved effective in incentivising owner-occupiers to install energy efficiency measures. Across the countries identified, at least thousands of households had applied for the support schemes. These schemes are available to most households but provide additional support for low-income households. In France, the PrimeRénov’ has received over 1.7 million applications, distributed over €1.7 billion in grants between 2020 and 2023 (Carole-Anne Cornet, 2024). In the Netherlands, over €1.2 billion were provided as part of the Energy Savings Loans, resulting in the renovation of over 90,000 homes across the country (Nationaal Warmtefonds, 2024). One notable measure is the Italian Superbonus which was the only measure providing support up to 110% of the cost of the renovation for owner-occupiers. Whilst the initial objective of the regulation – incentivising owner-occupiers to undertake energy efficiency renovations – has been achieved, the policy had been much more popular than expected, as the take-up of incentives had hit €219 billion by the end of 2023, as opposed to the budgeted €35 billion (Balmer & Fonte, 2024).

Understanding the effectiveness of providing additional support when considering income level as a personal circumstance is more challenging, as governments don’t report such detailed information. Table 2 provides detailed uptake and spending information for all measures identified, when information was available.

Table 2: Income level-related measures and impact

High cost of work in the home

Overview

Out of the 18 regulations identified which considered personal circumstances, three specifically considered the high cost of work in the home, as a combination of property type and location personal circumstances. These regulations mandate the ban of fossil-fuelled heating systems and their replacement by clean or hybrid heating systems. These regulations were identified in the Netherlands, Switzerland and the United States of America (USA). For this exemption, these regulations consider the cost of replacing a fossil-fuelled heating system with a clean / hybrid one and the lifetime cost of running the clean / hybrid heating system. In the cases where the combined estimated installation and running costs of the clean / hybrid heating system are higher, owner-occupiers are exempt from the ban. The regulations in place do not mention a duration for this exemption. Denver City Council has implemented such a regulation banning the installation of natural gas furnaces and water heaters in new commercial and multi-occupancy buildings as part of its new building codes (Weiser, 2023). Additionally, they have earmarked $30 million in incentives to help building owners and homeowners install heat pumps instead.

Analysis of effectiveness and success

There is no published information available online on the effectiveness and / or success of these regulations. These regulations are rather recent, published in 2021 in Switzerland, 2023 in the USA and 2024 in the Netherlands. The Dutch regulation, which mandates a hybrid heat pump as the standard for residential heating, will be implemented from 2026. (Dutch Ministry of the Interior and Kingdom Relations, 2023)

Table 3: Measures considering high cost of work in the home

Other exemptions: alternative clean heating considerations, location, age of residents and household composition

Overview

Our research uncovered two examples of regulations where an exemption was granted if an alternative clean heating system was already being implemented. This approach effectively ties compliance obligations to geographic location, making them dependent on local infrastructure rather than individual choice. As a result, whether a homeowner needs to adhere to these mandates becomes a matter of personal circumstance dictated by their residence’s location, which is typically a fixed factor unless the homeowner decides to move. This geographic-based exemption recognises the contributions of existing local initiatives and reduces redundancy in regulatory compliance.

These examples are both in the Netherlands, where gas-fired heating appliances were banned from all newbuild construction in 2018 and all replacement heating systems will need to meet a specific level of efficiency as per the standard for heating appliances implemented from 2026. The standard for heating appliances is a de facto ban on gas-fired heating appliances with the only alternative being hybrid systems and heat pumps. The Dutch Government grants exemptions to the construction of a new build development when green gas is used in the local and existing gas infrastructure, and if there is no alternative heating system available. From 2026, the Dutch Government plans to grant exemptions to the heating appliance efficiency standard only when homes are connected, or plan to be connected in the near future, to another alternative to natural gas, such as a heat network, to avoid duplication of costs.

Our research also uncovered a unique example of a regulation in Germany mandating all new heating system installations to be at least 65% renewable, effectively mandating hybrid systems or heat pumps. In addition to subsidies and wide-ranging transition periods applying to the whole population, this regulation includes an exemption for owner-occupiers aged 80 or older occupying a building of up to six properties, for new installations or replacement. There is no published explanation of the reasoning behind this exemption, however we understand it is meant to avoid any unnecessary stress and disruption on elderly people.

Analysis of effectiveness and success

The Dutch efficiency standard will be implemented from 2026 and thus can’t be assessed yet. However, we believe that the Dutch public is aware of this regulation as it attracted significant attention in the press and general media when it was voted on. Similarly, whilst the German building act is one of the most advanced clean heating legislations in Europe, there isn’t enough time to measure its impact since it was implemented in January 2024. The Dutch Gas Act has been implemented since 2018 and is estimated to support 1.5 million existing homes to change their heat source by 2030 (Cole, 2021).

Table 4: Other exemptions

Interview findings

The following sections provide an overview of the responses and comments from interviewees. Where similar responses have been made, information has been grouped together thematically where appropriate.

Country specific examples

Flanders are looking to introduce a decision tree of personal circumstances

One interviewee shared a proposed policy change that relates to the Energieprestatie legislation in Flanders (Propriétés Im mobilières (PIM), 2022). This regulation mandates that for all property sales from 2023 onwards, properties with an EPC of E or F must be renovated to a level D or better within five years of purchase. Failure to do so will result in a fine. However, the Flemish energy minister recently announced that people struggling to comply due to personal circumstances would not necessarily face a fine. The proposed solution is a decision tree that could include personal circumstances such as divorces, a death in the family or financial difficulties to determine whether it is reasonable that an owner occupier has not met the standard (Baert, 2024). The decision tree announcement has not yet been followed up by an official change to the regulation. Therefore, currently the requirement to meet the regulatory requirement applies to everyone.

The interviewee was asked to comment on potential parameters for the decision tree; they stressed that all comments are highly speculative. It is likely that the decision tree will be for an extension rather than exemption to the standard, such as allowing the owner occupier an additional five years. The government recognises the importance of homes all meeting the standard so it is unlikely that many people will be granted an extension. It is not yet clear how the Flemish government will define valid personal circumstances but losing a job is unlikely to qualify as there is funding available for those on low incomes. However, a terminal illness diagnosis or the death of a partner could potentially be considered valid.

British Columbia is not actively looking to include personal circumstances but do include other exemptions

British Columbia has some significant differences in terms of policy and housing heating systems. Exemptions only apply in cases where the physical house cannot accommodate the change, such as lack of floor space. The interviewee also stated that in emergency situations, such as a heating system breakdown, the government will not insist that the homeowner upgrades the system. In Vancouver, there is a regulation that mandates upgrades to low-carbon hot water heating systems. This regulation was described as ‘soft’ with minimal levels of enforcement for the first five years; the regulation comes into effect from 2024 (City of Vancouver, 2024). The expectation is that this will be tightened and more stringently enforced in the future, but the current focus is on early adopters. The interviewee recognised the potential benefit of including personal circumstances, particularly to allow extensions in emergency situations or for right to repair. However, there was also a concern that this would increase the administrative burden.

Additional findings from the interviews

Challenges getting people to make changes in their homes

Several interviewees commented on the challenge in getting both owner occupiers and landlords to make changes to their properties. One interviewee commented that smoke alarms are now obligatory in all properties in Scotland, but compliance has been challenging despite this being affordable and less invasive than some decarbonisation measures. There was an acknowledgement that some people will struggle to meet the standard and that this was valid, for example for elderly or disabled people, as associated disruption would be harder for these groups. Likely reasons for lack of engagement relate to a lack of trust and in some cases, insufficient funding or access to finance. It is vital that these barriers are addressed as a priority where possible, before introducing regulation that allows exemptions or extensions.

Concerns raised regarding including personal circumstances in regulation

Including personal circumstances could risk some residents being ‘left behind’ and missing out on the benefits of the energy transition due to decarbonisation measures not being completed. This could be due to a lack of financial support (or lack of awareness that this is available), lack of understanding of the benefits (such as a warmer home) or due to some stakeholders, such as landlords, using personal circumstances as a loophole to avoid undertaking work. This point was raised in several interviews. Several stakeholders stated that the priority should be engaging and supporting people to meet the decarbonisation standards as it will benefit them overall. In circumstances where the cost of doing the work is prohibitive more funding should be made available. One interviewee commented that if a person on a low income cannot stay in their home during the retrofit work, then the funding should also cover the cost of them temporarily staying somewhere else.

Personal circumstances may be a valid reason for not meeting the standard, but regulation is not necessarily the right tool

Several interviewees noted that vulnerable people, particularly elderly and disabled people, are often already known to social services and there is potential to rely on their assessment of someone’s personal circumstances as they are on the front line. In some countries, people are sometimes exempted from meeting energy efficiency regulation informally. In cases where someone has a terminal illness then a decision can be made on the ground not to enforce. The focus should be on making delivery work in practice and not just meeting the regulation. One interviewee commented that personal circumstances do not always fall under precise criteria, for example having no social support from friends or family may make someone more vulnerable but regulation will usually not include such criteria. Some retrofit programmes have not sufficiently considered how to work with socially diverse groups, which creates issues for delivery. Addressing this problem would support better delivery of regulations on the ground and lead to better overall outcomes, instead of focusing on top-down regulation.

Unclear how including personal circumstances would work in practice

There is a risk that including personal circumstances in regulations will be overly bureaucratic. There would need to be clarity on how people apply for exemption or extension and how personal circumstances are monitored to determine if they are still relevant. Personal circumstances can change quickly, so the regulations need to be able to respond dynamically in a way that is not restrictive. There is still a risk that things will become confusing and difficult to manage. There are already challenges with the current data levels on standards within the domestic sector that need to be improved to ensure an accurate picture on compliance. Improving the quality of the data would be necessary to manage any exemptions or extensions under personal circumstances. Additionally, there needs to be clarity on how to handle situations such as mixed tenancy blocks of flats where there may be different personal circumstances in each dwelling.

If personal circumstances are to be included in regulation this should be minimal

Three interviews highlighted that if personal circumstances were to be included, it should be cautiously. One stated that there could be a place for extensions but highlighted that there are still concerns related to managing this in practice. Another interviewee stated that any exemptions should be kept to a minimum as there was concern that this could be deliberately used to stop change. There is a risk that those with personal circumstances are assumed to be unable to act, which is not necessarily correct. Most people will be able to act and those that cannot, due to financial issues should be provided with support. Several interviewees stated that this should include appropriate levels of finance, including through banks and mortgages so people can make the necessary improvements to meet the standard.

Key findings: Personal circumstances in other decarbonisation regulations

In an effort to identify as many examples as possible of decarbonisation regulations including flexibility for personal circumstances, we widened the scope of our research to transport and housing-related decarbonisation regulations. A few cities across the UK have implemented is at the forefront of decarbonising individual transport in measures to reduce the number of polluting cars in city centres. The regulation sets a standard for vehicle emissions, and drivers need to pay a fee if their vehicle doesn’t meet the standard. London’s Ultra Low Emission Zone (ULEZ) has been extended in 2023 to cover all of London’s boroughs. (Transport for London, 2023) It provides exemptions for vehicles for disabled people, because they might not be able to use alternative transportation options. ULEZ regulation also provides for a fee reimbursement for National Health Service (NHS) patients driving to a point of care. The second example is a similar and more recent regulation in Edinburgh, which offers a few more exemptions for specific types of vehicles, including vehicles for people with disabilities as well as historic vehicles, showman’s vehicles, emergency and military vehicles. (Edinburgh Council, 2024)

Whilst these regulations provide examples of decarbonisation regulations including blanket exemptions, it is challenging to draw specific learnings for heating and energy efficiency decarbonisation, particularly as the exemptions included are tied to vehicle types.

Table 5: Personal circumstances in other decarbonisation regulation

Conclusions

Key findings for regulation development

Income level

Most of the regulations identified in our research focused on addressing the impact of the energy transition on low-income households. Policymakers seem to be aware of the high costs of the transition and provide financial support under different forms, including grants, subsidies or low interest loans and tax deduction. The financial support is usually tied to specific energy efficiency objectives in the home, or the installation of a specific heating technology. Low-income households can get access to more funding to cover the incurred costs, up to 110% in Italy.

No financial support is provided to deal with the disruption resulting from the replacement of the heating system. The interviews identified this as an important gap in policy, as vulnerable people, particularly those with ongoing health conditions will likely need additional support, during work that is particularly disruptive.

High cost of work in the home

A few of the regulations identified in our research provided exemptions to owner-occupiers where the cost of installing a clean heating system was significantly higher than the cost of installing a fossil-fuelled heating system. Whilst these regulations consider the installation cost as well as the lifetime cost of the appliance, it remains challenging to assess the lifetime cost of a new appliance and without careful implementation and enforcement, there is a risk that this type of regulation could be exploited to justify the continued use of fossil-fuelled heating systems.

Other exemptions: alternative clean heating and age

A few of the regulations identified in our research provided exemptions from clean heat standards where homes had access to alternative clean heating technologies (e.g. heat networks) or when green gas is used in the gas network. Our research also found an example which exempted owner-occupiers over 80 years of age from replacing their heating system with a system that is at least 65% renewable, to avoid significant disruption.

Stakeholder opinions on the inclusion of personal circumstances

The interviewees primarily consisted of those who had never considered including personal circumstances within regulations or who were sceptical about how this would be beneficial. There were also questions raised regarding how effective this would be in helping vulnerable groups while balancing the needs of the energy transition. This included a lack of clarity regarding who the introduction of personal circumstances was intended to support and additional concerns regarding the process becoming overly bureaucratic. One interviewee noted that the potential disruption associated with installing decarbonisation upgrades could potentially be alleviated by providing temporary accommodation for vulnerable residents during the works.

Overall conclusion

Our overall research concluded that there are limited examples of regulations that include exemptions, extensions or abeyances based on personal circumstances. Our recommendation to the Scottish Government is that blanket exemptions are not suitable for this policy area as it risks excluding some members of society from the benefits of the energy transition. We found a limited number of regulatory examples that consider personal circumstances. This could be a suitable amendment to the regulation provided there is clarity on how exemptions would be managed over time and that does not become overly bureaucratic for residents.

We recommend that the Scottish Government continues to monitor the situation in Flanders, as new policy announcements may provide greater clarity on the proposed decision tree. We also recommend further consideration is given to the suggestion by one interviewee, to provide alternative accommodation for those on a low-income during upgrade works to their homes, which can be highly disruptive.

Priorities for further research activity

We have found that the Scottish Government appears to be considering the impact of upgrading residential home on vulnerable groups more than other countries. This is an important consideration to ensure the energy transition is fair and does not negatively affect vulnerable groups. However, should the Scottish Government seek to include personal circumstances within energy efficiency and clean heat regulations we recommend further research. This includes investigating more precisely which vulnerable groups are most likely to benefit from an exemption, extension or abeyance through stakeholder engagement. Additionally, greater clarity is required regarding what the needs of different vulnerable groups are to determine how the inclusion of personal circumstances within regulations would potentially benefit them. Finally, there is a need to identify the potential risks and possible negative unintended consequences associated with including personal circumstances before any policy amendments are made.

The introduction of personal circumstances has the potential to provide different levels of benefit for different groups that may struggle to meet the HiB Standard. There was significant discussion during the project, with interviewees, the Scottish Government and the project delivery team regarding who is most likely to benefit from the inclusion of personal circumstances in regulation. However, this was not the key focus of the research, so any conclusions regarding who is most likely to benefit is highly speculative. We have outlined our assumptions below, but these would require further research to be conclusive.

The three groups that could benefit from the inclusion of personal circumstances relate to the proposed trigger points for action from Scottish Government. These are outlined below:

• New owner-occupied properties: One of the proposed trigger points to meet the standard is the point of sale of a property. The benefit of including personal circumstances is likely to be low for this group, as they have already encountered disruption when moving. The current proposal is to allow a grace period of 2-5 years for this trigger point; therefore, additional disruption associated with meeting the standard would likely be well tolerated. One interviewee commented that when some vulnerable people, particularly older people, move to a new property, they often move to sheltered or social housing rather than into a privately owned home. This would reduce the benefit of including personal circumstances as such housing is covered by separate legislation.
• Tenants in the private rented sector: Another proposal is for landlords to meet the standard, regardless of the circumstances of their tenants. The potential benefit of including personal circumstances of tenants could be high, as vulnerable people in this group have less agency than those in owner-occupied properties. However, there is also a risk that by including personal circumstances, landlords may see this as a loophole to avoid making improvements on their property that would benefit their tenants. The uncertainty regarding the levels of disruption and potential unintended consequences for tenants would benefit from further research.
• Opportunity to connect to a heat network: A final proposed trigger point is a new district heat network. Residents would not be obligated to connect but would be expected to adopt an alternative clean heating solution instead if they do not. The benefit of including personal circumstances for this group could also be high, as any community or neighbourhood that connects to a heat network is likely to be composed of a range of residents, including vulnerable people.

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Appendix

The full list of criteria collected for each regulation and included in database:

• Country / Region where the policy is in force
• Type of regulation such as a national strategy, subsidy, standard, tax, etc
• Level of governance: municipal, regional or national
• Implementing body within relevant country
• Topic area: energy efficiency, clean heat or both of these or transport
• Name of regulation/policy
• Date first introduced
• Regulation objective
• Regulation description
• Personal circumstances provision in the regulation
• Support available – Financial
• Support available – abeyances or exemptions
• Redress options available
• Criteria used for assessment
• Link to the regulation
• Link to relevant case study (if available)

© The University of Edinburgh, 2024
Prepared by LCP Delta on behalf of ClimateXChange, The University of Edinburgh. All rights reserved.

While every effort is made to ensure the information in this report is accurate, no legal responsibility is accepted for any errors, omissions or misleading statements. The views expressed represent those of the author(s), and do not necessarily represent those of the host institutions or funders.

February 2024

DOI: http://dx.doi.org/10.7488/era/4856

Executive summary

The 2023/2024 consultation on the Heat in Buildings (HiB) Bill proposed standards covering heating and energy efficiency that all existing buildings will be required to meet. This report explores the data sources that could be used in future to develop a digital compliance monitoring system for those standards. The standards require:

1. In all buildings, including non-domestic premises: non-polluting heating from 2045.
2. In owner occupied homes: a minimum energy efficiency standard by the end of 2033.
3. In privately rented homes: a minimum energy efficiency standard by the end of 2028.
4. Those purchasing a property to comply with the prohibition on polluting heating within a specified amount of time following completion of the sale.
5. Providing local authorities and the Scottish Ministers with powers to require buildings within a Heat Network Zone to end their use of polluting heating systems by a certain date and with a minimum notice period.

Compliance with the standards can be met through:

1. The presence of a clean heating system, including connection to a heat network.
2. Meeting the energy efficiency standard through either installing a list of measures or meeting a fabric energy efficiency rating of 120kWh/m²/year or less.

Compliance with the standard creates a need to check on the progress of Scotland’s buildings. This may require a dedicated system. Through desk-based investigation and stakeholder interviews, we identified public and private repositories of information regarding buildings, which could be used to carry out compliance monitoring for domestic and non-domestic properties.

Findings

We found no digital dataset (or database comprising various datasets) that combines data relevant to the HiB Standard that is highly accurate and with full coverage of all buildings in Scotland. For instance, only 55% of Scottish domestic dwellings have an assessed EPC created following a domestic energy assessment, as opposed to a prediction based on similar nearby properties. As a result, no existing dataset could readily be used for compliance monitoring.

Ultimately, reliable digital compliance monitoring can only be achieved with a high degree of accuracy of the data being inserted and coverage across the whole built environment in Scotland. Our findings include observations around the role of data governance, property identification, professionals and professional indemnity insurance, data consistency, archetype approaches, and data sharing.

Conclusions

We suggest that an optimal digital solution in terms of coverage and accuracy could be achieved in the near term by combining data from different sources and enriching it with new data. We identify below which datasets are relevant to various aspects of the Standard. This review is on the basis that current update points for EPCs remain the same and that the process is able to adapt and update sufficiently quickly to the new clean heating systems coming onto the market.

Table 1 Existing datasets that could be used to measure compliance

Considering the above, the following options may be considered by the Scottish Government for the establishment of a compliance and monitoring tool. Each option has advantages and drawbacks as well as a set of actions required to enable successful implementation.

Option 1: Use existing data sources in their current locations

• Option 1a: Homeowner reporting into existing locations – 3 to 6 months to develop

1. Homeowners are required to self-report into these locations and upload evidence. Government looks individually at these data sources.
2. The responsibility to demonstrate compliance rests with the homeowner, who must generate, gather and upload the relevant information to the data sources to demonstrate compliance to the government.

• Option 1b: Professional reporting into existing locations (status quo)
  • Government looks individually at these data sources, which can only be updated by professionals.
  • The responsibility to demonstrate compliance rests with the homeowner, who must pay for generating, gathering and uploading the relevant information to the data sources to demonstrate compliance to the government.

Option 2: Professional reporting from linked databases – 3 to 6 months to develop

1. Data sources listed above remain in their current locations.
2. Government looks at a single portal, which in turn looks at existing sources that can only be updated by professionals.
3. The responsibility to assess compliance rests with the government and the responsibility to demonstrate compliance rests with homeowners or their professional consultants. The government creates a means of collating the data on a per-property basis via a new portal.

Option 3: Professional reporting into a new central database – 12 to 18 months to develop

1. Data is moved from existing data sources to a new government-managed platform.
2. Government manages a combined dataset that can only be updated by professionals.
3. The responsibility to assess compliance rests with the government, and the responsibility to demonstrate compliance rests with homeowners or their professional consultants. The government creates a means of collating the data on a per property basis on this new platform.

