Scottish Government

6 POSSIBLE SCOTTISH POLICY INTERVENTIONS

6.1 This section raises possible policy considerations that could encourage ecodesign for further discussion and debate. These relate to the aim to reduce waste and increase waste treatment up the waste hierarchy, in support of the Zero Waste goal and the National Indicator to reduce waste sent to landfill to 1.32 million tonnes per annum by 2010. They also relate to the Greener objectives, particularly to reducing the local and global environmental impact of Scotland's consumption and production.

Overview of policy considerations

6.2 The evidence considered as part of this review suggests that ecodesign principles could be further developed and incorporated into design training and education, processes and standards. The extent to which this is the case varies by design sector and needs further investigation, and the potential costs and environmental gains of doing so need to be assessed.

6.3 Inadequate ecodesign information availability and skills are likely to be key barriers to mainstreaming ecodesign principles, which policy can address. Policy can work both on improving the assessment of environmental impacts and on reducing those impacts, providing tools to minimise life cycle impacts and moving end-of-life treatment up the waste hierarchy, whilst reducing both total and hazardous waste arisings (Zwolinski and Brissaud, 2008).

6.4 Addressing this could be a key issue not just to achieve environmental benefits but to maintain the competitiveness of Scottish design and manufacturing, given the increasing importance of environmental design legislation across the EU and further afield. Given the predominance of exports to the EU in many sectors of Scottish industry (around 50% of total exports by value are to the EU25 (Scottish Enterprise, 2008)), developing and disseminating knowledge to efficiently comply with EU legislation and best practice will help give Scottish exports a competitive advantage.

6.5 Policy interventions can target:

• ecodesign skills and knowledge development (how to design waste out of products and assess this),
• skills and knowledge dissemination (education and lifelong learning) and
• ecodesign practice (mainstreaming ecodesign into Scottish product design, manufacturing and consumption),

6.6 and are broadly split into:

• demand side (consumption) and
• supply side (production) options.

6.7 Demand side policies aim to increase demand for high performing products to increase their market share and so incentivise innovation in that direction. Demand-side policies can influence sales of products designed and manufactured in Scotland and outside of it, potentially influencing design around the world.

6.8 Supply side policies aim to facilitate design changes to meet this demand. Attention is needed to develop policies with broad private-sector support and to consider impacts on the international competitiveness of export dependent industries. This can influence product design for products that are designed and/or manufactured in Scotland, and also help spread ecodesign best practice to designers abroad through teaching to international students attending Scottish University courses.

6.9 The sections below discuss policy considerations for Scotland following the three areas of ecodesign skills and knowledge development, skills and knowledge dissemination, and ecodesign practice.

Policy for ecodesign skills and knowledge development

6.10 Table 4 below indicates the key issues identified in this review that affect the development of skills and knowledge relating to ecodesign, and summarises the policy options for addressing them. Further detail of the policy suggestions is given below the table.

Table 4. Policy options for ecodesign skills and knowledge development

6.11 This review has revealed that standardised approaches and streamlined, clear and easy-to-implement tools for assessing and comparing the life cycle impacts of products are still insufficiently developed. Information on the impacts of different materials is also lacking in certain situations.

6.12 The availability of information on best practice techniques for reducing the impacts of products and production processes also varies. The situation varies by industry sector.

6.13 A mapping of the current state of knowledge, information and tools, and identification of key gaps, likely to include industry-specific, simple LCA tools and assessment techniques, materials information, and production best practice, would be a useful, medium-term, project. A detailed analysis of the sources of waste arisings and the unmet potential of design to reduce waste quantity and hazardousness, and raise its treatment up the waste hierarchy, would support this mapping.

6.14 Further research on tools and information to fill gaps in knowledge could also be beneficial for achieving environmental objectives, in conjunction and coordinating with UK, EU and international levels of government and business, including promoting wider moves to sustainable design research at these levels.

6.15 At a more fundamental level, research should be considered on the realistic potential contribution to waste reduction from product and process design, to assess if sustainable production can deliver sufficient resource reductions in the timeframe required to minimise the risk of severe impacts on natural systems. Research would also be useful in assessing how policy-making can deliver correct incentives to realise such potential, or on alternative measures to achieve such reductions if production cannot meet them alone.

Policy for ecodesign teaching and dissemination

6.16 Table 5 below indicates the key issues in ecodesign teaching and dissemination, and options for policies to address these. More detail is provided below.

Table 5. Policy options for ecodesign teaching and dissemination

6.17 Various government support bodies provide substantial help with ecodesign to business, including tailored advice and site visits. It was reported by HLSTC (2008: 68-71) for the UK that some businesses were confused about the roles of the different bodies. It is not clear the extent to which this is an issue that significantly affects the ability of businesses to access the full range of services available to them. It may be valuable to discuss this issue with business and possible options for providing extra clarity for businesses seeking advice. One option may be to establish a clear single first-contact point to provide a centralised description of services available from these bodies, and which can refer businesses to the relevant organisation for their needs. The Scottish Government is currently reviewing all of its waste delivery bodies, to ensure economy, effectiveness and efficiency.

