Scotland ‘failing in landfill ban preparation’

Local authorities and commercial waste operators in Scotland have failed to make adequate preparations for the upcoming landfill ban, a report to the Scottish Government has said.

And, the Eunomia report commissioned by the Scottish Government also claimed that some waste operators “may not be sufficiently financially robust to compete in the changed market”, with the burden falling on local authorities instead. The report also notes that the waste industry and councils have known about the ban since 2012.

Scotland’s recycling rate for 2015 has been revised

The Waste (Scotland) Regulations 2012 ban biodegradable municipal waste (BMW) from being placed in landfill in Scotland from the 1st of January 2021 but they don’t stop the material being sent to landfill in England or to energy from waste.

Ahead of the regulations coming into force, Eunomia Research & Consulting was commissioned by the Scottish Government to report on the current and future markets for the disposal and recovery of BMW. The aims of this work, said the Scottish Government, were:

  • to consider the availability and costs of disposing of Scottish biodegradable municipal waste in other UK landfills or recovering energy in Energy from Waste (EfW) plants.
  • to consider the opportunities and costs of recovering of Scottish biodegradable municipal waste by exporting the material as refuse derived fuel (RDF) to continental or Irish EfW facilities.


The report was published yesterday (April 23) and said that just 14 councils in Scotland have already made the financial investment to ensure solutions are in place before the 2021 ban, accounting for just 55% of municipal waste.

Nine councils making up 23% of municipal waste arisings have no plan at all for the ban, while others have long-term solutions but not an interim one, or vice-versa.

For commercial waste operators the report said that they “to do not appear yet to have made adequate preparations for the ban.”

“Where strategies are in development they are primarily focussed on transporting waste, either to landfill or treatment infrastructure in Northern England or into thermal treatment capacity abroad.”

Concerns over the ban leading to Scottish companies paying landfill tax in England have long been expressed, with the government’s Office for Budget Responsibility (OBR) claiming last month that Scotland’s 2021 ban on biodegradable municipal waste to landfill will ‘mostly benefit UK tax receipts’ (see story).


The report was commissioned by the Scottish government with two aims: to consider the availability and costs of disposing of Scottish biodegradable municipal waste in other UK landfills or Energy from Waste (EfW) plants; or exporting the material as RDF to continental or Irish EfW facilities. The study can be seen here: Waste Markets Study.

It found that the ban will mean that English landfill costs, and haulage, will replace Scottish landfill as the market cap post-2021 at least as long as capacity remains available.

This will create a “shock to the market” which could inflict “significant marginal costs in cash terms” to some local authorities in the country.

The report said that the ban will result in “significant economic costs to Scotland” due to the need to export an increased amount of residual waste – whether as an interim solution until new thermal treatment capacity comes online, or as a long-term solution. This has the effect of “exporting revenue to English or continental landfill or treatment providers”.

The transition from landfill to alternative treatment “will also result in a reduction in revenue to the Scottish Government as landfill tax receipts reduce.”


The highest costs in the short term are likely to fall on a small number of authorities that have a long-term solution in place that comes in post-2021 but due to their location will have little option but to rely on the export market for a short interim period starting immediately after the ban.

But, with some energy from waste plants already under construction, improvements to the situation can be offset if Scotland builds additional thermal treatment capacity, the report stated.

Residual capacity

Overall, Eunomia’s modelling found that there will be insufficient residual waste treatment capacity in Scotland available to deal with waste generated once the ban is put in place. The extent of this gap will depend on the level of recycling that is achieved.

It gave two scenarios, the first being that Scotland hits all its recycling targets. Under this scenario,  Scotland will have 1.01 million tonnes of treatment capacity compared with generation, falling to 0.09 million tonnes per annum by 2035.

The second sees residual waste generation increases marginally up to a total of 2.40 million tonnes at the time when the ban comes into effect and 2.43 million tonnes by 2035. This leaves a capacity gap of 1.28 million tonnes at 1 January 2021, which decreases slightly as new facilities come on stream through to 2023/24 before growth in waste arisings increases it to 1.15 million tonnes by 2035.

The report concluded that despite the lead-time since the ban was announced in 2012, insufficient residual waste treatment capacity has been brought through into development to meet the expected level of need in Scotland.

In the short term, the ban is likely to lead to a significant rise in residual waste treatment costs for organisations that have not already secured a long-term contract, as the price of local landfill will no longer restrict gate fees and there will be greater reliance on exports, whose price will be likely to be set by reference to the next cheapest option – typically, landfill in England.

Environmental benefits

The report summary points out that the study focuses on the impact of the ban on the cost and benefits of the disposal of residual waste. It is noted that “The impact upon waste reduction, reuse and recycling is not considered. The likely substantial economic and environmental benefit that might be expected from the increase in reuse and recycling is therefore not reflected in these results.”

RDF exports

In contrast to England, the Scottish regulator keeps secret details about exports of Refuse Derived Fuel (RDF) from Scotland, which will be an even more important outlet for municipal waste after the ban. SEPA told in response to a request for details about exports that “the release of the information in question would be likely to prejudice substantially the commercial undertaking of the companies and impact on the relationships they have built and sustained with suppliers and partners in this small market. To release the information could potentially disrupt ongoing business of those involved.”

LARAC Scotland

2 May 2019
Grand Central Hotel, Glasgow

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