Opportunities

We highlight an opportunity for Scotland to develop a comprehensive central database looking at many aspects related to buildings and property, including building materials, fabric condition, and energy use. While this is out of scope of this project, such a database could bring many benefits, such as increased building safety, simpler conveyancing, smoother statutory consent processes, fewer vacant homes, improved building condition, and more resilient property value. The EU and various member states are legislating on the introduction of property logbooks (also called “green building passports”) to constitute such datasets from the ground up, starting at property level. The list of database tools provided by the private sector in our study is testament to the market’s confidence in their potential to positively impact comfort, affordability, and the environment through the provision of digital logbooks.

Glossary of terms and abbreviations

Background and context

Introduction

Following the Scottish Government’s Climate Change (Emissions Reduction Targets) (Scotland) Act 2019, new strategies and policies have been published to provide a framework for reducing the emissions from our homes and buildings. One such key document is the ‘Heat in Buildings Strategy’, which aims to support the decarbonisation and retrofitting of existing buildings. Further to the Strategy, a consultation ran between November 2023 and March 2024 with proposals for a Heat in Buildings (HiB) Bill, designed to provide new regulations for the improvement of energy efficiency and transition to clean heating systems in homes and buildings in Scotland. At local authority level, Local Heat and Energy Efficiency Strategies (LHEES) and Delivery Plans have been published to identify opportunities and target funding for decarbonised heat at local council level.

The Scottish Government wishes to explore a digital system to monitor compliance of existing buildings with the upcoming Heat in Buildings Standard to be established by the proposed Bill. This paper reviews existing digital data sources that the Scottish Government could draw on in developing a future monitoring regime.

Data in property and construction

The real estate industry started to adopt digital technology, such as spreadsheets and accounting software, throughout the 1980s as personal computing became more common (Reed, 2021). At the same time, it became possible to model building performance using computers, leading the Building Research Establishment (BRE) to develop the Standard Assessment Procedure for the Energy Rating of Dwellings (SAP), based on the BRE Domestic Energy Model (BREDEM) and published by BRE and the Department of the Environment in 1992. It has now been adopted by the UK Government and Scottish Government as the official methodology for calculating the energy performance of dwellings (Scottish Government, 2023).

This approach was drawn into international environmental legislation through the European Union’s Energy Performance of Buildings Directive (EPBD), first enacted in 2002, and updated in 2010, 2012, 2018 and 2024. This Directive called for standard assessment procedures to analyse the energy performance of buildings, standard data inputs and outputs, and a means of communicating the findings of this process to the public through what became Energy Performance Certificates (EPCs). EPCs use building energy models to communicate modelled energy efficiency in buildings, from bands A (highest energy efficiency) to band G (lowest energy efficiency). Given the varying definitions of ‘energy efficiency’, these bands have changed over the years.

Heat in Buildings (HiB) Strategy (2021)

The HiB Strategy, published by the Scottish Government in October 2021 “provides an update to the 2018 Energy Efficient Scotland Route Map and the 2015 Heat Policy Statement, and brings together [Scottish Government’s] ambitions on energy efficiency and heat decarbonisation into a single framework.” It calls for all owner-occupied homes to reach EPC C by 2033 and all private rented homes by 2028, although it acknowledges that the more difficult homes in mixed tenure or mixed ownership blocks, and non-domestic premises, may take until 2045 to achieve it. Public Buildings should have zero emission heating sources as soon as possible, with a backstop of 2038.

The Strategy further acknowledges challenges around these targets, suggesting that “where it is not technically feasible or cost-effective to achieve the equivalent to EPC C rating, (…) a minimum level of fabric energy performance through improvement to walls, roof, floor and windows, as recommended in the EPC, would apply.”

Heat in Buildings Bill consultation

In December 2023 the Scottish Government published a consultation (Scottish Government, 2023) on the proposed Heat in Buildings Bill.

The consultation included the following proposals:

1. Prohibit the use of polluting heating systems after 2045 across all buildings.
2. Require those purchasing a home or business premises to end their use of polluting heating systems within a fixed period following completion of the sale.
3. Require homeowners to make sure that their homes meet a reasonable minimum energy efficiency standard by 2033 only where no clean heating system has been installed.
4. Require private landlords to meet this minimum energy efficiency standard by 2028 regardless of whether a clean heating system has been installed.
5. Require property owners to connect to a Heat Network when it comes available, or change to another form of clean-heating of their choice

We consider the elements below, present in the consultation, to be of particular relevance to the data requirements for a compliance system.

Section 2 states:

“We propose to set a minimum energy efficiency standard that can be met by installing a straightforward list of measures. This list of measures would be developed to prioritise those that could have the most impact for homes with the lowest amount of cost and disruption. Any homeowner who had installed these measures – or as many of them as are feasible for the type of home they live in – would be considered to have reached a good level of energy efficiency and meet the new standard.

We think this list could be:

• loft insulation
• cavity wall insulation
• draught-proofing
• heating controls
• 80 mm hot water cylinder insulation
• suspended floor insulation”

“Alongside this straightforward list of measures, we propose an alternative option of meeting the standard based on the result of an EPC assessment. We have recently consulted on the addition of a new fabric efficiency metric to EPCs, which could be used to show that a property meets a good level of energy efficiency.”

“Owner occupied homes that have ended their use of polluting heating by 2033 will not be required to meet the minimum energy efficiency standard.”

“Private rented properties would still be required to meet the minimum energy efficiency standard, however, even if a clean heating system had already been installed.”

“We are not proposing to set a minimum energy efficiency standard for non-domestic buildings.”

“While we are also not proposing to apply this Heat in Buildings Standard to the social rented sector, the sector will still be on the same pathway.”

Section 4 states:

“We are proposing that any buildings within a Heat Network Zone will not need to meet the Heat in Buildings Standard following a property purchase.”

Section 5 states:

“This consultation has described five points in time at which we may be asked to meet the Heat in Buildings Standard:

1. at the end of a grace period which follows the completion of a property purchase;
2. following notice from a local authority to a building owner in a Heat Network Zone that they are required to end their use of polluting heating;
3. at the end of 2028, private landlords will need to have met the minimum energy efficiency standard;
4. at the end of 2033, owner occupiers will need to have met the minimum energy efficiency standard; and
5. at the end of 2045, all building owners will need to have ended their use of polluting heating.”

A definition of HiB Standard compliance

We used a definition of HiB Standard compliance against which to compare existing digital datasets, databases, and tools.

1. Presence of a clean heating system i.e., a heating system which does not emit CO₂ at point of use.
   1. This includes connection to a Heat Network.
   2. Being in a heat network zone means that the property does not need to meet the Heat in Buildings Standard following a property purchase.
2. Installing a list of measures (alterations to the building) or meeting a fabric-based heating demand of 120kWh/m²/year or less (as modelled by approved software).

The opportunity for Scotland

Scotland’s differentiated legislative, regulatory and policy regime affords it the opportunity to determine its own approach with regards to energy and heat in buildings, though with certain limitations around control over the gas grid or product standards. Furthermore, the Scottish building stock is different to the wider U.K. stock, calling for a specific approach. More people live in flats (National Records of Scotland, 2023), (Office for National Statistics, 2023), construction is of a lower quality generally (BRE Trust, 2020), it has a larger social housing sector (Serin, et al., 2018), and the climate is more challenging. Furthermore, traditional tenements, post-war non-traditional construction, and the greater prevalence of timber kit construction in the late 20^th century (PBC Today, 2022) are all unique features of the Scottish building stock.

The gap between the current state of Scottish housing and the expectations set by the HiB Bill will stimulate economic activity. This positions retrofit as a key area of potential growth in the labour market.

Mapping the current situation

Buildings

The HiB Strategy (Scottish Government, 2021) and Scottish House Condition Survey (Scottish Government) contain statistics about the built environment and the people and communities living in them.

1. The total domestic building stock in Scotland comprises around 2.7m homes.
2. Following their introduction in 2009, as of 2023 around 1.5 million domestic EPCs currently exist (55% of the building stock).
3. Following their introduction in 2009, as of 2023 around 49,000 non-domestic EPCs currently exist (25% of the building stock).
4. In 2022-2023 there were 101,055 residential property sales in Scotland (Registers of Scotland, 2023), leading to as many updates to the EPC register.

Building data holders

We drew up a list of organisations known to be maintaining databases associated with the built environment. Other organisations were added upon suggestion by interviewees.

All organisations were contacted via email with a letter of introduction from the Scottish Government about the research study. A series of standard questions were posed, which are listed in Appendix A.

The array of different datasets and tools for buildings and energy data included within this study can be categorised as follows:

1. Public databases – owned, funded or managed on behalf of the government.
2. Public data analysis tools – owned, funded or managed on behalf of the government.
3. Private datasets and analysis tools – owned and funded by third parties.

A summary of all databases contacted as part of this study is provided in Annex A. The following tables summarise the findings. Where “-” is used, there was no comment given in the interview relating to this category.

Public databases only

Table 2 Summary of information in public databases

Detailed commentary on each is in Appendix B.

Public databases with data analysis tool

Table 3 Summary of information in public databases with data analysis tools

Detailed commentary on each is in Appendix C.

Private database or data analysis tool

Table 4 Summary of private databases or data analysis tools

Detailed commentary on each is in Appendix D.

Information required for HiB monitoring

The compliance criteria noted in section 3.5 are cross-referenced below with the datasets and tools reviewed in Table 5.

We haven’t distinguished between data which is assumed, predicted, observed, or modelled. See Section 5 below for commentary on this distinction. The databases are primarily split into two categories:

1. Those which contain EPC data (beyond the EPC band).
2. This includes data about all elements of the building.
3. EPC data is the basis of “Home Analytics”
4. Home Analytics is itself the basis of several other databases (see Appendices B, C and D for details)
5. Those that don’t contain EPC data beyond the EPC band.

The only public data set with data of a higher quality on the individual building elements than the EPC data is the Scottish House Condition Survey (SHCS). The SHCS data is based on a small sample set of the housing stock and then extrapolated over the whole stock to generate the associated report. This level of quality and accuracy is also present in “Single Survey” data, which is present for a much larger percentage of the stock, though this is held privately at present.

One of the few databases which provide centralised and accessible information about Heat Network Zones is the Scotland Heat Map, providing that Local Authority LHEES data has been uploaded to it.

Table 5 Databases cross-referenced with HiB compliance criteria

Data sharing and transferability

Data is held by various organisations in a mix of structured and unstructured databases. Some of them are publicly or privately accessible via APIs. Some of them require the export of data in usual formats (CSV or XLS). Some of them do not have any built-in connections, but this could be created on demand. More problematic is the lack of a common framework for what the data means, different ownership of data, the lack of data sharing agreements, and the rights that individuals and organisations have to make it available to others.

While SAP (upon which the EPCs are based) provides a useful definition and structure for each element it looks at, enabling comparisons across buildings, this is not an exhaustive way of looking at and analysing buildings. These gaps, and the lack of a common standard, are quickly filled by other assessment methods created by trade bodies or organisations for their own purposes, which results in a fragmented, hardly interoperable, and ultimately unactionable data universe. For instance, while SAP determines floor area in a certain way, Royal Institution of Chartered Surveyors (RICS) determines it differently. While RICS or RIAS leave it up to Chartered Professionals to prioritise fabric interventions, SAP provides a proscriptive way. While PAS2035 provides a specific list of possible interventions, these are not used across the board in all retrofit assessment software available.

In short, there is no commonly agreed way of fully describing the characteristics, condition, and work required of all buildings. Work is underway in the private sector to address some of these gaps and differences. For instance, we are aware that a study group within the National Retrofit Hub is working on creating a data scheme suitable for domestic properties. Such a scheme could then be adopted by Residential Logbook Association (RLBA) members to standardise the way in which data is recorded and presented in their platforms. This work could further be integrated into the emerging Property Data Trust Framework being developed by the Open Property Data Association in order to standardise access to various data points. As a whole, this work could provide a standard for the description of buildings, increase interoperability of platforms and databases, and pave the way for faster rollout of retrofit measures. There is also currently a small project being funded by BE-ST to investigate the opportunity of a national buildings ‘domestic’ database.

Before data can truly be transferable, however, other issues need to be considered as part of this work. These include data ownership and data sharing consent mechanisms. For instance, some of the data which a homeowner could make use of in order to plan retrofit, such as Home Analytics, belongs to the Scottish Government, is held by the Energy Saving Trust and can only be accessed by request from local authorities or registered social landlords, but not homeowners. This creates a barrier to access information which ultimately relates to the property in the ownership of the person trying to access it. Similarly, Trustmark logs information covering all past government-funded interventions, but this information isn’t readily accessible to the homeowners. Access to this would allow homeowners to have precise and up to date information of their property’s heat and energy installations, and the potential for further work. For consumer access to such information to be possible, such as through the medium of a property logbook (also called “green building passport”), a trusted means of verifying the identity of the person requesting the data needs to be agreed upon by all parties.

Particular attention should be paid to the data ownership and sharing provisions of data held by third-parties on behalf of the government. The study team recognises the commercial incentives that organisations holding data on behalf of the government have to restrict, and in some cases charge for, access to data which is in public (government) ownership. A review of the government’s data sharing agreements with third-party organisations holding data on its behalf could be conducted to ensure that:

1. publicly-owned data can be made available to appropriate persons and organisations (such as the householder or their consultants);
2. publicly-owned data is not privatised;
3. only modelled data derived from third party organisations’ own investment and Intellectual Property can be commercialised.

Summary of existing energy & building data landscape

Our review showed that there is no single existing source of data which could readily be used as a compliance and monitoring tool for the Scottish Government for the aspects of building construction and performance set out in the HiB Bill consultation. The existing data landscape described above is patchy in its coverage, with even the most comprehensive data set (Domestic EPCs) covering just over 50% of the stock to which it applies^[1]. Some databases, such as EPCs, have the potential to contribute an important proportion of the data required. However, they suffer from issues which preclude their wholesale adoption for the purpose of compliance and monitoring.

Furthermore, while the structure of EPC data is consistent, there are variations in the structure, unit of measurement and phraseology of the other data points gathered, held, and processed in other databases which could all be complimentary if this issue were resolved.

Two of the databases listed above – the Scotland Heat Map and the National Grid – bring together complementary datasets to provide a more holistic picture of the decarbonisation potential of building heat sources, but it is hard to use them for HiB compliance as they present data for groups of buildings, rather than individual buildings.

In conclusion, any solution for the monitoring and tracking of the HiB compliance will have to draw on several datasets and be enriched with additional data to close gaps where modelled/assumed data is currently relied upon.

Observations

The following section contains our more detailed observations of the datasets outlined in summary above in more detail with commentary arranged by topic.

Indexing

Accessing information about a given property across multiple databases would require searching indexed data according to a single unique identifier for the property.

There are several ways in which properties in the UK have been identified. These include Property Title numbers, Unique Property Reference Numbers (UPRN), Meter Point Reference Numbers (MPRN), and Postal Addresses. Unfortunately, these aren’t immediately usable: Property Titles can relate to more than one dwelling, UPRNs aren’t present for every building in the UK, MPRNs can relate to multiple properties at once, and Postal Addresses have multiple formats. A breakdown of the strengths and drawbacks of various identifiers is in Appendix E.

Heat network zones

The HiB Bill consultation refers to the Local Heat and Energy Efficiency Strategies (LHEES) published by each Local Authority. Each LHEES identifies potential Heat Network Zones, areas where a heat network appears to be viable. LHEES are to be updated every 5 years. The second round of LHEES will take into account designated heat network zones. Some LHEES data on Heat Network Zones is being uploaded to the Scottish Heat Map. The Scottish Government will update the Heat Map data and Local Authorities will report any inaccuracies/ ad hoc updates, making use of the Heat Map’s GIS framework to make them interactive and usable.

Given the high priority the HiB Bill consultation gives Heat Network Zones, knowing whether a property is in a Zone or not is a key piece of information for compliance monitoring. Having all LHEES potential heat network zone data and designated Heat Network Zone data digitised and accessible would provide a key plank of the SG monitoring and compliance framework. Potential zone data isn’t vital for compliance – but could help to communicate where zones might soon be.

EPCs, RdSAP, Home Analytics

Domestic buildings must have an Energy Performance Certificate (EPC) created on construction, sale, or lease (or marketing thereof). An EPC must be created through an approved modelling methodology called SAP, or RdSAP in its simplified version. The certificate must be lodged on a public register, which in Scotland is administered on behalf of the Scottish Government by the Energy Saving Trust (EST).

The base data that is collected and used for creating EPCs (EPC data) is collated and owned by the Scottish Government. This data is then enriched with socio-economic and spatial indicators, such as Local Authority Ward, topographical information, Scottish Index of Multiple Deprivation, and other indicators to create a data set called “Home Analytics” (HA). Predictive modelling is then used to:

• Close the gaps: of the 2.7m homes in Scotland, only around 1.5m of them have EPCs. To get a Scotland-wide picture, HA predicts EPCs using the EPCs of nearby properties.
• Identify decarbonisation opportunities. By looking at several other simple datasets (e.g., orientation, typology, nearby land) it can suggest measures which might be viable for each property (such as the installation of a wind turbine, or solar panels).

Where data has been assumed, or predicted based on an algorithm, confidence ratings applied to show that these data points were not produced via observation by an energy assessor. 100% confidence is given to original information, and lower ratings for derivative or modelled information. Home Analytics is available to public sector organisations and their subcontractors for specific projects.

Due in part to difficulties in accessing the Home Analytics dataset, many of the organisations we spoke to have constructed their own database based on the public EPC register, augmented by combining with various other data sources to generate more informed conclusions about either the country-wide picture, or smaller zones of stock.

Non-domestic analytics

Non-domestic buildings also must have an EPC on construction, sale or lease, or marketing thereof. SBEM or an approved Dynamic Simulation Model (DSM) can be used to produce the EPCs. In the same way as domestic EPCs, the input and output data is owned by the Scottish Government and is managed by EST. Our research did not extend into the non-domestic analytics database. However, from discussion with interviewees the study team were informed that the non-domestic analytics database contains less observed data, and more modelling than HA (due to bigger variance in non-domestic buildings).

Public Buildings Standards

Having spoken to several key managers within the public building portfolios sector, we found that the energy performance data held by the public sector about their buildings is variable and incomplete.

Scottish Futures Trust (an executive non-departmental public body of the Scottish Government, established to improve public infrastructure investment) are now onto the second revision of their Net Zero Public Buildings Standard, which “helps public bodies define objectives for their new or retrofit construction project in pursuit of a credible path to net zero operational energy”.

As noted above, HiB notes the target for public buildings is to have clean heating systems first and foremost, with achieving a broader level of energy efficiency a further implicit means of improving the efficiency of said heating system. Given this, the target for this stock may be purely to decarbonise heating systems.

PAS2035 and Trustmark

PAS2035 is the UK Government specification for the retrofit of domestic buildings. It establishes a complete process, creates new roles and responsibilities, and brings in checks and balances which aim to avoid the pitfalls of previous Government-funded home energy efficiency investments. It is currently mandated where the “ECO” funding stream is used for projects, and some public sector bodies in England and Wales mandate it for works funded by other streams. From the study team’s experience, standard PAS2035 practice relies heavily on EPCs as the tool to determine the energy efficiency of buildings before and after any work.

Trustmark is the organisation tasked with applying quality assurance (QA) to the PAS2035 process. A key element of this quality assurance is that installation data should be uploaded to a Trustmark-managed ‘data warehouse’ at the end of a PAS2035-compliant project. This data comprises the wider QA documentation generated, such as “before and after” EPCs, photographs, reports, drawings, and specifications.

The Scottish Government, and the wider construction industry in Scotland, have been debating the role of PAS2035 in retrofit activity for several years. As of the date of this study, there appears to be a mixed response to increasing use of the PAS2035 standard for retrofit work, in part due to the higher cost implications. This may be discounting the benefits of record-keeping and post-installation data lodging aspects which PAS2035 brings.

Trustmark notes that the data is considered publicly owned, and consequently private commercial organisations cannot easily access it, despite ongoing explorations into how to expose more of it. They also note that the vast majority of what is held relates to properties in England, given the small number of PAS2035 projects carried out in Scotland. Trustmark reported that only around 600,000 properties (2% of UK 27 million existing homes) have data lodged in the ‘data warehouse’.

Microgeneration Certification Scheme (MCS)

The MCS is a quality assurance scheme for small renewable energy, heat pump and Photovoltaic (PV) cell installations. It was created to improve the quality of work carried out by having a defined list of approved installers, and a methodology to track such installations. It was implemented by the UK Government from 2011 onwards. MCS requires registration of installers, standard methods of generating specifications and quotes, and guarantees for equipment installed and after-sales care. The documentation of each system installed is lodged with MCS and held centrally.

Lead vs lag

Many databases comprise data for buildings which can be described as “historic” or “stale” (i.e., not recent). We refer to them as ‘lag’ data. Others use this historic data as inputs into models which suggest what measures individual buildings, groups of buildings, whole estates, or the national stock could benefit from. This second type of data is considered ‘lead’ data.

For the purposes of tracking compliance, the lag data sources are more useful because though they might be stale, they are not predicted, which implies a lower confidence. But this raises the question of the point at which the lag data gets updated. These data update points are described as “update points” below.

Property Logbooks / Building Passports

Two of the organisations we spoke to provide property logbooks (sometimes referred to as “building passports”). These software applications are emerging digital tools which provide a comprehensive digital record of the building’s past. Some of them comment on fabric condition, occupancy patterns, and provide a ‘roadmap’ for work to be undertaken to the building into the future. The advent of these digitised data repositories and improvement plans is something the focus of this paper (accessing and synthesising building databases) could leverage.

Two-way connections between building logbooks produced by private companies and nationwide databases, such as Home Analytics and Scotland’s Heat Map, could create a joined up, dynamic and holistic data environment about buildings, and have positive impacts extending beyond the current aims of the Heat in Buildings Bill.

The provision of property logbooks is now mandatory in France for newbuilds and retrofitted properties (Today’s Conveyancer, 2023). A European research project (DemoBLog) is contributing to the evidence that a holistic and digital approach to building data can accelerate reduced environmental impact of buildings (European Commission, 2023).

A Scottish equivalent is the recommendations of the Scottish Parliamentary Working Group on Tenement Maintenance and their proposal for five-yearly inspection reports. These documents would include Building Passport-level information on the mutual parts of tenements and be mandated by statute. To be useful in the context of HiB compliance, they would have to then be digitised and accessible.

Modelled vs measured

Measured or observed data comprises data captured in-situ and reported directly without processing. However, we found that very few properties have had an in-situ performance measurement, and that sample sizes would be too small to extrapolate to the whole stock, or even to archetypes. While this data can be relied upon to measure compliance, this data is incomplete (more measurements should be made) or stale/lag (which can be addressed by update points described below).

Where it hasn’t been possible to measure data in situ, chiefly due to the cost of surveying, tools have sought to model (or predict) data based on a variety of criteria, such as similar typologies nearby and assumed occupant behaviours. As noted above, this is a core component of Home Analytics, but it is also used in some of the private sector databases.

This distinction becomes complex as EPCs use observed data as an input, and then use software to model energy usage and fabric based heating demand, making them a hybrid of both.

Compliance monitoring relying on modelled/predicted data may lead to disputed findings where the approved modelling is shown to conflict with real-world observed measurements. For instance, should an RdSAP-based EPC state that fabric based heat demand is over 120kw/sqm/year, but measured heat demand proves to be lower, would the property be deemed to be in compliance? This is an important matter for an upcoming Bill to make clear, with consequences for a digital compliance monitoring system.

Update points

As noted above, EPCs are required by regulations:

• When a domestic or non-domestic building is built, sold, or leased (when advertised for such).
• As a condition of receiving funding, such as grants for energy improvement works (Home Energy Scotland, Business Energy Scotland, or Local Energy Scotland), or ECO (which requires PAS2035).

These update points allow for the refresh of data, which, over a period of months trickles all the way through to various datasets, including Home Analytics, and others. Having more update points, such as at any intervention listed in the Standard, would help measure compliance using existing datasets.

Several key triggers are noted in the HiB Bill consultation, including one focussing on the property’s purchase. The chances of the HIB trigger points, and the trigger points for updating the other databases, aligning in a reasonable time frame should be considered. For instance, if an EPC is updated on purchase to show that the building is not on a clean heating system, and then one is installed without an obligation to have a new EPC created, and then the Scottish Government checks for compliance, the record would show that the building does not comply.

Confidence and risk

Variation in data quality and the widespread use of modelling to produce apparently complete datasets has led to lack of trust from practitioners, who like to rely on their own measurements prior to providing retrofit advice. This has been a primary driver behind the UK and Scottish Government’s recent work to ‘improve’ or ‘enhance’ areas such as the process and content of EPCs (Scottish Government, 2023). Concern over data quality is not unique to the construction and property sectors. A challenge for the Scottish Government is how any existing data source can be used to check for compliance if the data is of potential uncertain provenance and fidelity.

The traditional construction and property sectors used a structure of insurances, professional qualifications, and codes of ethics to provide a quality assurance system for work with buildings. Where advice and design is concerned, this system relies on professional indemnity insurance backed up with chartered professionals such as architects, surveyors and engineers. These structures are notably absent from the energy efficiency and retrofit sector, which contributes to a lower level of trust in the sector by the public.

There is some quality assurance built into some of the datasets the study team reviewed. For example, Trustmark, via the Scheme Providers, carries out sampling of EPCs to check for compliance against the standard process for producing EPCs. Some private operators align and utilise British Standards quality assurance or data management certifications.

Energy focus

A significant number of the datasets reviewed are focused on energy (kWh/sq.m/year), rather than building fabric, or connection to a heat network zone. The reasons for this are varied, though perhaps linked to the prevalence of EPC bands as a primary focus in recent years. EPC data includes building fabric information, which can be used for HiB Standard monitoring and compliance, though this is not present where just the EPC band itself is used in a given database. From this we observe that the EPC data is more useful for monitoring and compliance than just the EPC band itself.

The future of EPCs

An obvious challenge to basing a compliance scheme on EPC data modelling is the ongoing initiatives in the public sector that could result in changes to the methodology and outputs of the EPC over the next few years. The Scottish Government refer to their ambition to improve the EPC in the HiB Bill consultation and recently consulted on a range of options. In parallel, the UK Government is looking to replace SAP with the Home Energy Model (HEM).

Self-certification

In researching compliance against the Heat in Buildings Standard we considered the potential approaches involving either self-declaration (relying solely on the building owner/occupant), or the role of existing compliance and check mechanisms.

Below we have outlined examples of self-certification compliance approaches:

The census: it is mandatory for everyone to complete the census. There are fines for not doing so, or for giving false information. There is not, as far as we’re aware, a process for checking the validity of information given by respondents to the census. However, there is no gain or loss to the person completing the census for the information they provide, and so there is no particular pressure to report any given way.

Building Standards: Building Standards (the control over building regulation consent in Scotland) requires drawings to be submitted showing how the proposed works meet the building regulations. A Building Warrant is issued, enabling the works to be built legally by the local authority when they deem the proposals meet the Building Regulations. At the end of the works, the client or their representative issues a Completion Certificate, self-certifying that the works meet the drawings consented as part of the warrant. The Local Authority does spot-checks on the works to confirm that this is the case, and, if satisfied, will issue an Acceptance of Completion Certificate.

SER: the Structural Engineers Register is a limited company appointed by the Scottish Government’s Building Standards Division to administer a scheme for Certification of Design (Building Structures). This is one of only two areas where self-certification is allowed. The scheme requires structural engineering firms and individual engineers to maintain registration with SER though qualifications and audits of their work. This allows them to sign off the structural design of buildings and avoid review by the local authority. The oversight of the scheme is stringent and the structural calculation assessments are checked by a separate engineer. For Section 6 of the Building Regulations (Energy), there is an online submission procedure administered by RIAS.

EPCs: Domestic Energy Assessors (DEAs) undergo a 3-day training course, submit photo evidence of their inspections, and are checked on a percentage of their assessments. They carry Professional Indemnity Insurance (PII), they have a code of practice administered through Trustmark, and are required to carry out Continual Professional Development (CPD). Their obligation is to run the RdSAP process correctly, but they are not responsible for the result of the EPC, or for the recommendations given by the EPC (which are generated by algorithm).

MOTs: In the case of motor vehicles, cars must have an MOT annually and hold a certificate stating they meet the checklist of performance indicators. Qualified test centres check this, for which there is a nominal charge. Any factors not in compliance are notified to the vehicle owner/user. Using a car which has failed to pass a MOT certificate means it is illegal to drive the vehicle.

Competent person: A “competent person” is required to carry out processes mandated by organisations like RICS, and this level of qualification is set out in the relevant professional standard. BS7913 sets best practices for work with historic buildings and establishes the role of a “competent person” and what qualifies a person as such. In both cases, funders or clients of work to which this competence relates require this standard to be met to enable them to fund the work.

Self-reporting

Self-reporting may be suitable for reporting compliance with the clean heating system mandate, with checks being carried out at purchase (such as the Building Warrant used for new build, or for existing buildings where the assessment is included within the pre-sale survey of the building). If a statement has been made that a clean heating source is present, but this is found not to be the case on sale by the Home Report Surveyor, then the sale value is likely to be affected and may fall foul of the Sale of Goods Act (1979).

Self-reporting is however more complex for the energy efficiency standard, as the definition of something seemingly simple, such as the loft-roll being compliant, varies from standard to standard. Questions arise, such as whether it is evenly installed, pushed into corners, whether there is a vapour control layer under it, whether it is dressed around the cold-water storage tank, etc. A further challenge is that not everyone is able to access the loft, or sufficiently computer-literate to use the digital systems. It is our recommendation that some form of survey by an assessor with some level of training and consumer protection could undertake this work.

The energy efficiency metric (kW/m²) is more complex still, as it requires training in how to use a dedicated piece of software, and how to reliably enter data to get consistent results. Again, we propose that a competent assessor is best placed to carry out this work

Finally, homeowners must seek advice on what alterations to make to a property to make it compliant. At present, the RdSAP EPC is very clear that the recommendations are suggestions, and not “advice” to be followed without further checks. This distinction frequently escapes the public, which could lead to widespread failure of retrofit to deliver reliable improvement. However, this is where an ‘archetypes approach’ for retrofit guidance could assist homeowners and property managers.

An advantage is that self-reporting can lead to wide societal engagement, and more education and agency over the task at hand.

The challenge with self-reporting is to incentivise individuals to do it and to make the process easy to comply with. The quality of self-reporting will vary. Like the census process, the questions being asked and the possible answers need to be precisely determined (such as using multiple choice answers). There is a risk of false reporting to gain advantage unless there is some policing/checking if the answers given will lead to any gain or loss.

Consultant reporting

The challenge with consultant reporting is that there are significant differences behind the designation of ‘consultant’, with training ranging from 3 days to 7 years. Some consultants have legally protected status, codes of ethics and some have a code of practice. Some carry PII, some don’t. PII only insures the advice given for a certain area of competence. For instance, a structural engineer’s PII will not pay out if the advice was given on non-structural matters. Both the PII and the confirmed area of competence are therefore important. Without PII and a defined area of competence, there is no consumer protection for the advice given by the consultant.

There are differentiations between different specialisms. We suggest it would be useful to conduct further research assessing how HiB Standard compliance could be conducted by different disciplines and roles, their areas of competence required, and requirements for PII.

Reporting should show confidence rating linked to the qualifications/ability/consumer protection of the person making the statement. Red/Amber/Green ratings are used by some, others (Home Analytics for example) used percentages.

Options to consider

This study suggests three main options that may be considered by the Scottish Government for the establishment of a digital compliance and monitoring tool.

Option 1: Use existing data sources in their current locations

Data sources remain in their current locations, with two options:

1. Option 1a. Homeowners are required to self-report into these locations and upload evidence.
2. Option 1b. Professional reporting into existing locations (status quo).

For both options, the responsibility to demonstrate compliance rests with the homeowner with either self-reporting or professionals reporting.

Advantages

1. Requires little investment from the government.

Drawbacks

1. Would likely be difficult for homeowners due to the complexities of the Standard and the need to look for information in various places.
2. It may be long-winded for owners who are not familiar with digital technology.
3. Reduced consistency if homeowner reporting, rather than a professional with PII.

Requirements

1. Create “how-to” guides to help homeowners understand where they can gather the information.
2. Ensure that the appropriate data sharing mechanisms and identity verification mechanisms are in place so that information can be queried from data holders by homeowners.
3. Ensure that non-digital means of accessing the information are available.
4. Identify opportunities for market to engage; district heating providers to broker connections between public/commercial anchor load buildings and homes in heat zones, clean heat system providers provide support apps/websites, surveyors promote building assessment services.

Option 2: Professional reporting from linked databases

Data remains in its current locations. Government looks at a single portal, which in turn looks at existing sources. The responsibility to assess compliance could rest with the government or homeowners, but the government must first create a means of collating the relevant information on a per property basis.

Advantages

1. Saves homeowners’ time.
2. Gives the government a more comprehensive picture of any property in the country.
3. Makes property data more actionable and consistent in reporting
4. Public facing online data input platforms already exist, with confidence ratings, allowing self-monitoring at the front end. Back-end data logging to be linked by unique identifier.
5. Consumer protection and consistency of data due to presence of PII.

Drawbacks

1. Requires more technical investment from the government
2. Medium risk to privacy infringements

Requirements

1. Create or generalise the use a unique identifier per property
2. Create more data update points
3. Create or use an existing data nomenclature and phraseology
4. Review and update existing data sharing agreements with relevant data holders
5. Create APIs to enable data transfer
6. Create a public facing ‘check if your building is compliant’ government portal such as Check vehicle tax

Option 3: Professional reporting into a new central database

Data is moved from existing data sources to a new government-managed platform. The responsibility to assess compliance could rest with the government or the homeowners, but the government must first gather all relevant information on all properties in a new data holding structure.

Advantages

• Saves homeowners’ time
• Gives the government a complete picture of every property in the country
• Makes property data more actionable and enhances consistency of reporting.
• Provides country-level insights on all property and energy needs
• Enables more modelling and place-based answers to decarbonisation needs.
• Consumer protection and consistency of data due to presence of PII

Drawbacks

1. Requires significant government investment
2. Could be construed as government overreach
3. Existing data custodians could offer pushback
4. Might slow down innovation if human resources are not devoted to exploiting data
5. Higher risk to privacy infringements.

Requirements

1. Create or generalise the use of an unique identifier per property
2. Create a public facing ‘check if your building is compliant’ government portal such as Check vehicle tax
3. Create more data update points
4. Create or use an existing data nomenclature and phraseology
5. Create technical infrastructure required to hold data
6. Terminate existing data sharing agreements with relevant data holders and organise data handover
7. Either create APIs to enable data transfer between existing data custodians and the government, or change the data lodging mechanisms to feed in directly into the government data lake
8. Create a frontend dashboard to query information from all databases at once
9. Identify opportunities to exploit data strategically.

Further Key Considerations

The following points should be considered alongside the options set out above.

Data governance

The industry suffers from a lack of commonly agreed standards and procedures which would allow data to flow between organisations and databases. While there exists virtually no technical difficulty in moving data across platforms, the legal basis for this, the format of the data, and the necessary safeguards in terms of data ownership, are absent.

This lack of such a data governance framework is a significant hurdle to the emergence of the retrofit industry, and ultimately, the decarbonisation agenda. To fill the gap, private sector actors have been forming associations and trade bodies, to formulate answers to these issues, such as the Open Property Data Association or Residential Logbooks Association. Our view based on our research and experience is that for real progress to be made, governments will need to take ownership of the data governance issue and standardisation of process and reporting structure, participate in industry work, and eventually endorse the outcomes of this work, as was done when the UK Government endorsed the SAP methodology for assessing buildings.

In general, providing that the ownership of a given property can be proven (such as through the Property Data Trust Framework), publicly-owned information about a property should be available free of charge to that property’s owner, and their consultants.

Identifying and indexing

There is currently no comprehensive way to identify every structure considered a separate building in Scotland. Several possibilities exist. UPRN would be a good way forward for domestic properties compliance, but less so for non-domestic buildings. A separate piece of work is required to find a way to identify and index all buildings to which the Standard and associated monitoring and compliance checking will apply.

Archetype approaches

An exercise to analyse how archetype approaches and interventions could support a compliance methodology may be useful, considering the high number of house and apartment types within an archetype construction (e.g., tenements, timber frame, no fines). Studies and reports have cited archetypes approaches [ (ZEST Taskforce, 2021), (Smith, 2021), (Bros-Williamson & Smith, 2024)] to retrofit, and archetype-specific list of measures to be applied to demonstrate compliance aligned to a specific EPC band.

Common Scheme Standardisation / nomenclature

A significant piece of work would be required to ensure that, once a building identifier has been produced, the data attached to this identifier is labelled according to a nomenclature shared across the industry. The work required would involve:

1. Determining a common format in which input data pertinent to retrofit objectives can be collected to enable interoperability, transfer and actionability regardless of provenance and destination.
2. Determining a common format for output data reflecting the resulting programme of works.
3. Encouraging any relevant organisation to adopt the standard, starting with property logbook providers.
4. Working with governments to publicise the scheme and insert it within the Property Data Trust Framework.

Data access and data sharing

Building data is the fundamental building block on which national retrofit efforts are planned and delivered. Without easy access to publicly-owned information about their property, homeowners may delay their investigations and home improvements. Without free access to publicly-owned information about their property, homeowners could be made to finance organisations that have no ownership of this data. The study team believes that a strict distinction should be made between publicly-owned and privately-owned data, and that the former be made readily available to appropriate persons.

Beyond operational energy

The primary emphasis of the HiB Bill consultation centres on promoting clean heating systems, such as heat networks or individual building systems powered by clean electricity, and on fabric improvements. The focus on building fabric does not include comment on the condition of the building, which is a factor of fabric performance. Factoring condition into the HiB Standard, on top of monitoring and compliance, could provide an opportunity to address the condition of the nation’s building stock as part of the retrofit agenda. We suggest that broadening the approach to compliance and monitoring to encompass building condition could offer an opportunity for synergistic improvement to fabric and energy and underpin a future legacy of a pan-Scotland built environment approach.

Appendices

Question List/Appendix A

Table 6 Areas of discussion with database owners

Detailed commentary to section 4.3/Appendix B

Sasine Register. Not spoken to. Information in the study is from publicly available data on what the register does.

EPC Register. The EPC register is a database of all EPCs created for domestic and non-domestic buildings in Scotland. It is managed by the Energy Savings Trust.

Valuation Database. Not spoken to. Information in the study is from publicly available data on what the Database does.

Scottish House Condition Survey. This is a subset of the Scottish Household Survey who survey 10,000 households a year, asking a huge range of demographic questions (age, disabilities, activities, etc.). They then re-survey 3,000 dwellings with a physical inspector (assessor, architect), who do a full physical survey, recording everything about the house in terms of energy efficiency (fuel, central heating, insulation, age and efficiency of boiler) and things like disrepair. The selection of buildings is intentionally representative of the wider housing stock.

Scotlis. The land register can be used to find property prices, view boundaries on a map, check if land or property is on the land register, and identify who owns the property. Not spoken to. Information in the study is from publicly available data on what the register does.

PAS2035 Data Warehouse. Trustmark hosts retrofit lodgement data (PAS2035) for buildings that have been retrofitted under government funded retrofit schemes. This includes information about the retrofit work done. Each home is lodged individually. Trustmark’s key role is quality assurance, so they test a sample of these installations using a risk-based approach for desktop and on-site audit using the information uploaded to the data warehouse.

Detailed commentary to section 4.4/Appendix C

Scotland Heat Map. It is a GIS tool, a collection of datasets, that primarily Local Authorities use to check for demand for heat, to help introduce policies to reduce CO₂ from heat production. Are areas suitable for heat networks. It is one of the core datasets in LHEES. At the moment some Local Authority LHEES are being uploaded to it. It’s about bringing data together in a spatial way. The main metric is heat demand metrics generated from a range of sources. Based on UPRN, they have a strong relationship with the Ordnance Survey. Uses a layered approach, footprint on an OS map, and applying energy benchmarks. Different sources of subjective reliability. Indicative tool bringing together data generated for other purposes, have to make some gross assumptions based on not much information. It answers the question: does this area look promising for heat networks?

Improvement Service. This is a data sharing portal. It helps Local Authorities make data useable, standardised, and actionable. Their first big project was to put some order to the property address dataset.

Public Sector Benchmarking. They have performed energy benchmarking analysis for Scottish Public Sector assets. It shows data for a “typical” building of that type to compare against “best practice”. Public sector building managers can then compare their building to that. The point of this document was always to do comparisons. Highland Council have taken this data and analysed the whole estate and made the data public but that is yet to happen elsewhere.

Home Analytics. It’s an address level database with information on all properties in Scotland ranging from building characteristics to heating systems based on the RdSAP input and output data from domestic EPCs. It contains more or less half of all buildings as survey data and uses algorithms to create assumed EPCs for those which don’t exist. It is indexed by UPRN (which is produced by Ordnance Survey). Installations which require a new EPC due to funding rules will lead to this data ending up in Home Analytics, which is uploaded/updated every 6 months.

Non-Domestic Analytics. The EST team who run this were not spoken to, so the data in our report is based on publicly available information about non-domestic analytics. Like Home Analytics but for non-domestic buildings. It contains everything Home Analytics does, except there is less modelling behind it. Fewer non-domestic properties have an EPC, so there are more unknowns. Big exception is access.

DREam. Home analytics data augmented with IR survey results and asset management data provided by a private company IRT. The dataset remains the property of the Local Authority or RSL commissioning the study.

National Grid ESO. This tool cross-compares other datasets to provide long term energy forecasting for domestic and non-domestic demands, and potential opportunities as the nation decarbonises.

National Household Model. Not interviewed.

Detailed commentary to section 4.5/Appendix D

Kuppa. A modelling tool for options appraisal: “Kuppa gives you a holistic view of a home’s energy performance, now, and how it could be in the future.”

Zoopla. Not interviewed.

National Buildings Database. Emergency services and safety data, edging into climate resilience currently under development by Edinburgh University and others.

Shedyt. Shedyt is a digital homeowner manual which exists to simplify property management for occupiers in collaboration with a marketplace of real estate experts, starting with residential property developers. It’s a tech company first and foremost, offering a marketplace. They match property developers to the people who sell to them. When a newbuild goes up, everything is specced up: the aim is to not throw this away. Long term ambition being to help the occupier down the line. Up to now, the data wasn’t captured for the benefit of the homeowner, but only themselves & legislation. The idea is to offer one place to manage your home idea.

The Property Logbook Company. Their business came from the legal side of use cases. In 2003 the land registry went from analogue to electronic titles. All the analogue documents become irrelevant when things went digital. Going digital has actually slowed down conveyancing. PLC suggested making “the big warehouse” digital to overcome that – for the lawyer, it provided the certainty that a document existed. It’s a digital interpretation of a very analogue process. PLC built B2B business which the consumer accessed whenever they bought and sold properties. The homeowner has access to the system. When they put new windows in, for example, they can upload the document to evidence this

Single Survey. The single survey is a condition survey presented in a legislatively mandated format, standardised for all homes transacted in Scotland. The data gathering and report production is by proprietary software created by the individual providers. Quest (owned by Landmark) have a database. OneSurvey, in Scotland, is controlled by Allied Surveyors. MovMachine in Edinburgh (ESPC) is used as CRM. SurvPoint is used by Shepherds is also used as CRM and Project Management platform. Quest is £12/use. The data is owned by the surveying firm. Information gathered is given to Rightmove, Zoopla etc. this information could’ve been collated centrally, but RICS didn’t proceed with the idea. The richer data is in the Surveyor’s notes, but that’s difficult to access. It could be possible to strip out the condition codes from the online databases. Postal address is key identifier.

PropEco. Futureproofing home with advanced data and analytics

Chimni. A property logbook company. Secure digital record of all transactions (conveyancing), maintenance, DIY and certifications (such as connectivity with EPC register), Trustmark supporting retrofit. They provide an additional group of APIs which allows a homeowner to access the info that sits in the Trustmark Data Warehouse. Their aim is building API certifications with as many places as possible.

Kamma Data. Originally a geospatial map company. The first thing they do is attach UPRN to addresses. Their end product is data. They note that property data is poor quality, with no proper framework and thus inconsistent. They’ve built a machine learning module which helps match properties together and build a profile for property. They have a retrofit automation tool which takes pricing data and data from the national grid to make recommendations, making it an optimisation engine.

Novoville Shared Works. A property logbook/building passport looking at people, property and its constituent elements. Structured around RICS, RIBA and GFI frameworks for data and cross-compatible with RdSAP data structures, Shared Works can connect to thermal modelling engines such as Scene to provide retrofit optioneering to build a plan which is then audited by a construction professional such as an architect or surveyor. The Shared Works Building Passport can be looked at alongside other to form buying communities and so create community groups and cost efficiencies.

Kestrix. Similar to IRT’s DREam but coming at it from different direction. Kestrix’s premise is scalability of IR to the building energy efficiency market, and once scaled to work towards accuracy. The lack of accurate actionable data is the challenge they’re trying to solve. Their tool captures vision and thermal imagery to build 3D models. Their goal is to get to U Values from IR. They aim to create a more accurate than EPC building physics model to leverage and make retrofit recommendations for portfolio. The imagery is aerial, oblique shot from drones, thermal imagery shot at night, private mode right now, project based. They outsource the drone work. They are a software company.

Property Identifier Commentary/Appendix E

UPRNs

Of all the above, the Unique Property Reference Numbers (UPRNs) appear as the best way of identifying private residential buildings. This is because they are already used in many of the datasets reviewed, they are unique, and supported by the Ordnance Survey.

For those working with non-domestic buildings where different buildings may all reside on one campus, UPRNs were deemed insufficient by some of the interviewees since several buildings will share one UPRN yet may be very different.

Property Title Numbers

When HM Land Registry register a property, they give it a unique reference called a title number and prepare both a register and, in most cases, a title plan. Like the UPRN, this is connected to the legal property, and so would be the same for individual structures all on the same legal title and therefore present shortcomings when dealing with some non-domestic buildings.

MPRN

MPRNs act as unique identifiers for the gas meter in each building. However, with the ongoing decarbonisation of homes and considering the 16% of the Scottish housing stock not connected to the gas grid, the use of MPRNs related to gas would not provide adequate coverage and might over time become a redundant identifier.

MPAN

A meter point access number (MPAN) is used for electric meters in buildings. As with MPRNs, these identifiers are not suitable, as some buildings have several meters, and some meters serve more than one building.

VOA

In December 2023 the Dept for Net Zero and Energy Security established a research project to develop a National Buildings Database (commencing with non-domestic buildings). One of the potential identifier codes for each building that may be used is the Valuation Office Agency (VOA) registration for each building. The Property Details dataset was introduced in the 1970s and was originally known as the Dwelling House Coding guide. Its original purpose was to provide a simple system for understanding the main features and attributes of a property. VOA datasets do not contain information about individuals or households. The information VOA collects and holds about domestic properties supports statutory functions for valuation and maintenance of Council Tax lists under the Local Government Finance Act 1992. It’s the statutory requirement of VOA to maintain accurate valuation lists for Council Tax. However, VOA only collects data needed to place an accurate band on the property.

As council tax is operated separately in Scotland and given the separate laws and regulations for Scotland’s property, it may be useful to determine if there is a Scottish equivalent identifying code which could be utilised as part of the monitoring and tracking of HiBs.

Outside of Britain

Unique Building Identifier (UBID) is an initiative by the US Department of Energy (DOE) to establish a system for generating and maintaining unique ID’s for all buildings across the planet. The UBID algorithm generates a unique ID based on the geo-spatial location and form of a building footprint. A unique building ID will provide a universal indexing mechanism for the collection, linking and aggregation of building-centric data from disparate sources (see: GitHub – Open city model data for the United States).

References

BRE Trust, 2020. The Housing Stock of the United Kingdom. [Online]
Available at: https://www.gov.scot/publications/delivering-net-zero-scotlands-buildings-consultation-proposals-heat-buildings-bill/pages/1/

Bros-Williamson, J. & Smith, S., 2024. Applying a retrofit and low-carbon technology archetype approach to buildings in Scotland, Edinburgh: University of Edinburgh.

European Commission, 2023. Demo-BLog – Development and Demonstration of Digital Building Logbooks. [Online]
Available at: https://build-up.ec.europa.eu/en/resources-and-tools/links/demo-blog-development-and-demonstration-digital-building-logbooks

National Records of Scotland, 2023. Housing. [Online]
Available at: https://www.gov.scot/publications/delivering-net-zero-scotlands-buildings-consultation-proposals-heat-buildings-bill/pages/1/

Office for National Statistics, 2023. Housing, England and Wales: Census 2021. [Online]
Available at: https://www.gov.scot/publications/delivering-net-zero-scotlands-buildings-consultation-proposals-heat-buildings-bill/pages/1/

PBC Today, 2022. Timber frame homes UK market to rise by £70m. [Online]
Available at: https://www.pbctoday.co.uk/news/mmc-news/timber-frame-homes- uk/107522/#:~:text=In%20Scotland%20timber%20frame%20homes,%2C%20rising%20by%20almost%2060%25

Reed, R., 2021. Property Development. Abingdon: Routledge.

Registers of Scotland, 2023. Property market report 2022-23. [Online]
Available at: https://www.ros.gov.uk/data-and-statistics/property-market-report-2022-23#:~:text=In%202022%2D23%3A,when%20compared%20with%202021%2D22

Scottish Government, 2021. Heat in Buildings Strategy – achieving net zero emissions in Scotland’s buildings. [Online]
Available at: https://www.gov.scot/publications/heat-buildings-strategy-achieving-net-zero-emissions-scotlands-buildings/

Scottish Government, 2023. Building standards approved energy assessment software: guidance. [Online]
Available at: https://www.gov.scot/publications/building-standards-approved-energy-assessment-software-guidance/

Scottish Government, 2023. Delivering net zero for Scotland’s buildings – Heat in Buildings Bill consultation. [Online]
Available at: https://www.gov.scot/publications/delivering-net-zero-scotlands-buildings-consultation-proposals-heat-buildings-bill/pages/1/

Scottish Government, 2023. Energy Performance Certificate (EPC) reform: consultation. [Online]
Available at: https://www.gov.scot/publications/energy-performance-certificate-epc-reform-consultation/pages/2/

Scottish Government, nd. Scottish House Condition Survey: Collection. [Online]
Available at: https://www.gov.scot/collections/scottish-house-condition-survey/

Serin, B., Kintrea, K. & Gibb, K., 2018. Social housing in Scotland. [Online]
Available at: https://housingevidence.ac.uk/wp-content/uploads/2024/03/R2018_SHPWG_Scotland.pdf

Smith, S., 2021. Developing Net Zero Technical Solutions for Scotland’s Future Mass Retrofit Housing Programme, Edinburgh: Scottish Government.

Today’s Conveyancer, 2023. Property logbooks made compulsory in France. [Online]
Available at: https://todaysconveyancer.co.uk/property-logbooks-made-compulsory-france/

ZEST Taskforce, 2021. Achieving net zero in social housing: The Zero Emissions Social Housing Taskforce Report. [Online]
Available at: https://www.gov.scot/binaries/content/documents/govscot/publications/independent-report/2021/08/achieving-net-zero-social-housing-zero-emissions-social-housing-taskforce-report/documents/zero-emissions-social-housing-taskforce-report/zero-emissions-social

© The University of Edinburgh, 2024
Prepared by EALA Impacts CIC, Novoville and University of Edinburgh on behalf of ClimateXChange, The University of Edinburgh. All rights reserved.

While every effort is made to ensure the information in this report is accurate, no legal responsibility is accepted for any errors, omissions or misleading statements. The views expressed represent those of the author(s), and do not necessarily represent those of the host institutions or funders.

1. https://epbd-ca.eu/wp-content/uploads/2021/07/Implementation-of-the-EPBD-in-the-United-Kingdom-%E2%80%93-Scotland-%E2%80%93-2020.pdf ↑
   

Research completed in August 2024

DOI: http://dx.doi.org/10.7488/era/4792

Executive Summary

Background

The UK Climate Change Committee states that adjustments to dietary patterns are necessary to meet greenhouse gas (GHG) reduction targets for Scotland. Food-based dietary guidelines (FBDGs) have a policy role to play in supporting such adjustments.

Drawing on international evidence including three case studies, this report presents findings on whether and how greenhouse gas emission criteria could be included in Scottish FBDGs.

Main findings

• Out of 33 jurisdictions reviewed, only seven have FBDGs with extensive climate focus. However, this number is increasing over time.
  
• Emissions-focused FBGDs advise reducing meat, in particular ruminant meat; moderating dairy; increasing vegetables, fruits and plant proteins; sourcing sustainably; avoiding highly processed foods and reducing food waste.
  
• FBDGs for Flanders, the Netherlands and Sweden offer good examples of how dietary linkages between human and planetary health can be explained with clear recommendations for food consumers.
  
• Development of climate-focused FBDGs suits a ‘science first’ approach, involving cross-disciplinary expert panels and reviews. Stakeholder inputs are restricted to the final steps of messaging and implementation.
  
• Policy implementation for climate-friendly diets requires coordinated effort and strategic packages of measures, to tackle the food system holistically.
  
• In Flanders, the Netherlands and Sweden, policy coordination has been lacking. Measures to date are largely limited to information campaigns and voluntary actions in public catering.
  
• More recently, Flanders and the Netherlands have launched more integrative food strategies. They are starting to combine policy measures across the food chain to encourage more sustainable diets.
  

Implications for Scotland:

• Adopting climate-focused FBDGs would require time and effort, but would be a generally low-regret action, aligning with dietary goals and the net zero agenda.
  
• Some micronutrient deficiency risks are possible for certain population groups, depending on which foods are substituted. Other potential risks include displacement of GHG emissions from import/export activities.
  
• To address such issues, a coordinated cross-departmental policy approach would be needed, deploying a mix of supply-side and demand-side measures.
  
• In particular, households at risk of micronutrient deficiencies due to constrained access to healthy foods would need targeted support, including improvements to their food environments.
  

Glossary / Abbreviations table

Introduction

Background

The food system is a significant emitter of greenhouse gases (GHGs), accounting for up to 30% of emissions globally and at least 20% within Scotland.^[1] As other sectors of the economy (e.g. energy) decarbonise, food’s share of total emissions will increase over time. Mitigation of this can be (and is being) attempted through changes to the production methods of the foods that currently comprise our diets (e.g. via improved plant and animal health and reductions in chemical inputs).

Yet meeting GHG emission targets will also require changes to diets themselves, towards those featuring greater proportions of climate-friendly foods. Dietary shifts for climate reasons must also, of course, promote human health, a dual imperative that is captured in concepts such as the Planetary Health Diet.^[2]

Scottish Government commitments to a sustainable, healthy food system and associated emission reductions are expressed in the Programme for Government 2023/24 and underpinned by, for example, the Good Food Nation (Scotland) Act 2022, the Climate Change (Scotland) Act 2009 (and subsequent amendments) and Climate Change Plan Updates.^[3] In the Scottish Dietary Goals, the aim to reduce red and red processed meat intake to no more than 70g/day, due to the links with colorectal cancer, is also broadly consistent with the UK Climate Change Committee’s recommendation of a 20% reduction in meat by 2030 to reduce emissions.^[4]

The current UK Food Based Dietary Guidance (FBDG) is the Eatwell Guide^[5]. Studies indicate that a diet following the Eatwell Guide generates lower emissions than the current UK diet^[6]. However, diets based on many FBDGs globally, including the Eatwell Guide, exceed emissions targets for 1.5 degrees global warming^[7]. Hence this report was commissioned to gather international evidence on more climate-focused FBDGs, and explore how they may potentially apply in Scotland.

The specific project objectives were to:

(i) explore dietary guidelines and recommendations in other jurisdictions;

(ii) explore the extent to which these have a climate focus;

(iii) identify what policies, strategies and actions have been taken to encourage progress to the guidelines;

(iv) discuss what could potentially apply in Scotland, drawing on Scottish data and evidence, and

(v) explore impacts on different groups in Scotland, e.g. gender, age, social class, vulnerable groups.

The findings are relevant to the UK Climate Change Committee’s statement that meeting Scottish emission reduction targets will require changes to dietary patterns. The findings are also relevant to future revisions of the Scottish Dietary Goals.

Project Methods

The project was undertaken in five steps, from October 2023 to March 2024. The steps are shown in Figure 1.1 and described below.

Step 1: Guided by the Steering Group, and with reference to published studies, we selected the FBDGs of 33 international jurisdictions for inclusion in the study. The set comprised mainly European and anglophone jurisdictions.

Step 2: Using FAO resources and online documentation, we accessed the FBDGs in all 33 jurisdictions, and reviewed each one for reference to climate. We allocated each FBDG to one of three categories, according to the extent of climate focus: from ‘red’ (little to no reference to climate) to ‘green’ (extensive climate focus).

Step 3: Following discussion with the Steering Group, we selected three example ‘green’ FBDGs to examine in more detail. These were Flanders, the Netherlands and Sweden. In each case, we identified the main advice and how it is linked to climate. We also studied the development process for the FBDGs. Lastly, we reviewed key policies, strategies and actions taken to implement the FBDGs. The main data sources were online materials and grey literature. These were supported by semi-structured interviews with officials involved in the development of the guidance in each jurisdiction (see Appendix A).

Step 4: We compared the insights from the 3 jurisdictions with the current situation in Scotland, drawing from official data sources and recent studies. We then reflected on what could potentially apply in Scotland, in terms of more climate-focused FBDGs and supporting policies. These reflections drew from published studies and official statistics, and were also informed by semi-structured interviews with a range of Scottish stakeholder groups. Guided by the Steering Group, these groups were: ASSIST FM; the British Dietetics Association; Food and Drink Federation Scotland; National Farmers Union Scotland; Nesta; Soil Association Scotland.

Step 5: We explored the impacts of more climate-focused FBDGs on different sub-groups in Scotland. The key data sources were official dietary statistics and recent studies of potential impacts of climate focused diets in Scotland.

International review of FBDGs

Review of FBDGs in other jurisdictions, with reference to climate criteria

Appendix B provides a tabulated summary of information for all 33 FBDGs included in the review, on a country by country basis. Appendix C summarises the intakes for key food groups (all meat, red/processed meat, dairy, fruit and vegetables) as stated in the FBDGs for 22 of the 33 jurisdictions.

Of the 33 FBDGs studied, we found the majority (19) contained no or extremely limited reference to climate impact. Six contained moderate reference, while seven contained extensive reference (Table 2.1). It is worth noting that although the majority of countries have yet to explicitly include reference to climate in their FBDGs, or are still at the development phase, the number is increasing over time. For example, all the entries in the Extensive column have emerged in the past decade.

Jurisdictions in the red column: these have FBDGs which make no reference to climate impact, or only very limited reference, in either background or consumer-facing documents. ‘Limited reference’ denotes guidance which mentions sustainability, but only in an isolated way, and without any explanation or context. For example, the FBDGs of Austria and the UK (Eatwell Guide) both recommend choosing ‘sustainably sourced’ fish, by looking for MSC or similar labelling. However, this is the only reference to sustainability in the documents (i.e. no other food group has a similar recommendation), and there is no explanatory connection to the underlying sustainability issue with fishing.

Jurisdictions in the amber column: these FBDGs – in either consumer-facing or background documents – make more reference to climate than those in the red column. However, those references appear either in a circumscribed way, disconnected from the main guidance, or are individually brief or superficial within the body of the main guidance. An example of ‘circumscribed reference’ is the national guidance for Belgium. In the background document, there is a short stand-alone chapter dedicated to sustainability and climate, which explains the relevance to dietary issues. However, the contents are not connected to other chapters, and sustainability is not referred to in the consumer-facing guidance. An example of ‘superficial reference’ is the guidance for France. There are three individual references to climate and the environment in the consumer-facing guidance, however each one is very brief, without explanation of the underlying issues.

Jurisdictions in the green column: these FBDGs – in either the consumer-facing and/or background documents – make extensive reference to climate impact. The most advanced of these have climate impact as an integral component of the guidance, rather than an added feature, or set of ideas in development. Features that the ‘green’ FBDGs have in common include (i) introductory sections which make a clear connection between human health and planetary health, (ii) frequent references to climate impact throughout sections and applied to different food groups, (iii) effort (some more than others) to explain the reasons behind the climate-related guidance, and how consumers may navigate complexities and trade-offs between health and climate impacts.

Content of FBDGs with extensive climate focus

Overview of content

The jurisdictions found to have the most extensive reference to climate impact in their FBDGs were Denmark, Flanders, the Netherlands, Sweden and Finland. Germany and Spain are also included in this group, although their coverage is less extensive and integrated than the others^[8].

These FBDGs make a clear link between human health and planetary health, by pointing out that what we eat affects not only our own well-being but also the environment. In terms of over-arching consumption advice, these FBDGs recommend:

• eating less meat and animal products;
  
• eating more plants, plant proteins and wholegrains;
  
• choosing nutrient dense foods over nutrient poor;
  
• drinking tap water;
  
• not overeating;
  
• avoiding waste.
  

The following sections describe what these climate-focused FBDGs advise, by food group. Advice from the Eatwell Guide is also referenced, for comparison.

Advice relating to meat

All seven FBDGs advise reducing meat consumption, due to the high GHG emissions from meat production, in particular ruminant meat. Table 2.2 shows the maximum recommended intake levels for meat in the seven FBDGs, and the Eatwell Guide. Germany specifies the lowest maximum weekly intake for all meat (240g), while Finland and the Netherlands specify the highest (500g). The Eatwell Guide does not specify a maximum level for all meat. The Netherlands specifies the lowest maximum intake for red/processed meat (300g) while Sweden specifies the highest (500g). The Eatwell Guide specifies the second highest maximum intake for red/processed meat at 490g.

ns: not specified. Germany: ‘all meat’ includes beef. Red/processed is processed only.

Examples of qualitative advice on meat in these FBDGs:

• When choosing meat, select more sustainably produced options, e.g. organic or agroecological, following a ‘’less but better” approach (The Netherlands, Sweden).
  
• Diets based on small amounts of meat can support the positive effects of grazing livestock on landscape and biodiversity (The Netherlands, Sweden)
  
• Meat-free days per week are specifically recommended by Denmark, Finland (1) Flanders (up to 4), Netherlands (up to 6), Spain (up to 7) and Sweden (up to 3).
  

The Eatwell Guide advises eating less red and processed meat. It gives no advice on production systems, nor on meat-free days.

Advice relating to dairy

The seven climate-focused FBDGs advise moderation in dairy product consumption, due to the GHG emissions associated with dairy farming. Table 2.3 shows the recommended daily intake levels for selected dairy products in these FBDGs. For milk/yoghurt, Denmark and Germany recommend c.250ml, while most others recommend a range extending to 500ml at the upper boundary. For hard cheese, the lowest recommended intake is 20g (Denmark) and the highest maximum is 60g (Spain). Four out of the six FBDGs do not specify a set intake level for cheese, although Germany offers guidance on how to allocate a total dairy amount between different product types. The Eatwell Guide does not specify intake levels for any dairy products.

Examples of qualitative advice for dairy consumption in these FBDGs:

• Take enough dairy to avoid chronic diseases and get enough nutrients, but not more than that, because dairy products come from cows, which have a high environmental impact (The Netherlands).
  
• Eating moderate amounts of dairy can support the positive effects of grazing livestock on landscape and biodiversity (Sweden).
  
• Where possible, choose eco-labels like organic for the more sustainably produced options (Sweden).
  
• Eat fewer processed dairy products, to get the nutritional benefits without the added climate burden from extra processing stages (Finland).
  

The Eatwell Guide advises eating ‘some’ milk and dairy food (or dairy alternatives). It gives no advice on production systems or levels of processing.

Advice relating to vegetables, fruit and plant proteins

All seven FBDGs give very clear recommendations to eat more vegetables, fruits and plant proteins for climate reasons. Table 2.4 shows the specified daily intake levels for these foods. For vegetables and fruit, recommended intakes range from 450g (Netherlands) to 690g (Spain). By comparison, the Eatwell Guide recommends the lowest minimum intake: at least 400g. In terms of legumes, only Denmark, Germany and Spain specify minimum intakes, from 100g (Denmark) to 200g (Spain) per week. For nuts, all jurisdictions except Sweden recommend intakes, from 15g to 30g per day. The Eatwell Guide does not recommend intake levels for legumes or nuts.

Examples of qualitative advice for vegetables, fruits and plant proteins in these FBDGs:

• Eat vegetables and fruit in season, for lower carbon footprint (Flanders, Sweden).
  
• Choose field grown rather than glasshouse grown (Flanders, Sweden), although glasshouses powered with renewable energy can have similar footprints (Finland).
  
• Locally grown is not necessarily lower carbon (Flanders).
  
• Choose ecolabelled and organic to reduce climate impact (Sweden).
  
• Legumes are nitrogen-fixing, which saves use of nitrogen fertilizer (Finland).
  

The Eatwell Guide does not advise on production methods or seasonality in this group.

Advice relating to cereals, grains, fats and oils

All climate-focused FBDGs highlight that, in general, grains and cereals have relatively low carbon footprints. Recommended intakes range from 75g (Denmark) to 90g (Sweden) wholegrain foods per day. Rice is identified as a grain with a higher carbon footprint (Denmark, Sweden, Finland), hence, advice is to swap rice for other grains or potatoes.

In terms of fats and oils, plant-based oils are recommended over butter and spreads due to their lower carbon impact (Denmark, Finland, Sweden). Within plant oils, rapeseed oil is presented as a particularly sustainable option, with a low carbon footprint (Sweden).

The Eatwell Guide does not advise about types of grains or fats from a climate perspective. This means that rice is recommended equally alongside pasta and potatoes. It recommends oils from plant sources, such as rapeseed and olive oil, as these are unsaturated fats. The outcome is that the same oils are recommended by Eatwell and the climate-focused FBDGs.

Advice relating to high fat, salt and sugar (HFSS) foods ^[9]

The seven FBDGs, advise to consume as few foods as possible from this category. This benefits the environment because (i) many foods in this category are ultra-processed (UPF), containing ingredients/processes which are carbon intensive, and (ii) they are nutrient poor. As all food production has an environmental impact, it is best to consume foods that are nutrient dense, to make the environmental impact ‘count’. All the FBDGs recommend tap water as the lowest carbon impact beverage, and that bottled drinks, including bottled water, should be avoided for the sake of the planet.

For HFSS foods, the Eatwell Guide’s recommendations are to avoid or eat in small amounts. The outcome is therefore the same as climate-focused FBDGs. For beverages, unlike the climate-focused FBDGs, the Eatwell Guide does not distinguish between bottled and tap water, and includes milk and diet/sugar-free drinks as recommended drinks.

Advice relating to sustainability

All climate-focused FBDGs contain the strong common messages of (i) only eat as much as you need and (ii) avoid food waste. The latter is advised as important for the planet because every food item wasted has an environmental impact that could have been avoided. The Eatwell Guide advises to eat only as much food as you need. It does not include any advice about food waste.

Summary of similarities and differences between climate-focused FBDGs and the Eatwell Guide

Advice within climate-focused FBDGs which is in common with the Eatwell Guide:

• Limit intake of red and processed meat (although 5 out of 6 FBDGs set maximum intakes lower than the Eatwell Guide)
  
• Eat plenty of vegetables and fruit (although all 6 FBDGs recommend minimum intake levels higher than the Eatwell Guide)
  
• Choose vegetable oils, e.g. rapeseed or olive oil, over animal fats
  
• HFSS foods are non-essential to diet so only eat in small amounts
  
• Only eat as much as you need
  

Advice within climate-focused FBDGs, which is different from the Eatwell Guide:

• Eat less meat and animal products, while increasing intake of plants and plant proteins (includes advocating meat-free days)
  
• Moderate dairy intake
  
• Choose seasonal, field grown vegetables and fruits
  
• Choose foods from more sustainable production methods, e.g. organic
  
• Choose potatoes, pasta or other grains over rice
  
• Favour unprocessed or lightly processed foods, and avoid UPFs
  
• The only recommended drinks are tap water, tea and coffee
  
• Avoid food waste
  

Sub-national variation

Of the seven FBDGs reviewed in this section, several come from jurisdictions with a degree of sub-national devolution, with regional powers able to adopt different approaches to certain policy areas. However, although guidance may be presented with regional badging, most often we found the substantive content of FBDGs is the same in different parts of a given country. The Flanders region of Belgium was the only clear example of sub-national variation in FBDGs found by this study. Yet policies to encourage uptake of nationally uniform FBDG do vary regionally in some jurisdictions. For example, across Dutch and Swedish municipalities and Australian States and Canadian Provinces.^[10]

Case study: Flanders

This chapter provides an overview of the FBDGs in Flanders, how they were developed, and policy implementations to date. Appendix E provides more details.

FBDGs in Flanders: the Flanders Food Triangle

In Flanders, the FBDGs are captured in a 24-page consumer-facing document “Eating According to the Food Triangle: Good for Yourself and the Planet” (2021). It was developed by the Flemish Institute of Healthy Living (“Gezond Leven”), in cooperation with the Department of the Environment of the Flemish Government. The context of the guidance emphasises that the environmental impact of our food is currently greater than what our planet can bear, so dietary change is needed.

In terms of content, the Food Triangle (Figure 3.1) is offered as the basis for a healthy and environmentally responsible diet. It advises eating more vegetables, fruits, wholegrains and plant proteins, while eating less meat, butter and cheese. Discretionary foods (high in fat, salt and sugar) are separated from the triangle as non-essential to the diet, to be eaten ‘as little as possible’. This category includes processed meat. The guidance also recommends up to three or four days per week of meat-free meals. It provides links to support materials developed by Gezond Leven, including recipes for vegetarian meals and a seasonal buying guide for fruit and vegetables.

How the FBDGs were developed

A ‘science first’ approach was taken to develop the guidance. First, Gezond Leven and the Department of the Environment commissioned a review of scientific literature on the health and environmental impacts of dietary choices. Next, they convened a cross-disciplinary academic expert panel to help analyse the evidence and determine the core content of the final guidance. After this, public-facing messaging was designed and tested amongst citizens, with the support of experts in behaviour and communication. Only after the guidance was finalized were stakeholders consulted. Importantly, these consultations related only to the coordination and implementation of the guidance: they did not influence or change its substance.

Policies, strategies and actions related to the FBDGs

Various policy documents in Flanders have content aligned with the goals of the FBDGs, although they do not refer specifically to the guidance. For example, the ‘Strategic Plan: Flanders Lives Healthier in 2025’ and the ‘The Flemish Climate Policy Plan’ both refer to the need for changes to food consumption habits in the jurisdiction, for reasons of health and climate impact.

Recent strategies have also been launched with the aim to encourage more holistic, systems-based action on food than has been achieved historically. (In the past, policies for food have reflected departmental silos in government.) For example, the 2022 Flemish Food Strategy (“Go4Food”^[11]) sets out 11 ‘Food Deal’ themes, around which cross-cutting actions are encouraged to coalesce. Funding is intended for these, albeit not specified in the document.

Another cross-cutting example is the ‘Flemish Protein Strategy 2021-2030’. This aims to increase the ratio of plant protein consumption vs animal protein consumption in Flanders to 60:40. Using CAP funding for domestic plant protein production as a catalyst, the strategy supports collaborations between food supply chain actors, research institutes and NGOs.

In practice, the Protein Strategy has led to increased domestic production of plant protein crops, research/innovation in processing, and promotion of plant proteins by food retailers. Overall, it represents an effort to fund coherent cross-sectoral work on sustainable food, by leveraging EU funding and private sector investment. CAP funding has similarly been used to encourage greater organic food production, albeit to a lesser degree than plant protein production.

Actions specifically to promote climate-friendly diets have been more limited in scope and scale. They have been largely focused on public communications campaigns and work with public catering (Table 3.1).

Evaluations of effects of FBDGs and/or policies

The Flanders Government conducts a National Food Survey on a 10-year cycle, with the next round due in 2024. This will be the first opportunity to gauge any changes in public dietary habits from the latest FBDGs. In the meantime, a recent small-scale survey on protein consumption showed trends in the desired direction (increases in plant consumption, decreases in meat consumption), but only to a very small extent. More formal evaluations of policy effectiveness are needed.

Case study: The Netherlands

This chapter provides an overview of the FBDGs in the Netherlands, how they were developed, and policy implementations to date. Appendix F provides more details.

FBDGs in the Netherlands: The Wheel of Five and Seven Steps to Sustainability

In the Netherlands, climate-focused dietary guidance is captured in the “Eating more sustainably: fact sheet” (2022), which accompanies the main “Wheel of Five” dietary model. The factsheet is a 10-page document targeted at professionals/policymakers. It sets out the case for environmentally sustainable diets, and explains how the Dutch diet should change to be in line with science-based planetary health recommendations.

The factsheet states that shifting from the current diet to the Wheel of Five is good for health and climate, but it also gives more specific advice about the most sustainable options to choose (Figure 4.1). The 7 ways are: (i) eat less meat (opt more often for pulses, nuts or eggs); (ii) waste as little as possible (buy and cook what you need); (iii) eat recommended amounts (moderate your snacks and sweets); (iv) drink mostly tap water; (v) eat enough dairy and cheese (but within bounds); (vi) buy seasonally (and check product origins); (vii) choose premium sustainability labels.

How FBDGs were developed

Two agencies led the development of the Dutch FBDGs. These were the National Institute for Public Health and the Environment (NIPHE), a research centre which collects and analyses scientific evidence and conducts data modelling, and the Netherlands Nutrition Centre (NNC), a body which translates the science into practical FBDGs for consumers and health professionals. Both are independent bodies, funded solely by the Ministries of Health and Agriculture.

In 2015, the NIPHE reviewed the scientific evidence on health and climate impacts of diets, with input from academic subject experts. NIPHE used this intelligence to model dietary guidelines as close as possible to the existing Dutch diet, while meeting parameters of health, climate impact, feasibility and impact on different target groups.

The NNC used the modelled solutions to draft the public facing dietary guidance, including the graphics. A transparent consultation process followed with experts, to check for any errors/omissions in the science, and also with health professionals, to advise on practical implementation.

The food industry was specifically not involved in the consultation. Only after the final guidance was completed were meetings held with industry representatives. This approach was taken to maintain both the real and perceived independence of the NIPHE and NNC. In total, the development process took several years.

Policies, strategies and actions related to the FBDGs

Policies relevant to food in the Netherlands appear to reflect the traditional priorities of host ministries, with relatively little integration of health and climate goals. For example, the 2018 ‘National Prevention Agreement: Towards a Healthier Netherlands’ makes no reference to climate or sustainability, while the 2019 ‘Climate Agreement’ contains only one brief reference to the need for change in food consumption habits. The 2015 ‘National Food Policy’ includes goals to increase consumption of fruits and vegetables, but these are justified for health not climate reasons.

However, the Dutch National Protein Strategy is more integrative. As in Flanders, CAP funding has been used to encourage plant protein production at farm level. This is being combined with further funding under economy-wide ‘green growth’ schemes, from both public and private sources, to encourage market growth along the supply chain.

Actions specifically to encourage take-up of the FBDGs are led by the NNC. They are centred on public communication tools and work with public caterers. In addition, one Dutch municipality (Haarlem city) is imposing a ban on outdoor advertising of meat. Table 4.1 provides more details.

Evaluations of effects of the FBDGs and/or policies

The NNC undertakes consumer research and also administers the Dutch National Food Survey. Their data indicate that awareness of the Wheel of Five dietary model in the Dutch population is 71%, and trend analysis from the Dutch National Food Survey indicates small increases in fruit and vegetable consumption, and small decreases in meat consumption between 2007 and 2021. The changes are small, but in the right direction. However, policy effectiveness has not been evaluated formally.

Case Study: Sweden

This chapter provides an overview of the FBDGs in Sweden, how they were developed, and policy implementations to date. Appendix G provides more details.

FBDGs in Sweden: “Eat greener, not too much, and be active”

In Sweden, the FBDGs are captured in the 28-page consumer-facing document “Find your way to eat greener, not too much, and be active” (2015). It was developed by the Swedish National Food Agency (SNFA), in cooperation with the Swedish Public Health Agency, Board of Agriculture and Environmental Protection Agency. In terms of context, the guidance makes the argument for a holistic approach to eating, and for considering the environmental impact of food choices.

Advice is structured around 3 sections: 1. things to eat/do more of; 2. things to switch; and 3. things to eat less of (Figure 5.1). For each named food group (vegetables and fruits; seafood; wholegrains; healthy fats; low fat dairy products; red and processed meat; salt; sugar), there is a dedicated page which explains the advice in more detail, including the link to environmental impacts. These pages also offer specific ingredient and recipe suggestions to help make the change.

How FBDGs were developed

The Swedish National Food Agency is an independent, government-funded body, which administers public diet and health activities. It is one of 25 government agencies with special responsibility for achieving the government’s environmental objectives.

The FBDGs development process was science led, although stakeholder input happened earlier in the process than in Flanders and the Netherlands. From 2008-13, the Swedish Food Agency commissioned a series of reports on the environmental impacts of different foods, alongside evidence on the health effects of diet gathered from Nordic Nutrition Recommendations (NNR)^[12]. The joint evidence was reviewed, with experts from the Swedish Public Health Agency, Board of Agriculture and Environmental Protection Agency. The review was supported by a stakeholder panel.

In 2014, a public consultation took place, including participants from industry, consumer and patient organisations, and public health professionals. Then the guidance was drafted and tested with consumers. The guidance was published in 2016/17. The whole process from initial discussions to publication took almost 10 years.

Since the development of this guidance, the latest revision of the Nordic Nutrition Recommendations (NNR), in 2023, has been published. It includes explicit reference to climate impact. It therefore provides a very high standard, scientifically informed evidence base on climate-friendly diets.

Policies, strategies and actions related to the FBDGs

In Sweden, the policy landscape for sustainable diets appears fragmented. For example, the 2016 “National Food Strategy for Sweden”, and subsequent 2019 “Action Plan”, focus almost exclusively on agricultural production. Meanwhile, the 2016 “Strategy for Sustainable Consumption” contains only a brief reference to food. The 2018 “Climate Framework Policy”, which sets out the Swedish Government’s net zero targets for the whole economy, also makes no reference to food consumption or dietary change.

In 2021, the Swedish Government tasked the Swedish Food Agency and Public Health Agency to propose areas of action needed for a more sustainable food system in Sweden, and indicators to measure progress^[13]. The work was based on consultations with authorities, industry and civil society. The report, published 2024, emphasizes the need for joined-up policies to tackle health and climate problems. However, given recent shifts in politics in Sweden and hardening resistance from industry stakeholders to food system change, it may be challenging for officials to take forward many of the recommended Actions in the report.

Actions specifically to encourage take-up of the FBDGs are led by the Swedish Food Agency. To date, they have focused on public communications activities and work with public caterers, in particular schools. Table 5.1 provides more details.

Evaluations of effects of the FBDGs and/or policies

No formal evaluations have been conducted of the effect of the FBDGs on dietary habits. However, consumption trend data show that meat consumption peaked in 2016 and has subsequently declined whilst the proportion of Swedish meat within total meat consumed has increased. This suggests there has been some response to the “eat less but better” messaging, with ‘better’ meaning ‘Swedish’.

Implications for the potential development and implementation of climate-friendly FBDGs in Scotland

Having assessed climate-friendly FBGDs in other jurisdictions, and explored their development and policy implementation in Flanders, the Netherlands and Sweden, this chapter considers the possible implications for Scotland. Throughout this chapter, the FBDGs of Flanders, the Netherlands and Sweden are used as climate-focused comparators.

Dietary profile of Scotland compared with jurisdictions having climate-focused FBDGs

Studies show repeatedly that the diet of the average Scottish adult is unhealthy. It comprises higher than recommended intakes of calories, fat, sugar and salt, and lower intakes of fibre and fruit and vegetables^[15]. These are associated with a range of chronic health problems, including diabetes, cardiovascular disease (CVD), hypertension and certain cancers.

In addition, average diets for some groups of Scottish consumers are deficient in micronutrients such as selenium and iodine. These deficiencies are also associated with a range of health problems, including fatigue, mental impairments and weakened immune systems. However, intake rates of red and processed meats are within the Scottish Dietary Goals maximum recommended for almost three quarters of the population^[16].

* Scottish-specific BMI figures with UK figures in brackets from same Eurostat source as other countries. Comparisons are indicative given differences in survey methods, definitions and timings. See also Appendices B and C.

Table 6.1 above shows intakes for different food groups in Scotland, compared with Flanders, the Netherlands and Sweden. Notwithstanding caveats regarding precise comparability, the figures suggest that Scottish fruit consumption is relatively high compared to the other jurisdictions, while meat and vegetable intakes are relatively low. Dairy consumption appears similar to Sweden but lower than the Netherlands. Body Mass Index (BMI) scores, as indicators of broader diet-related health, are also similar for the proportion of the population overweight, but Scotland (and the UK) have markedly higher obesity rates.

Potential impacts on the Scottish population from take-up of climate-focused FBDGs

Table 6.2. Examples of likely revisions needed to Eatwell Guide to align with more climate-focused FBDGs, and potential risks to Scottish population

The key features of climate-focused FBDGs were discussed in Chapter 2, summarizing similarities and differences between climate-focused guidance and the Eatwell Guide. Table 6.2 lists possible revisions for guidance in Scotland, to align with more climate-focused FBDGs. It also indicates the potential risks of negative impacts on the Scottish population, should the revised guidance be taken up. The potential risks for meat, dairy and sustainable sourcing advice are further discussed below. Potential risks for population sub-groups are discussed in section 6.3.

Potential impacts of revised meat intake advice

For greater climate focus, revisions to the Eatwell guidance would likely specify a lower maximum intake for red/processed meat, a new maximum intake for all meat, and strengthened messaging on reducing meat generally in the diet.

Comrie et al (2024) modelled the effects on micronutrient intake and of chronic disease risks from a 20% reduction in meat intake in Scotland, i.e. to levels consistent with the recommendations of UK Climate Change Committee (CCC).

They found that a 16% reduction could be achieved by encouraging the 28% highest red/processed meat eaters to limit their intake, of those meats alone, to the current Eatwell/SDGs maximum of 70g per day. To achieve the CCC’s 20% reduction target, the average intake of red/processed meat would need to reduce to 60g per day. This would impact the highest 32% of current red/processed meat consumers.

If meat intakes are substituted with alternative protein sources, e.g. fish, dairy or eggs, both scenarios above represent low risk options in terms of nutritional impacts. They would also bring health benefits associated with lowering red and red processed meat intakes. However, if meat intakes are substituted with refined grains or HFSS foods, then there are risks of diets becoming less rather than more healthy^[18]. Therefore, revised dietary guidance needs to include advice about healthy and accessible substitutions for meat. Other policies need to make those substitutions affordable and accessible.

Non-GHG related environmental impacts are also possible from reduction in meat intakes, depending on which foods people switch to. Increases in demand for fish could exacerbate marine pollution/ecosystem problems. Also, switching from red ruminant meat (beef, lamb) to non-ruminant meat may lead to increases in intensive pig and poultry systems. Whilst these systems are more carbon efficient, they can increase air and water pollution problems^[19]. To address these risks, a holistic perspective on environmental impact is needed during the scientific evidence gathering phase of the FBDG revisions. Other policies need to address environmental impacts of fish, pig and poultry systems.

Potential impacts of revised dairy intake advice

For greater climate focus, revisions to dietary guidance would likely set new advice to moderate dairy intake^[20].

Comrie et al (2024) modelled the nutritional and chronic disease impacts of reducing dairy intake across the population by 20%, alongside meat reduction. They find that unless substituting with eggs, there are deficiency risks in the general population for iron and iodine. They highlight that as dairy is consumed in greater quantities across the population than meat, there is more reliance on it for micronutrients. Dairy is also a source of protection against Type 2 diabetes. Therefore, some nutritional and disease risks are possible, at the population level, from moderation of dairy intake.

In principle, nutritional and disease risks could be addressed with plant-based substitutes. However, these could require considerable changes to current dietary habits for many, and substitutes may have cost and accessibility issues. These have implications for the structure of the food environment. New advice on such changes would be needed, as the current guidance gives limited explanation. The new advice would need to address the composition of processed plant-based meat and dairy substitutes, in terms of fat, salt and sugar, and potentially , the use of fortification to supply key micronutrients. As is the case with existing meat and dairy products, at present, there is high variability between products and brands in the market, in terms of composition.

Potential impacts of advice on sustainable sourcing

For greater climate focus, revisions to the Eatwell guidance would likely introduce new advice on sustainable sourcing, for example choosing organic or agroecological products. These products are typically more expensive than conventional alternatives. In periods of generally squeezed incomes and high food price inflation, this advice may be unobtainable for many. Careful messaging would be needed within the guidance to address risks of frustration/alienation. At the same time, policy measures are needed to make sustainably sourced food more affordable and accessible^[21].

Potential impacts on sub-groups of Scottish population from take-up of climate-focused FBDGs

With reference the likely changes to Eatwell guidance presented in Table 6.2, potential impacts are as follows:

Advice to reduce meat intake and moderate dairy intake

The modelling work conducted by Comrie et al (2024), on the impacts of reducing meat and dairy intakes across the population by 20%, also considered sub-groups. Depending on the substitution scenario, the authors found risks of some micronutrient deficiencies. These included selenium and zinc intakes for women and calcium intakes for young adults. Revised guidance on meat and dairy intakes would therefore need to include careful messaging and tailored advice for sub-groups, such as these, who may be at greater risk of micronutrient deficiencies. These problems may be exacerbated for women and young adults in lower income groups, who may find it more difficult to afford or access suitable meat alternatives, such as fish, eggs or plant proteins. Ability and capacity to cook meals using alternatives may also disproportionately affect these groups.

Advice to increase vegetable, fruit and plant protein intakes

Some population sub-groups may find it more difficult than others to access the range of vegetables, fruits and plant proteins recommended by revised guidance. As a result, they could face nutritional and disease risks, disproportionate to the wider population. These sub-groups could include lower-income consumers, who may struggle to afford more expensive items and/or cook the recommended foods. They could also include people in rural areas, or in urban food deserts/swamps, who face more limited ranges of foods and food retail options.

Advice to choose sustainably sourced foods

Citizens in lower income groups may be disproportionately unable to follow this advice. This could be particularly alienating. Careful messaging would be needed within the guidance. Programmes and initiatives are also needed to make sustainably sourced food more accessible and affordable.

Advice to favour potatoes, pasta and other grains over rice

This advice could disproportionately impact sub-groups whose diets rely more heavily on rice than the wider population. Tailored messaging would be needed, as well as advice on how to make the most climate-friendly choices for rice.

Advice to avoid UPFs and avoid food waste

Reducing consumption of processed and ultra-processed foods (UPFs) requires access to alternatives and a capacity for more labour and/or energy intensive food preparation. Hence consumers with restricted access due to income and/or food environment constraints and/or lacking the necessary time or facilities for food preparation (e.g. kitchen equipment) will be less likely to be able to avoid processed and UPFs. For similar reasons, consumers with limited or no access to appliances such as fridges and freezers may find it more difficult to follow advice to avoid food waste.

Policies, strategies and actions to implement climate-focused diets

Policy coordination for climate-focused diets

Policies to encourage take-up of climate-focused diets should make sustainable choices the easiest choices for consumers. This means tackling the food environment in a holistic way, using strategic packages of policy measures and instruments^[22]. This requires collaboration and co-ownership between multiple government departments^[23].

The case studies of Flanders, the Netherlands and Sweden reveal problems with coordination and coherent policy implementation on climate-friendly diets, to date. Siloed thinking has been evident, reinforced by resource allocations tied to narrow departmental remits rather than cross-cutting goals.

More recent food strategies aim to encourage more holistic, systems-based action on food and diets (e.g. the Flemish Food Strategy). However, implementation is at an early stage, and formal evaluations of their effectiveness have yet to be conducted.

Policy measures and actions for climate-focused diets.

Table 7.1 gives examples of specific policy measures for climate-focused diets that may feature in holistic packages. It also shows whether any of these measures have been applied in Flanders, the Netherlands or Sweden.

On both the demand and supply sides of the food system there are fiscal and regulatory measures. Also on the demand side are public information provision, labelling and public catering. The supply side also includes influencing voluntary industry action. In Flanders, the Netherlands and Sweden, public information campaigns and public catering dominate on the demand side, while fiscal measures and influencing industry dominate on the supply side. The pros and cons of these measures are discussed below, with implications for Scotland.

Public information provision

This is a popular measure to encourage climate-friendly consumption. All three case study jurisdictions have applied it. Public information campaigns are relatively quick and inexpensive to implement, and the range of options now includes digital tools that offer interactivity (e.g. the Mijn Eetmeter diet tracking app in the Netherlands^[24]).

However, there is little evidence that information alone can shift dietary habits. Population heterogeneity is significant, and people engage with or avoid information for multiple reasons^[25]. Nevertheless, public information has a role to play in packages of policy measures. It may help to address low awareness of diet and sustainability issues in the population. Also, public information can signal the government’s priorities and direction of travel to citizens, industry and public bodies. This can be a way to show leadership to stakeholders^[26].

Implications for Scotland:

Develop public information campaigns or messaging for climate-friendly diets as part of strategic policy packages, rather than stand-alone actions. Consider the multiple audiences for information on climate-friendly diets, and explore the potential for campaigns to signal clearly the policy agenda to a range of stakeholders.

Labelling

In theory, labelling schemes for climate-friendly foods can have an ‘industry pull’ effect. As producers change their practices in order to get certified, this brings widespread improvements^[27]. However, evidence for the capacity of labels to change consumer behaviour is mixed at best^[28]. Consumers already face multiple labelling schemes which compete for their attention. Also, environmental impact labels for food products are beset with technical challenges. For example, standardised, reliable metrics for carbon scores are lacking. In addition, labels which only show carbon values are ignoring other important environmental impacts.

For these reasons, climate-friendly labelling is uncommon^[29]. None of the case study jurisdictions have sought to develop climate labels. Instead, they recommend existing certification schemes that are already familiar to consumers, as ways to identify more sustainable options. These include organic labels.

Implications for Scotland:

The development of any new carbon-specific labelling is unlikely to be worthwhile. Following the examples of the Netherlands and Sweden, it would be more feasible to focus on existing certification schemes (e.g. organic, meat quality assurance schemes), and explore ways to strengthen their climate relevance.

Fiscal measures and regulation (demand side)

Demand side regulation has been used actively in the food sector for public health reasons. Examples include restrictions on advertising unhealthy foods to children, and on the use of trans fats in food manufacturing. Fiscal measures (e.g. subsidies, taxes) have also been implemented for health reasons, for example, the Soft Drinks Industry Levy. Both types of measure are associated with stronger behaviour change outcomes than information or labelling. They are also associated with driving positive changes in industry practices, including reformulation of products^[30].

However, these measures are less commonly applied explicitly in relation to climate-friendly diets, as they can have unintended consequences and evidence on effectiveness is mixed^[31]. A risk of taxing high carbon foods like meat, for example, is that some consumers switch to foods of lower nutritional value, such as HFSS foods. As lower income households are already more likely to purchase such foods, such taxes risk exacerbating health inequalities. Furthermore, taxes on domestic high carbon foods may lead to carbon ‘leakage’ through import/export substitution effects, with no net reduction in global climate impact.

Implications for Scotland:

Taxes on foods for climate reasons may lead, unintentionally, to regressive outcomes. To address risks of exacerbating health inequalities, taxes should be partnered with policies to make healthier substitutes affordable and accessible to lower income groups. To address risks of GHG leakages, domestic carbon taxes should be partnered with appropriate trade policies.

Importantly however, not all tax/subsidy powers reside with the Scottish Government. Even those that do are subject to UK-wide agreement under the Internal Market Act 2020 and/or the Subsidy Control Act 2022.^[32] Hence not all fiscal policy options are necessarily feasible within Scotland.

Public catering provision

Public catering is frequently presented as a policy area with the potential for direct behaviour change towards more climate-friendly diets^[33]. There are two main ways this can happen. First, procurement standards and criteria can be revised to be more climate-focused. Criteria can relate to food and non-food purchases, facilities and equipment. Second, catering service practices can be revised to reduce climate impact. This can include, for example, recipe and menu design, and food waste reduction.

Flanders, the Netherlands and Sweden have all taken climate-related public catering actions, including introduction of meat-free days in school menus. To date, these actions have largely been voluntary for their sectors.

Implications for Scotland:
In the Scottish public sector, food procurement and catering provision are governed by separate standards. Often, they are also managed by different teams and processes, which presents challenges to coherent decision-making on climate impact.

To make public food procurement more climate friendly, a higher minimum weighting could be applied to climate criteria in contract awards. Suppliers could be asked to provide more carbon information, or be part of certification schemes. However, such demands may disproportionately impact small suppliers or first-time bidders. This would conflict with wider goals to encourage greater diversity in public procurement. Measures to reduce this risk may include supporting suppliers to meet more exacting climate requirements. Procurement officers could also be offered additional sustainability training.

Catering provision standards vary according to sector. In schools, statutory standards for food are based on nutritional not climate goals^[34]. These standards could be revisited to explore ways to make them more climate-friendly. This would increase their consistency with local authority obligations to measure and reduce the carbon footprints of their services^[35]. Extension of the Food For Life programme to all local authorities (currently voluntary) could also be a route to more climate focus.

In practice, school catering managers are increasingly taking voluntary climate actions, e.g. food waste reduction and meat-free days. Measures are needed to better support these actions, e.g. by strengthening public information on sustainable diets, and offering training and support for climate-friendly catering to service teams.

Influencing voluntary industry actions

Governments have well-established engagement with industry to encourage voluntary actions for public health reasons. Actions are now being encouraged to promote more climate-friendly food choices, for example, by reformulating products or changing microenvironments in-store to shape choice architecture^[36]. Such approaches can be attractive to government since they avoid the time and effort needed to design and implement formal regulatory controls or taxes. However, industry actors may withdraw if market circumstances alter or industry leadership changes. Hence, voluntary agreements need to be monitored. They are often encouraged through the threat of imposing non-voluntary arrangements (e.g. regulation, fiscal measures) if engagement levels drop^[37].

Both Flanders and the Netherlands are currently encouraging voluntary industry agreements related to sustainable diets. Under their Protein Strategies, they are encouraging domestic processors and retailers to increase activity in plant proteins. They have done this by presenting direct investments in domestic plant protein, derived from CAP Green Deal funding, as a market growth opportunity (see below). This is an example of more holistic policymaking, with coherence across supply and demand side measures.

Implications for Scotland:

Persuading industry partners to voluntarily adjust their practices requires either a perceived threat of future regulatory controls/fiscal distinctives from non-adjustment, or perceived benefits from doing so. Achieving either requires repeated engagement with industry stakeholders to establish mutual understanding of objectives, constraints and feasible options. Scottish industry stakeholders are already routinely involved in agricultural and food policy discussions, but voluntary actions by different stakeholders often progress at different rates. This can lead to poorly coordinated outcomes.^[38]

Regulation and fiscal measures (supply side)

Various regulatory controls are applied to agricultural production across the EU, and some of these relate explicitly to mitigating GHG emissions. For example, farmers’ support funding requires adherence to Good Agricultural and Environmental Condition (GAEC) criteria. EU-level efforts also seek to regulate food imports on the basis of their GHG emissions. However, the link between all regulatory measures and domestic dietary guidance is often implicit at best.

Similarly, fiscal support for domestic agricultural production is also deployed under the EU-wide CAP. Much of this takes the form of decoupled payments not tied explicitly to the production of any particular (or indeed any) food product. However, some support is targeted explicitly at specific sectors, such as organic production and plant protein production. For the latter, further public funding from other sources has been deployed for R&D activities and to leverage private funding along the supply chain. This has been the case in Flanders and Netherlands’ Protein Strategies.

Implications for Scotland:

Agricultural production is already subject to various regulatory controls. Revision to agricultural funding support is likely to introduce new requirements related to GHG emissions. This will include obligations to monitor and report emissions^[39]. Such improvements to the climate impact of Scottish agricultural production can be connected to advice within FBDGs, to choose more sustainably sourced foods.

Regulatory controls on imported food items fall outwith Scottish Government devolved powers.

Supply-side fiscal measures are already deployed within Scotland, most notably with respect to holders of agricultural land but also through investment and training grants for other parts of the supply-chain and funding for a range of research institutions. The majority of funding through such measures is not currently linked strongly to climate-related dietary change. However, as in some other countries, there may be scope to do so. This will require greater cross-departmental working and reprioritization of current budgets. Such issues feature in current parliamentary scrutiny of the Agricultural and Rural Communities Bill, including in relation to Good Food Nation ambitions.^[40]

The scope for deploying new tax measures is more limited given constraints on devolved powers.

Conclusions

Listed by project objectives, the key findings are summarised here.

Dietary guidelines and recommendations in other jurisdictions

Out of 33 jurisdictions studied, only seven have FBDGs with extensive climate focus.

The main differences between health-focused and climate-focused guidance are that the latter recommends greater meat reduction, in particular ruminant meat, moderating dairy intake, choosing sustainably sourced foods, avoiding highly processed foods and avoiding food waste.

In three jurisdictions with climate-focused FBDGs (Flanders, the Netherlands, Sweden), the guidance was developed via a ‘science first’ approach, using expert panels and reviews. Stakeholder inputs were restricted to the final steps of messaging and implementation, to preserve the independence of the guidance.

Policies, strategies and actions taken to encourage progress to the guidelines

Policy implementation for climate-focused guidance requires coordination across government departments and budgets, and strategic packages of policy measures. These are needed to tackle food environments holistically, to make climate-friendly choices affordable and accessible.

Policy implementation of FBDGs in the three jurisdictions has lacked coordination, and measures have been largely limited to public information campaigns and encouragement of voluntary actions in public catering (e.g. menu adjustments).

Potential applications in Scotland and impacts on different groups

Adoption of climate-focused FBDGs would be a generally low-regret action, consistent with the direction of travel for policies relating to climate and health.

Some micronutrient deficiency risks are possible for certain population groups, depending on which foods are substituted. These include women, young adults, and lower income households. Other risks include import/export carbon leakage.

To address such issues, a coordinated cross-departmental policy approach would be needed, deploying a mix of supply-side and demand-side measures.

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Appendices

Appendix A: Interviewees and discussion guide

Flanders:

Senior professional from Flanders Institute of Healthy Living (Gezonden Leven)

Senior professional from Flanders Department of the Environment and Spatial Planning

Netherlands:

Senior professional from the Netherlands Nutrition Centre (Voedingscentrum)

Sweden:

Senior academic from the Swedish University of Agricultural Sciences

Scotland:

Representative from NESTA

Representative from NFUS

Representative from the British Dietetic Association

Senior academic, University of Edinburgh

Representative from the Soil Association

Two representatives from ASSIST FM

Representative from the Food and Drink Federation Scotland

Other:

Team of academics from the London School of Hygiene and Tropical Medicine (undertaking similar research on behalf of Defra)

Discussion Guide

Aims of Interview

The Scottish Government currently provides dietary guidance via the EatWell Guide, which promotes better health and nutritional outcomes. Scottish Government is exploring how to align the guidance with its climate objectives, to encourage diets that are both healthy and climate-friendly. The purpose of these discussions is to gather views on what climate-friendly dietary guidelines could look like in Scotland, what actions would be most effective to encourage their uptake, and what barriers, problems or unintended consequences Scottish Government should be aware of, from your perspective as a representative of [name of stakeholder group].

1.Explain privacy notice and confirm consent to undertake the interview [2 mins]

2. Opener [5 mins]

• From the perspective of your organisation/profession, what does a climate-friendly diet mean to you?
  
• What key features, or guidelines, would you expect in a climate-friendly diet?
  
• If interviewees are familiar with the EatWell Guide, could also ask how climate-friendly they think it currently is, and what they would change/revise, to make it more climate-friendly.
  

3. Discussion of climate friendly dietary guidance, using prompt material [10 or 15 mins, depending on interviewee’s expertise]

In advance, we will share the attached montage of dietary guidelines assembled from climate-focused FBDGs, i.e. Flanders, Netherlands, Sweden:

On the slide are examples of climate-friendly dietary guidance, from other countries. Please tell me:

• What is your impression of these dietary guidelines?
  
• To what extent could they apply in Scotland?
  
• In particular, what is your view about the advice to:
  
• Reduce meat consumption, especially red meat (including specifying maximum intake per week)?
  
• Moderate dairy consumption?
  
• From your perspective, what difference does the addition of climate-focused guidance make to nutritional outcomes? Does it create any tensions? Will consumers be more or less receptive?
  
• What problems or unintended consequences might come from guidance such as this in Scotland?
  
• Which groups may particularly benefit, and which groups may be negatively impacted?
  
• (If time – If ScotGov decided to develop climate-friendly dietary guidelines, what would your advice be about which stakeholders should be involved in the development process?
  
• Who should lead the process?
  

4. Discussion of how to encourage take-up of dietary guidance, using prompt material [10 or 15 mins, depending on interviewee’s expertise]

In advance, we will share the attached montage of policy instruments from other jurisdictions, designed to encourage climate-friendly diets.

On the slide are examples of policy actions in other countries to encourage take-up of climate-friendly diets. Please tell me:

• What is your impression of these policy actions?
  
• To what extent could they apply in Scotland?
  
• In particular, what is your view of:
  
• Carbon labelling of food
  
• Subsidising fruit and vegetables to targeted groups
  
• Changing public catering standards to encourage more meat-free menus
  
• Acting on the food environment
  

5. Wrap up

• Do you have any questions you would like to ask?
  
• Confirm how information will be used
  
• Thank participant and end interview
  

Appendix B: FBDG information for selected countries

Dietary Guideline information for selected countries, citing official documentation and showing degree to which guidance is linked to environmental impact. Recommendations included where linked explicitly to environment/climate^[41]

All weblinks accessed during December 2023.

Austria

Degree to which document links guidance to environmental impact: Extensive and frequent Partial Occasional or none

* New Austrian Food Pyramids (plural) are due to be published in the autumn of 2024, https://www.sozialministerium.at/Themen/Gesundheit/Ern%C3%A4hrung/%C3%96sterreichische-Ern%C3%A4hrungsempfehlungen-NEU.html

Australia

Degree to which document links guidance to environmental impact: Extensive and frequent Partial Occasional or none

NB. National level guidelines apply everywhere but supporting policy measures vary across sub-national jurisdictions across Australia.

Belgium (country-wide)

Degree to which document links guidance to environmental impact: Extensive and frequent Partial Occasional or none

NB. Guidance expected to be updated after 2023 see https://www.health.belgium.be/en/advisory-report-9284-fbdg-2019

Belgium (Flanders)

Degree to which document links guidance to environmental impact: Extensive and frequent Partial Occasional or none

Brazil

Degree to which document links guidance to environmental impact: Extensive and frequent Partial Occasional or none

Canada

Degree to which document links guidance to environmental impact: Extensive and frequent Partial Occasional or none

NB. National level guidelines apply everywhere but supporting policy measures vary across sub-national jurisdictions across Canada.

Chile

Degree to which document links guidance to environmental impact: Extensive and frequent Partial Occasional or none

Croatia

Degree to which document links guidance to environmental impact: Extensive and frequent Partial Occasional or none

Cyprus

Degree to which document links guidance to environmental impact: Extensive and frequent Partial Occasional or none

NB. National level guidelines apply everywhere but supporting policy measures vary across sub-national jurisdictions across Canada.

Denmark

Degree to which document links guidance to environmental impact: Extensive and frequent Partial Occasional or none

Estonia

Degree to which document links guidance to environmental impact: Extensive and frequent Partial Occasional or none

Finland

Degree to which document links guidance to environmental impact: Extensive and frequent Partial Occasional or none

France

Degree to which document links guidance to environmental impact: Extensive and frequent Partial Occasional or none

Germany

Degree to which document links guidance to environmental impact: Extensive and frequent Partial Occasional or none

Greece

Degree to which document links guidance to environmental impact: Extensive and frequent Partial Occasional or none

Hungary

Degree to which document links guidance to environmental impact: Extensive and frequent Partial Occasional or none

Iceland

Degree to which document links guidance to environmental impact: Extensive and frequent Partial Occasional or none

Ireland

Degree to which document links guidance to environmental impact: Extensive and frequent Partial Occasional or none

Italy

Degree to which document links guidance to environmental impact: Extensive and frequent Partial Occasional or none

Latvia

Degree to which document links guidance to environmental impact: Extensive and frequent Partial Occasional or none

Malta

Degree to which document links guidance to environmental impact: Extensive and frequent Partial Occasional or none

Netherlands

Degree to which document links guidance to environmental impact: Extensive and frequent Partial Occasional or none

New Zealand

Degree to which document links guidance to environmental impact: Extensive and frequent Partial Occasional or none

Norway

Degree to which document links guidance to environmental impact: Extensive and frequent Partial Occasional or none

NB New Nordic Nutrition Recommendations (2023) https://www.norden.org/en/publication/nordic-nutrition-recommendations-2023 explicitly address sustainability issues and may indicate likely revision to expected update of dietary guidelines

Poland

Degree to which document links guidance to environmental impact: Extensive and frequent Partial Occasional or none

Portugal

Degree to which document links guidance to environmental impact: Extensive and frequent Partial Occasional or none

Romania

Degree to which document links guidance to environmental impact: Extensive and frequent Partial Occasional or none

Spain

Degree to which document links guidance to environmental impact: Extensive and frequent Partial Occasional or none

Slovenia

Degree to which document links guidance to environmental impact: Extensive and frequent Partial Occasional or none

Sweden

Degree to which document links guidance to environmental impact: Extensive and frequent Partial Occasional or none

Switzerland

Degree to which document links guidance to environmental impact: Extensive and frequent Partial Occasional or none

UK (England, Northern Ireland, Scotland and Wales)

Degree to which document links guidance to environmental impact: Extensive and frequent Partial Occasional or none

USA

Degree to which document links guidance to environmental impact: Extensive and frequent Partial Occasional or none

NB. Federal MyPlate guidance appears to apply across all individual States. Some (e.g. California) have State-badged material that is otherwise identical to Federal guidance. However, Alaska and Hawaii (plus Pacific Island dependencies) appear to also refer to the Secretariat of the Pacific Community and The Pacific Food Guide. The latter was sponsored by the United States Department of Agriculture to account for regional differences in culture and dietary challenges, but makes no mention of environmental or climate impacts of dietary choices: http://manoa.hawaii.edu/ctahr/pacificfoodguide/index.php/about-the-guide/. In response to academic criticism of the Federal guidance, Harvard University publishes the ‘Healthy Eating Plate’ as an alternative to MyPlate, https://www.health.harvard.edu/staying-healthy/healthy-eating-plate

Appendix C: Recommended intakes for key food groups, in FBDGs for 22 jurisdictions

Source: derived from references listed in Appendix B

Appendix D: Summary dietary patterns, recommended intakes and population characteristics for Flanders, Netherlands, Sweden and Scotland

* Scottish-specific BMI figures with UK figures in brackets from same Eurostat source as other countries. Comparisons are indicative given differences in survey methods, definitions and vintage.

Dietary statistics sources:

Belgium.

Scientific Institute for Public health 2016 Food Consumption Survey 2014-2015 https://www.sciensano.be/en/biblio/enquete-de-consommation-alimentaire-2014-2015-resume-des-resultats

Healthy Belgium 2020 Nutritional habits https://www.healthybelgium.be/en/health-status/determinants-of-health/nutritional-habits

STATBEL 2023. Structure of the Population.

https://statbel.fgov.be/en/themes/population/structure-population

Statistics Flanders 2023. Gross domestic product per capita

https://www.vlaanderen.be/en/statistics-flanders/macro-economy/gross-domestic-product-per-capita

For a Healthy Belgium 2020. Weight status.

https://www.healthybelgium.be/en/health-status/determinants-of-health/weight-status#references

Netherlands.

National Institute for Public Health and the Environment: Ministry of Health, Welfare and Sport. 2022. The diet of the Dutch Results of the Dutch National Food Consumption Survey 2019-2021 on food consumption and evaluation with dietary guidelines. https://www.rivm.nl/bibliotheek/rapporten/2022-0190.pdf

National Institute for Public Health and the Environment: Ministry of Health, Welfare and Sport. 2023. Dutch National Food Consumption Survey 2019-2021: Consumption https://statline.rivm.nl/#/RIVM/nl/dataset/50110NED/table?ts=1706353152036

Statistics Netherlands 2023. Regional key figures; National Accounts https://www.cbs.nl/en-gb/figures/detail/84432ENG

Statistics Netherlands 2023. Population Counter https://www.cbs.nl/en-gb/visualisations/dashboard-population/population-counter

Sweden

Swedish National Food Agency 2012 National food – adults 2010-11. Food and nutrient intakes among adults in Swedenhttps://snd.gu.se/en/catalogue/dataset/ext0093-1

Swedish Board of Agriculture. 2023. Food consumption and nutrient content. Data up to and including 2019 https://jordbruksverket.se/om-jordbruksverket/jordbruksverkets-officiella-statistik/jordbruksverkets-statistikrapporter/statistik/2020-12-09-livsmedelskonsumtion-och-naringsinnehall.–uppgifter-till-och-med-2019

Official statistics of Sweden 2023. Population statistics https://www.scb.se/en/finding-statistics/statistics-by-subject-area/population/population-composition/population-statistics/

Statistics Sweden 2023. Sweden’s GDP per capita ranks seventh in Europe

https://www.scb.se/en/finding-statistics/statistics-by-subject-area/prices-and-consumption/purchasing-power-parities/purchasing-power-parities-ppps/pong/statistical-news/purchasing-power-parities-20102012

Scotland

Barton, K. and Ronald, C. 2023. Estimation of Food and Nutrient Intakes from Food Purchase Data in Scotland 2001-2018 https://www.foodstandards.gov.scot/downloads/FSS_-_Monitoring_Dietary_Intakes_-_Living_Costs_and_Food_Survey_-_LCFS_-_2001_to_2018_-_Report_for_Publication_-_FINAL_-_PDF_Version_for_Publication_on_Website_-_01_February_2022.pdf

Stewart, C., McNeill, G., Runions, R., Comrie, F., McDonald, A. and Jaacks, P.L.M., 2023. Meat and milk product consumption in Scottish adults: Insights from a national survey. Available at SSRN 4628199. https://deliverypdf.ssrn.com/delivery.php?ID=857005071031031000088070115122121000008032020031003054085010011001034115108111087086083066097092081020103030015004125120065026076016072087060115025026001021037011068002087078095090086003011000052053046070037015000090031072029087122085104109065002075126019112074019089127120092112074085122005&EXT=pdf&INDEX=TRUE

Scotland’s Census 2023. Scotland’s Census 2022 – Rounded population estimates.

https://www.scotlandscensus.gov.uk/2022-results/scotland-s-census-2022-rounded-population-estimates

Obesity statistic sources:

Eurostat Body mass index (BMI) by sex, age and country of citizenship https://ec.europa.eu/eurostat/databrowser/view/hlth_ehis_bm1c/default/table?lang=en&category=hlth.hlth_det.hlth_bmi

NCD-RISC NATIONAL ADULT BODY-MASS INDEX https://www.ncdrisc.org/data-downloads-adiposity.html

Scottish Government 2022. Scottish Health Survey 2021 https://www.gov.scot/collections/scottish-health-survey/#2022

Appendix E: Dietary guidance development and selected food policies and strategies in Flanders

Governance of the Flanders region

Flanders is a region of Belgium. At 483 km², it comprises less than half the land mass of Belgium, but with more than 6 million inhabitants it represents 57% of the population. Authority for many aspects of health and environmental policy are devolved to regional governments in Belgium, including Flanders, whilst fiscal policy, defence, etc are governed centrally.

FBDGs in Flanders: the Flanders Food Triangle

In Flanders, the FBDGs are captured in a 24-page consumer-facing document “Eating According to the Food Triangle: Good for Yourself and the Planet” (2021). It was developed by the Flemish Institute of Healthy Living (“Gezond Leven”), in cooperation with the Department of the Environment of the Flemish Government. The stated aims of the document are to draw from the latest science and expert advice, in order to provide concrete, achievable consumer recommendations for diets that can improve human health and that of the planet.

The context of the guidance emphasises that the environmental impact of our food is currently greater than what our planet can bear, so dietary change is needed. A graph (Figure 13.1) ranks foods according to their environmental impact, such that citizens are advised to eat more of the foods at the top (legumes, tofu, wheat and rye, potatoes, root vegetables and nuts), and less of the foods at the bottom (lamb, beef, pork, cheese and milk). It also emphasises that consumer choices and habits are strongly influenced by the food environment. Consequently, it argues a multi-stakeholder effort is needed to make healthy, climate-friendly diet choices the most obvious and appealing options for consumers.

In terms of content, the Food Triangle is offered as the basis for a healthy and environmentally responsible diet. It is underpinned by 3 principles: (i) eat proportionately more plant-based food than animal-based food (due to the former generally having lower environmental impact than the latter); (ii) eat and drink as few nutrient poor foods as possible (because every food production step adds an environmental burden, hence our foods need to ‘count’ more); (iii) avoid food waste and moderate your consumption (because every food item that is wasted is an environmental impact that could have been avoided).

The guidance offers specific advice for each of the food groups in the Triangle, which includes quantified amounts for each category, with continued reference/justification to environmental impact. Discretionary foods (foods high in fat, salt and sugar) are separated from the triangle as non-essential to the diet, and this category also includes processed meat.

The Flanders FBDGs emphasises gradual change, not radical shifts: “balance is key: take care of yourself and the planet, but don’t forget to enjoy yourself.” It also recommends up to three or four days per week of meat-free meals. Links are offered to relevant support materials, developed by Gezond Leven, such as recipes for vegetarian meals and a seasonal buying guide for fruit and vegetables.

The guidance offers detailed and nuanced advice about the environmental impacts of different types of production system, and of transportation. For example, it cautions against assumptions that locally sourced food is automatically lower carbon. The guidance also advises on processed meat substitutes, for example, by recommending substitutes like tofu and tempeh, which are less processed than alternatives. It also gives specific advice about nutritional contents to look for in milk and dairy substitutes.

How the FBDGs were developed

Gezond Leven was the lead partner developing the guidance. It is an independent agency working under contract to the Flanders Government, responsible for public health promotion. The other key partner was the Department of the Environment and Spatial Development. The steps of the development process are depicted in Figure 13.2, and can be summarised as follows. The process began with a commissioned review of the scientific literature on the health and environmental impacts of dietary choices. Next, a cross-disciplinary expert panel of academics was convened, to help analyse the evidence and determine the core content of the final guidance, including the visual model. This step also involved development of the underpinning reasoning for the guidance, based on a strong scientific foundation. After this, public-facing messaging was designed and tested amongst citizens. Only after the guidance was finalized were stakeholders consulted on matters related to coordination and implementation of the guidance. Stakeholders did not influence or change the substance of the guidance.

The primacy of science in the development process, and the exclusion of stakeholders from the core development, was a deliberate decision by Gezond Leven. It was based on its first experience of designing climate-focused guidance in 2017, where stakeholders were included in the development process, and less time was spent establishing the scientific underpinning. Gezond Leven received criticisms from stakeholders and the media that the ensuing guidance was biased and lacking in scientific evidence. This led to the ‘science first’ approach for the 2021 guidance.

A co-benefit of developing a solid science base for the current guidance has been the creation of a background document, which explains clearly the reasoning for the integration of climate aspects. This helps Gezond Leven, and the Department of the Environment, to keep the momentum in policy actions which might otherwise be delayed or distracted, with regressive ‘why are we doing this?’ questions.

Policies, strategies and actions related to the FBDGs

The Flemish FBDGs, ‘Eating according to the food triangle: good for yourself and the planet’^[43] do not exist in isolation but sit alongside several other food and/or climate-related government strategies and policies.

For example, the ‘Strategic Plan: Fleming Lives Healthier in 2025’ was published in 2018. This acknowledges multiple influences upon human health but makes explicit reference to nutrition and food and the importance of enabling healthy choices, plus monitoring dietary patterns. Similarly, the ‘The Flemish Climate Policy Plan’ commits to reducing agricultural emissions and acknowledges the role of diets and local production patterns in achieving this but notes the challenge of doing so against a backdrop of rising agricultural emissions.^[44] Reducing food waste is also addressed in the ‘Action Plan Circular Food Loss and Biomass (Residual) Flows 2021-2025’.^[45]

More particularly, the 2019-2024 Flemish Coalition Agreement included a commitment to create a strong food policy. This led to the Department of Agriculture and Fisheries publishing ‘Go4Food: A Flanders Food Strategy for Tomorrow’ in 2020 (subsequently updated).^[46]

The Food Strategy explicitly recognises the importance of a healthy and environmentally responsible diet but highlights the need for an inclusive system-wide approach considering the interests of different groups of food consumers and producers. Moreover, the Strategy is acknowledged to exist alongside international (e.g. EU), national (i.e. Belgian) and municipal (e.g. city authorities) food strategies.

As shown in Figure 13.3 above, Go4Food presents four strategic pillars linked to 19 strategic objectives. The objectives include explicit reference to healthy and sustainable diets (SO1, SO2) and environmental sustainability (SO6 and SO7), plus more specific topics such as a circular economy (SO5), minimising food waste (SO8) and more sustainable protein production and consumption (SO9). In turn, these are linked to 11 ‘Food Deal’ ambitions, around which cross-cutting actions are encouraged to coalesce, supported by funding (albeit not yet specified).

The Strategy does not itself describe detailed policy measures but does list various possible policy. For example, public communications, education and training, research and development, voluntary agreements with private supply-chains, and financial incentives and regulatory controls.

A number of ‘food projects’ and ‘food deals’ with stakeholders have been initiated under the Strategy. However, no specific ring-fenced funding is attached to the Strategy, with budget allocations needing to be sought on an individual basis across multiple Departmental boundaries (and/or leverage private sector funding) and apparently encountering some political and administrative resistance (pers. comm).

One area in receipt of funding is protein production, reflecting the relative importance attached to the ‘Flemish Protein Strategy 2021-2030’ published in 2021.^[47] The Protein Strategy represents an evolution from similar, earlier strategies to increase the volume and range of domestically produced protein (to reduce reliance on imports, particularly where imports are deemed to be produced unsustainably).

In particular, there is an emphasis on growing additional plant protein for animal feed but also for domestic human consumption, with explicit recognition that this links to dietary change (novel protein sources such as insects and lab-grown cultures are also included). No specific targets are stated for reducing animal protein consumption, but health and climate advantages are noted.

A possible reason for specific funding being made available for the Protein Strategy may be that it aligns with EU-level ambitions to increase self-sufficiency in plant proteins. Such ambitions have recently been reinforced by the European parliament but were already stated to some degree in the EU’s Green Deal and the Farm-to-Fork Strategy, and have been translated into explicit funding commitments in the Flanders CAP Strategic Plan.^[48] Consequently, ring-fenced EU funding is available for increased on-farm production of plant proteins (e.g. in the form of specific public payments per hectare of crop grown). This has perhaps also made it easier to secure additional (if more modest) funding for product development and processing facilities (pers. comm.).

Ring-fenced funding under the Flanders CAP Strategic Plan is also available to increase the area of organic agriculture, and to increase the area of fruit and vegetables (not just protein crops) grown. Moreover, additional capital grant assistance is available for Producer Organizations (e.g. coops) wishing to invest in infrastructure or equipment for fruit and vegetable production. Such measures may increase the availability of locally produced food. Again, such measures align with EU-level ambitions, but it is notable that Flanders’ use of them is higher than in other Member States (including elsewhere in Belgium).^[49]

Appendix F: Dietary guidance development and selected food policies and strategies in the Netherlands

Background to the Wheel of Five and Seven Steps to Sustainability

In the Netherlands, climate-focused dietary guidance is captured in the “Eating more sustainably: fact sheet” (2022), which accompanies the “Wheel of Five” main dietary guidance, both produced by the Netherlands Nutrition Centre (NNC). The former is a 10-page document targeted at professionals/policymakers. The stated aims are to set out the case for environmentally sustainable diets, and how the Dutch diet should change to be in line with science-based planetary health recommendations.

In terms of context/framing, the document begins by conveying the environmental impacts of food production and consumption, and the urgent need for change. It states that the current Dutch diet is not sustainable (“the environmental footprint of the average Dutch diet is almost twice as large as the available area on the planet, per person, for food production”, p2) because the Dutch population (i) consumes too much animal products (ii) wastes huge amounts of food (iii) consumes more energy than is recommended.

The document then refers explicitly to the Dutch “Wheel of Five” model (Figure 15.1), which depicts the proportions in which different food groups are recommended to feature in the diet (vegetables and fruit; spreading and cooking fats; dairy, nuts, fish, legumes, meat and eggs; bread, grain/cereal products and potatoes; drinks). In the model, discretionary foods (high in fat, salt and sugar) are classed as ‘outside’ the model and non-essential to diet. The document states that shifting from the current diet to the Wheel of Five is good for health and climate.

Finally, the document gives specific advice within food groups, about the most sustainable options to choose, and sums these up in ‘7 steps to a more sustainable diet’. These are: eat less meat (opt more often for pulses, nuts or eggs); waste as little as possible (buy and cook what you need); eat recommended amounts (moderate your snacks and sweets); drink mostly tap water; eat enough dairy and cheese (but within bounds); buy seasonally (and check product origins); choose premium sustainability labels.

Overall, there are three eye-catching features of the Dutch FBDGs. First, the dairy intake recommendations are to “eat sufficient dairy to avoid chronic diseases but not more than that”. Second, there is detailed and nuanced advice about meat. The guidance recommends clearly that eating less meat and dairy reduces the impact on the environment, however it explains that eating a small amount of meat (around once per week), requires less agricultural land than a totally meat-free diet. This is because animals can convert some inedible plants into edible proteins. Thus, the guidance advises that animal products have their place in a sustainable diet, but intake levels need to be less than current consumption. Finally, the guidance places emphasis on making diets more sustainable by choosing better options within food categories, by way of eco-labels, and in particular, from a defined set of ‘reliable’ eco-labels. This set has been compiled by the Dutch government to help address consumer confusion over labels, so they can choose with confidence.

Background to the FBDG development process

Two agencies led the development of the Dutch FBDGs. These were the National Institute for Public Health and the Environment (NIPHE), a research centre which collects and analyses scientific evidence and conducts data modelling, and the Netherlands Nutrition Centre (NNC), a body which translates the science into practical FBDGs for consumers and health professionals. Both are independent bodies, funded solely by the Ministries of Health and Agriculture. In 2015, the NIPHE reviewed the scientific evidence on health and climate impacts of diets, with input from academic subject experts. NIPHE used this intelligence to model dietary guidelines as close as possible to the existing Dutch diet, while meeting parameters of health, climate impact, feasibility and applicability to different target groups. Figure 15.2 shows the model constraints. For health reasons, minimum intake levels of vegetables, fruit, wholegrains, fish, legumes, nuts and dairy were specified. For climate reasons, maximum intake levels of fish, red meat, total meat, eggs and dairy products were specified. Maximum intake levels of red meat and eggs were specified also for health reasons.

The NNC used the modelled solutions to draft the public facing dietary guidance, including the graphics. A transparent consultation process followed with experts, to check for any errors/omissions in the science, and also health professionals, to advise on practical implementation.

The food industry was specifically not involved in the consultation. Only after the final guidance was completed were meetings held with industry representatives. This approach was taken to maintain both the real and perceived independence of the NIPHE and NNC. In total, the development process took several years.

At the time of writing, the Dutch Health Council are currently updating their nutritional guidance, and advances in climate science/data mean there is the opportunity for NNC to add more environmental indicators into their modelling (e.g. land and water use, pollution, and biodiversity), for the next revision. Another ambition is to set a clearer sustainability target for the FBDGs, for example, to achieve a certain percentage reduction of GHGs in the Dutch diet.

Policies, strategies and actions related to the FBDGs

Policies relevant to food in the Netherlands appear to reflect the traditional priorities of host ministries, with relatively little integration of health and climate goals. For example, the 2018 ‘National Prevention Agreement: Towards a Healthier Netherlands’ presents ambitions for healthier lifestyles by 2040 but without reference to sustainability. Similarly, the 2015 ‘National Health Policy’^[50] includes goals to increase consumption of fruits and vegetables, but these are justified for health not climate reasons. Meanwhile, the 2019 ‘Climate Agreement’, which sets economy-wide emission reduction targets of 49% by 2030, contains only one brief reference to the need for change in food consumption habits (5 lines in a 247 page document).

In relation to agriculture, significant public funding has been allocated to support progress towards agricultural emission targets. This includes continuing production support measures under the CAP for organic farming, fruit and vegetable production, and protein production.^[51] For example, direct support to increase the area of particular crops grown, consistent with EU-level ambitions to expand organic agriculture and reduce dependency upon imported protein crops and fruit and vegetables.^[52] Dutch deployment of fruit and vegetable aid under the CAP is relatively high compared to most other Member States, although less than in Flanders.^[53]

The Dutch National Protein Strategy represents a more integrative policy approach. As in Flanders, CAP funding has been used to encourage plant protein production at farm level. This is being combined with further funding made available under the National Green Fund. It also includes leverage of private sector investment, on the basis of potential market opportunities for plant (and more novel) forms of protein. The Strategy also links to broader ambitions under the earlier ‘Strategic Biomass Vision for the Netherlands towards 2030’.^[54] Both Strategies acknowledge the health and climate motivations for reducing overall protein consumption by 10% to 15% whilst also decreasing the proportion of animal-based protein.

Example responses to encouragement for private funding to support the protein shift include bids for research and development, product innovations, and conversion of a meat processing plant to handle plant proteins.^[55]

Actions specifically to encourage take-up of the FBDGs are led by the NNC, and it has deployed a range of communication tools, including extensive use of social media and also diet tracker apps. Other policy measures include voluntary private sector agreements to reformulate processed products^[56] and reductions in advertising aimed at children. Certain municipalities have moved to ban advertising of fast food, and Haarlem is introducing a ban in outdoor advertising of meat.

In addition, reducing VAT on fruit and vegetables from the current rate of 9% to 0% has been proposed. This has, however, been delayed repeatedly because of political difficulties. A recent independent report commissioned by the government cautioned that implementation would be difficult. It also suggested that increased fruit and vegetable consumption would not be guaranteed.^[57]

Appendix G: Dietary guidance development and selected food policies and strategies in Sweden

Background to “Find your way to eat greener, not too much and be active”

In Sweden, the FBDGs are captured in the 28-page consumer-facing document “Find your way to eat greener, not too much, and be active” (2015). It was developed by the Swedish Food Agency, in cooperation with the Swedish Public Health Agency, Board of Agriculture and Environmental Protection Agency. The Swedish Food Agency is an independent, government-funded body, which administers public diet and health activities, and is also charged with responsibility to achieve Swedish Government environmental targets.

The document explains that because what we eat has an impact on the environment as well as health, we need to eat more sustainably. In terms of context, it explains that one quarter of climate impact from Swedish households comes from food eaten or thrown away. Eating more sustainably means economising on Earth’s resources, to ensure there’s enough good food to eat in future. It refers to a wide range of environmental issues, including water quality, pesticide use and antibiotics in farm animals as well as climate change.

The guidance itself does not incorporate any plate or pyramid model. Instead, it structures advice around 3 sections: 1. things to eat/do more of; 2. things to switch; and 3. things to eat less of. For each of these actions, there is a dedicated page which explains the advice in more detail, including the link to environmental impact, offering specific ingredient and recipe suggestions to help make the change. There is strong emphasis on “making the changes work for you”. Figure 16.1 shows the page of guidance for red and processed meat. This includes practical advice for reducing consumption of these products, foods to swap with, dish and recipe suggestions, and advice on how to buy the most sustainable red meat.

There are three points of particular interest in the Swedish guidance. First, as Fischer and Garnett (2016) note, the guidelines are nuanced and detailed about which types of foods to choose within a category, and why those are best for the environment. For example, the guidance advises high fibre vegetables over greenhouse salad crops, due to lower GHGs in production, and better transportation. It also recommends other grains and potatoes over rice, within the cereals group, because of the high carbon impact of rice production.

Second, the advice takes a nuanced approach to the environmental impacts of animal production systems, noting that livestock can contribute to landscape and biodiversity. This leads to a mantra of a ‘less but better’ approach to meat consumption, with ‘better’ meaning organic, eco-labelled and Swedish: “If you cut back on meat, you’ll have enough money for meat produced sustainably, with attention paid to the welfare of the animals. Choose eco-labelled meats such as free range, organic or certified eco-friendly.” There is no further discussion of this advice in relation to lower income households, for example.

Background to the FBDGs development process

The origins of the current FBDGs date back to 2007/08, when the Swedish Government was motivated to act on international evidence on climate change, including from the IPCC, which recognised that food is part of the climate problem. From 2008-13, the Swedish Food Agency commissioned analysis of the environmental impacts of different foods, alongside evidence on the health effects of diet gathered from Nordic Nutrition Recommendations (NNR)^[58]. The joint evidence was reviewed, in collaboration with experts from the Swedish Public Health Agency, Board of Agriculture and Environmental Protection Agency. The review was supported by a stakeholder panel.

Discussions during the review process were reportedly constructive, helped by the fact that the process was data-driven (e.g. no one could dispute that Swedes ate too much meat with the relevant statistics in front of them). Emphasis was also placed on finding points of agreement between the parties. For example, that although meat consumption should decrease, consumption of Swedish meat need not decrease, as Sweden is a net importer of meat. This led to the “less but better” messaging, which was supported by multiple stakeholders.

In 2014, a public consultation took place, including participants from industry, consumer and patient organisations, and public health professionals. From this process, the guidance was drafted and tested with consumers. The guidance was published in 2016/17, hence the whole process from initial discussions to publication took almost 10 years.

It is worth noting that since the development of this guidance, the latest revision of the Nordic Nutrition Recommendations (NNR), in 2023, has been published. The NNR is a forum and programme funded by the Nordic countries, including Sweden, to gather robust evidence on diet and nutrition. The latest revision includes explicit reference to climate impact. It therefore provides a very high standard, scientifically informed evidence base on climate-friendly diets.

Policies, strategies and actions related to the FBDGs

In Sweden, the policy landscape for sustainable diets appears fragmented. For example, the 2016 “A National Food Strategy for Sweden”, and subsequent “Action Plan” published in 2019, focus almost exclusively on supply-side measures, notably funding for farmers and technological innovation. This relies heavily upon pre-existing (ring-fenced) funding under the Common Agricultural Policy (CAP). The Strategy is justified in terms of increasing production for domestic and export markets and to increase self-sufficiency and rural employment. However, these measures are not connected to actions to stimulate domestic capacity or growth on the demand side.

In addition, the 2016 ‘Strategy for Sustainable Consumption’ contains only a brief reference to food (a short paragraph, which refers to a Government desire for country of origin labelling of meat in restaurants and canteens). Meanwhile, the 2018 “Climate Framework Policy”, which sets out the Swedish Government’s net zero targets for the whole economy, also makes no reference to food consumption or dietary change.

The gap between supply and demand side policy actions for healthy and sustainable food is also apparent in relation to organic food. The Government aims for 30% of Swedish agricultural output to be certified organic by 2030. It also aims for an increase in consumption of organic food, for 60% of public food to be certified organic by 2030. However, while direct funding has been allocated to support production, much less has been targeted at achieving the demand side ambitions.

In 2021, the Swedish Government tasked the Swedish Food Agency and Public Health Agency to propose areas of action needed for a more sustainable food system in Sweden, and indicators to measure progress^[59]. The work was based on consultations with authorities, industry and civil society. The report, published 2024, emphasizes the need for joined-up policies to tackle health and climate problems: for example, Action area 3 concerns “cooperation between public and commercial actors to promote a sustainable and healthy food environment”. However, given recent shifts in politics in Sweden and hardening resistance from industry stakeholders to food system change, it may be challenging for officials to take forward many of the recommended Actions in the report.

The National Food Strategy does not provide details of specific policy measures but does list types of measures. For example, the provision of information to consumers and the role of public sector catering. However, the main focus is on support to food supply-chains to increase productivity and reduce food waste. Efforts to improve productivity include support for research and innovation, but also deployment of funding under the CAP Strategic Plan. This includes coupled support for livestock production but also funding for organic production plus a limited amount for fruit and vegetable production.^[60]

A follow-up Action Plan to the National Food Strategy published in 2019^[61] does list more specific policy measures and projects, accompanied by budget allocations, but again focuses almost completely on production rather than consumption. The Action Plan also sets targets for 30% of Swedish agricultural and 60% of public food consumption to be certified organic by 2030.

The general absence of specific targets and policy measures in relation to sustainable food consumption has also attracted commentary from Swedish academics.^[62] Similarly, several published studies suggest that dietary change, particularly away from meat to more plant-based diets, has health as well as climate benefits.^[63] However, whilst meat consumption has reduced slightly in recent years, it is acknowledged that changing consumer behaviour to achieve further reductions is challenging.^[64]

Published academic studies have also commented on the general absence of specific policy measures. For example, over-reliance on public information, public sector catering and increased domestic production rather than direct regulatory controls and/or fiscal measures.^[65]

It is possible that the anticipated refresh of the National Food Strategy scheduled for 2024 will address some or all of the identified policy weaknesses. However, the Board of Agriculture and its Minister are still actively promoting production-based policy approaches (pers. comm.)

© The University of Edinburgh
Prepared by Pareto Consulting on behalf of ClimateXChange, The University of Edinburgh. All rights reserved.

While every effort is made to ensure the information in this report is accurate, no legal responsibility is accepted for any errors, omissions or misleading statements. The views expressed represent those of the author(s), and do not necessarily represent those of the host institutions or funders.

1. e.g. see Reay (2020), Crippa et al., (2021), Agriculture and climate change – Agriculture and the environment – gov.scot (www.gov.scot). ↑
   

   
   

2. e.g. see Planetary Health | UNFCCC and The Lancet Planetary Health Home Page ↑
   

   
   

3. equality-opportunity-community-programme-government.pdf (www.gov.scot), Good Food Nation – Food and drink – gov.scot (www.gov.scot), Climate change – gov.scot (www.gov.scot) ↑
   

   
   

4. See Comrie et al, 2024, Scottish Emission Targets & Progress in reducing emissions in Scotland – 2022 Report to Parliament – Climate Change Committee (theccc.org.uk) and 2. Response to CCC Recommendations – Climate Change Committee’s (CCC) annual progress report 2022 recommendations: SG response – gov.scot (www.gov.scot) ↑
   

   
   

5. The Eatwell Guide | Food Standards Scotland ↑
   

   
   

6. The eatwell guide: A more sustainable diet | The Carbon Trust (2016); Scheelbeek et al., 2020. ↑
   

   
   

7. Springmann et al (2020) The healthiness and sustainability of national and global food based dietary guidelines: modelling study | The BMJ ↑
   

   
   

8. German guidance was updated in spring 2024, shortly before publication of this report. The consumer-facing documents now contain less reference to climate than before. However, background documents do retain a climate focus, and the guidance itself is based on optimization modelling for health, GHG emissions and land use. Hence, we have retained the German FBDGs in the ‘green’ category. ↑
   

   
   

9. For example, confectionery, sweet biscuits, savoury snacks, cakes, pastries, puddings and sugar containing soft drinks. See https://www.foodstandards.gov.scot/publications-and-research/publications/briefing-on-discretionary-foods ↑
   

   
   

10. see Australia | Food Policy Index and FoodEPI_AB_Report_WEB-FINAL.pdf (utoronto.ca), Dawkins et al (2023) ↑
    

    
    

11. Voedseltop Synthese (vlaanderen.be) ↑
    

    
    

12. The NNR is a forum and programme funded by the Nordic countries, including Sweden, to gather the latest scientific evidence on diet and nutrition. The aim is to provide a robust evidence base that national governments in the Nordics can use to inform their dietary guidance. ↑
    

    
    

13. Government Offices Sweden 2021. Sweden’s pathway for sustainable food systems. ↑
    

    
    

14. School meals will speed up the transition to a sustainable food system | Vinnova ↑
    

    
    

15. E.g. Barton et al, 2015; Barton et al, 2022; Food Standards Scotland, 2020; Comrie et al, 2024. ↑
    

    
    

16. Comrie et al, 2024. ↑
    

    
    

17. See also Appendix D. ↑
    

    
    

18. Matthews et al, 2023. ↑
    

    
    

19. e.g. Gladding et al., 2020; Andretta et al., 2021; Gržinić et al., 2023. ↑
    

    
    

20. This would be to recognise the target of the Climate Change Committee. However, how that target would apply to Scottish dietary guidance is unclear, as no intake range for dairy is currently recommended. ↑
    

    
    

21. E.g. Strid et al., 2019; Hendrie et al., 2021; Leme et al., 2021; Yin et al., 2023. ↑
    

    
    

22. Matthews et al, 2023. ↑
    

    
    

23. Garnett et al., 2015. ↑
    

    
    

24. https://mijn.voedingscentrum.nl/nl/eetmeter/ ↑
    

    
    

25. Roos et al, 2021; Matthews et al, 2023. ↑
    

    
    

26. Bailey and Ross Harper, 2015. ↑
    

    
    

27. Roos et al, 2021. ↑
    

    
    

28. Roos et al, 2021; Burgaz et al, 2023. ↑
    

    
    

29. Matthews et al, 2023. ↑
    

    
    

30. Scarborough et al 2020 cited by Burgaz et al 2023 ↑
    

    
    

31. e.g. Purnell et al., 2014; Vermeir et al., 2020; Eluwa et al., 2023 ↑
    

    
    

32. See United Kingdom Internal Market Act 2020 (legislation.gov.uk) and Subsidy Control Act 2022 (legislation.gov.uk) ↑
    

    
    

33. Roos et al, 2021 ↑
    

    
    

34. Healthy Eating in Schools: guidance 2020 (www.gov.scot) ↑
    

    
    

35. Sustainable Scotland Network – Public Bodies Climate Change Reporting 2021/22: Analysis Report ↑
    

    
    

36. Burgaz et al, 2023; Bailey and Ross Harper, 2015 ↑
    

    
    

37. Matthews et al 2023. ↑
    

    
    

38. For example, processors and retailers are progressing faster on adding climate-related criteria to their quality labels than sector-wide Quality Assurance or PGI schemes. The resulting fragmentation may not help consumers to make informed choices about climate-friendly options. ↑
    

    
    

39. https://www.ruralpayments.org/topics/agricultural-reform-programme/arp-route-map/ and https://www.gov.scot/publications/climate-change-action-policy-package/ ↑
    

    
    

40. e.g. see https://www.youtube.com/watch?v=LrmbyMaxZhk and https://www.youtube.com/watch?v=KJ-2NjQC1ag ↑
    

    
    

41. Tables adapted from style deployed in supplementary material presented by James-Martin et al. (2022). Where recourse has been made to machine translation via Google Translate and DeepL, the accuracy of terminology and titles in English may be imperfect. ↑
    

    
    

42. However, the FAO suggests Ministry of Health, the Austrian Agency for Health and Food Safety, the National Nutrition Commission and the Austrian Nutrition Society; Ministry for Labour, Social Affairs, Health and Consumer Protection ↑
    

    
    

43. Food-triangle-EN.pdf (gezondleven.be) ↑
    

    
    

44. https://publicaties.vlaanderen.be/view-file/13458, be_final_necp_parta_en_0.pdf (europa.eu) and be_final_necp_partb_en_0.pdf (europa.eu) ↑
    

    
    

45. 210706 English version VR 2021 0204 DOC. Actieplan voedselverlies en biomassa 2021-2025 EN (oneplanetnetwork.org) ↑
    

    
    

46. Go4Food, A Flanders food strategy for tomorrow. Synthesis | Vlaanderen.be ↑
    

    
    

47. Vlaamse Eiwitstrategie 2021-2030 (oneplanetnetwork.org) ↑
    

    
    

48. EU protein strategy (europa.eu), REPORT European protein strategy | A9-0281/2023 | European Parliament (europa.eu), The Commission approves the CAP Strategic Plans of Belgium – European Commission (europa.eu), 16925dca-08d0-4592-8c87-202d12ec8bcd_en (europa.eu) ↑
    

    
    

49. 7b3a0485-c335-4e1b-a53a-9fe3733ca48f_en (europa.eu) (Fig 30), Organic action plan – European Commission (europa.eu), Fruit and vegetables – European Commission (europa.eu). Organic and fruit & vegetable support has been and remains available in Scotland under the CAP, albeit with more modest funding. ↑
    

    
    

50. https://extranet.who.int/nutrition/gina/sites/default/filesstore/NLD%202015%20National%20Health%20Policy%20Note.pdf ↑
    

    
    

51. Including for organic production and fruit and vegetable production Microsoft Word – 20220209_Nederlands NSP GLB – versie 1.0 (overheid.nl) ↑
    

    
    

52. Organic action plan – European Commission (europa.eu), Fruit and vegetables – European Commission (europa.eu) , EU protein strategy (europa.eu), REPORT European protein strategy | A9-0281/2023 | European Parliament (europa.eu) ↑
    

    
    

53. 7b3a0485-c335-4e1b-a53a-9fe3733ca48f_en (europa.eu) (Fig 30) ↑
    

    
    

54. 92465_visie_biomassa_engels_def.pdf (europa.eu) ↑
    

    
    

55. Five major players launch masterplan for protein transition as economic engine in The Netherlands – WUR, The ‘master plan’ to double legume consumption in the Netherlands by 2030 (foodnavigator.com) , Test resolution 4K magazine design (investinholland.com) , ‘ME-AT the alternative’ launches first locally grown protein chain – Vion Food Group ↑
    

    
    

56. https://www.rivm.nl/publicaties/nieuwe-criteria-voor-productverbetering ↑
    

    
    

57. https://www.seo.nl/wp-content/uploads/2023/03/2023-32-btw-nultarief-eindrapport.pdf https://www.seo.nl/wp-content/uploads/2023/03/2023-32-btw-nultarief-eindrapport.pdf ↑
    

    
    

58. The NNR is a forum and programme funded by the Nordic countries, including Sweden, to gather the latest scientific evidence on diet and nutrition. The aim is to provide a robust evidence base that national governments in the Nordics can use to inform their dietary guidance. ↑
    

    
    

59. Government Office Sweden 2021. Sweden’s pathway for sustainable food systems. ↑
    

    
    

60. 7b3a0485-c335-4e1b-a53a-9fe3733ca48f_en (europa.eu) ↑
    

    
    

61. The Government’s action plan part 2: A food strategy for Sweden – more jobs and sustainable growth throughout the country – Regeringen.se ↑
    

    
    

62. e.g. sei-wp-climate-food-transport-gong-2205a.pdf ↑
    

    
    

63. e.g. Less meat, more legumes: prospects and challenges in the transition toward sustainable diets in Sweden | Renewable Agriculture and Food Systems | Cambridge Core , Sustainability benefits of transitioning from current diets to plant-based alternatives or whole-food diets in Sweden | Nature Communications and Food Dishes for Sustainable Development: A Swedish Food Retail Perspective – PMC (nih.gov) ↑
    

    
    

64. e.g. Identifying barriers to decreasing meat consumption and increasing acceptance of meat substitutes among Swedish consumers – ScienceDirect, Livsmedelskonsumtion av animalier. Preliminära uppgifter 2020 – Jordbruksverket.se ↑
    

    
    

65. Dawkins et al. (2023) and 2023. Policy for sustainable consumptionan assessment of Swedish municipalities. Frontiers in Sustainability, 4, p.1265733. and Policy-Options-for-Sustainable-Food-Consumption-2021-Mistra-Sustainable-Consumption-report-1.pdf (sustainableconsumption.se) ↑
    

    
    

July 2024

DOI: http://dx.doi.org/10.7488/era/4622

Executive summary

Scotland’s net zero 2045 ambition and updated Climate Change Plan require the rapid development of carbon capture and storage (CCS) and carbon dioxide removal (CDR). Current pathways to meeting statutory targets are dependent on large industrial clusters, funded by the UK Government.

Alternative pathways for the rapid decarbonisation of smaller, distributed biogenic sources of carbon dioxide (CO₂) may be available, noting that these would be of an order of magnitude less than the industrial clusters, with the advantage of high-value CDR credits. This requires permits for storage sites within Scottish inshore waters which extend to 12 nautical miles from the coast, and policy coordination across capture, transport and storage.

This study explored the potential total CO₂ storage capacity in Scottish inshore areas and the availability of onshore emissions originating from biomass, known as bio-CO₂. The study also investigated if the distribution of potential sources and storage availability would make it possible to expedite Scotland’s CCS and CDR potential.

The capture of bio-CO₂ is already a commercial success in Scotland, with an ambition to scale without subsidy to 1 million tonnes per year by 2030, which requires storage. Norway, Denmark and Iceland are selling CO₂ storage at a premium, reflecting a supply-and-demand imbalance in regional storage availability.

Aims

This study aimed to assess the potential for developing CCS within 12 nautical miles of the Scottish shoreline – an area within Scottish Ministers’ competence. We explored the feasibility to deploy high-value capture and low-cost CO₂ storage in Scotland and what the commercially viable total capacity for nearshore storage is likely to be. The outcomes also address the availability of bio-CO₂, domestic CCS value chains, fit-for-purpose storage site licensing and high-value CDR certificates.

We propose that Scotland can make rapid progress by refocusing on domestic bio-CO₂. These emissions are already being captured in Scotland at low cost and with simple technology.

We identified prospects within the 12 nm territorial waters. Developing secure storage of high value bio-CO₂ within the Scottish jurisdiction can produce several financial benefits, including premium lease payments to Crown Estate Scotland, development of local skills and growth of new businesses. This has the potential to increase Scottish GDP by tens to hundreds of millions of pounds per year, as well as paying staff and corporate taxes.

Developing Scottish storage sites for CO₂ provides elements of control over licensing and the pace of approval for carbon capture and storage. Developing secure storage of high value bio-CO₂ within the Scottish jurisdiction can produce CO₂ removals, equivalent to direct air capture but at much lower financial cost.

We reviewed the potential for the rapid licensing of inshore storage using a streamlined version of UK licensing. Four geographic areas of interest are ranked by maturity of evaluation. We examine when injection could start if all regulations were in place across the different authorities.

Findings

We addressed five elements of CCS: licensing, storage, sources, timeframes and cost. We found that it is theoretically possible to adopt a streamlined licensing framework; inshore storage is available for rapid appraisal, albeit at a very limited capacity compared to offshore; bio-CO₂ sources are abundant across nine sectors with explosive growth potential driven by the global CDR market; timeframes can be measured in years with the potential to deliver operational injection of bio-CO₂ before 2030; costs are competitive with UK clusters and export markets.

Licensing

• CO₂ storage involves multiple activities under different licensing regimes.
• New regulations for CO₂ storage are not required.
• Minor amendments to existing statutory instruments may be required.
• The amendments may be fast if based on existing UK regulations and the CCS Directive.
• A Crown Estate Scotland (CES) lease is also required.
• Consents may also be required from the Scottish Environmental Protection Agency (SEPA) and the Scottish Government’s Marine Directorate.

Storage

• Four areas have well data and seismic coverage.
• Only the Lybster oil field is a candidate for immediate development.
• The total expected nearshore capacity is 2 Mt without further extensive surveying.
• The Forth Basin is a low Technology Readiness Level research opportunity.

Sources

• We mapped 98 of the largest bio-CO₂ sources in Scotland.
• Source emissions range from 2 to 360 kilotonnes per annum.
• Separation of CO₂ from distilleries and biogas upgrading are low cost.
• Combustion sources are higher cost and are the largest sources and sectors.
• The source distribution across five clusters favours road transport to local storage.

Timeframes

• North Sea Transition Authority appraisal licences average five years and three months.
• Appraisal are followed by storage permits and 2 years of further site development.
• The fastest storage permits are issued in as little as three years.
• The fastest development of a site to first injection is around a year.
• Lybster permitting could be fast but requires further exploration of legal frameworks.
• Rapid progression is dependent on pre-existing data to confirm site suitability.

Costs

• Capture costs for separation sources are low, at £60 per tonne.
• Capture costs for combustion sources are higher, at £120 per tonne.
• Truck transport costs £20 per tonne per 100 miles, or £0.12/tonne/km.
• Storage costs for Lybster are £70 per tonne.
• The full chain CCS cost is £150 per tonne for separation within 100 miles of Lybster.
• Storage costs for sites further offshore are at least two to three times higher.

Revenue

• CDR credits on the European voluntary market are worth £297 per tonne.
• Taxing storage would be subject to further work by the Scottish Government.
• As a simple example, a 10% tax could yield between £7 and £30 per tonne per annum.
• Lybster tax revenue would be £30 million for a 2 Mt capacity and £15 per tonne tax.
• Further revenue is available if bio-CO₂ is transported to Acorn via the Feeder 10 pipeline.
• Combined revenue for Lybster and Feeder 10 could total £250-500 million by 2045.

Next steps

In order to progress the potential benefits of CCS and CDR in Scotland, we recommend the following actions.

• The Scottish Government could conduct further work to fully understand the law around consenting and regulating storage and consider pursuing a streamlined regulatory framework for storage that builds on the structure established by the NSTA while emulating the accelerated approach taken by Denmark and Norway. This is relevant to Scottish policy, legislators, SEPA, and the Marine Directorate.
• The Scottish Government could consider supporting an appraisal of Lybster with the involvement of a compliant operator. This would require 3D seismic interpretation to build a static model and undertake reservoir simulation. This could be completed within one year with the intention of transitioning to a front-end engineering design study and development decision within three years. This requires a competent person’s report on the site, model outcomes, and risk analysis.
• The Forth Basin saturated water injection proposal could be considered as a potential research pilot to mature the concept and location from its current low TRL. This is relevant to the Scottish universities’ research community and British Geological Survey.
• Maturing the Fraserburgh and Solway Firth areas could proceed when market signals support the necessary investment in data acquisition and offshore development.
• The Scottish Government could seek mechanisms and policies to maximise the domestic benefits of full chain CCS, rather than exporting captured bio-CO₂ to storage providers in other countries. The high concentration of bio-CO₂ sources in the central belt raises the possibility of a gathering station for Feeder 10 access to Acorn.

Onshore bio-CO₂ sources located close to inshore CO₂ storage prospects.

(Sources: SCCS, BGS, SNZR, NNFCC, NSTA)

List of abbreviations