6.18 It would also seem beneficial to highlight best practice and "quick wins" to businesses with limited capacity to examine their practices in detail.

6.19 Open sharing of best practice between businesses should also be encouraged, maybe feeding into providing a resource presenting best practice, along the lines of OVAM's Inspiration database (see earlier).

6.20 The level of ecodesign teaching in Scotland was not clear from this review. It would be valuable to assess ecodesign teaching at different levels of education more thoroughly, although this is likely to be a longer term action. Depending on the levels found, there could be a case in certain areas for supporting the increasing mainstreaming of eco-design teaching, to support the achievement of Scottish Government waste and other environmental objectives, and to help ensure that Scottish designers have the skills and knowledge to meet future EU legislative requirements and maintain a strong industry.

6.21 As a minimum, it would seem appropriate that courses cover existing and upcoming environmental legislation affecting product design across the EU and worldwide, the contribution product design can make to reducing environmental impacts and saving business money, how to assess and reduce the impacts of design decisions, and how to keep up to date with policy developments in the future.

Policy for ecodesign practice in business

6.22 The key issues from this review affecting ecodesign practice in business are presented in Table 6 below, along with options for Scottish policies to address these. More details are provided in the sections below.

Table 6. Policy options for ecodesign practice in business

Demand side - incentivisation

6.23 Demand-side policies are about increasing the market share of more sustainable products, including those that contribute to reducing waste arisings and environmental impacts, and reducing the market share of poorly performing products.

6.24 The aim is to mainstream sustainable design and remove unsustainable products from the market. Some of the EU-level initiatives already reviewed have this aim, but there is scope for further action by Scotland.

Green Public Procurement

6.25 Levels of GPP are already high in the UK (see above), but there is scope to increase this. The Netherlands, for example, has a target to achieve 100% GPP by 2010 (Nash, 2009: 497)l. Whilst waste arisings and end-of-life criteria may be explicit in GPP criteria, consideration needs to be made that they do not conflict with the broader aim of reducing total environmental impacts over the whole product lifecycle.

6.26 UK and European efforts to standardise and streamline green procurement assessment criteria and procedures should simplify adoption of increased GPP. Existing product labels for energy efficiency and other environmental criteria should also help. One possible option for achieving waste and environmental ambitions would be to set a clear target and provide clear guidelines and tools for GPP to local authorities in line and compatible with what is already being done across the UK and EU.

6.27 It is inevitable that different environmental goals will at times directly conflict with one another, as already discussed, so the GPP criteria developed would need to include a clear hierarchy or weighting of goals, to enable choices to be made in these situations.

Voluntary agreements with business procurers and retailers

6.28 A voluntary agreement on green procurement criteria for business-to-business purchasing would also drive ecodesign, and has the potential to save business money in the same way it does in GPP for the public sector. WRAP already provides extensive support to business to implement this, but development of a voluntary scheme for green procurement could increase participation and further increase market share for green products and materials beyond that accomplished by GPP. Development of the scheme can build on existing experience with voluntary schemes such as those reviewed here, and on the experiences of individual businesses in this area. Where applicable, the voluntary scheme procurement criteria should match those of the GPP criteria, to maximise the ease of accessing these green markets, to reduce the barriers to ecodesign that would arise from multiple incompatible standards.

6.29 With retailers, there is an option to pursue a voluntary agreement to increase choice editing, to remove poorly performing products from sale and incentivise the purchase of best-in-class products by the public. Precedents for these kinds of approaches exist within the Retailers' Environmental Action Programme described earlier (EuroCommerce and European Retail Round Table, 2009b), and it seems that this Programme would be an appropriate one to coordinate with. Clear and prominent promotion to the public of the environmental criteria used by retailers would also send a strong signal which could help establish a social norm regarding consideration of such factors in purchasing decisions.

6.30 For food and drink specifically, the EU-wide Food SCP Roundtable and Envirowise's current efforts to focus increasingly on the reduction of household food waste through a post-Courtauld Commitment are important due to the high environmental impacts of this waste stream.

Tourism Green Star Ratings and awareness raising

6.31 For tourism, the likely impacts of different options for promoting waste reduction best practice in hotels, restaurants and other relevant tourist 'sites' could usefully be explored. Options could include a green star system similar and concurrent to the existing star ratings, based on the energy and water use of the buildings, resource use and waste arisings, waste disposal arrangements, etc. Given the efforts to improve their environmental performance made by some hotel chains and B&Bs there could be significant support for a standardised approach to raising awareness of and promoting their efforts. The potential to follow and operationalise the Global Sustainable Tourism Criteria could be investigated, for example. The Green Tourism Business Scheme, UK-wide but started in Scotland, offers some useful pointers here. www.green-business.co.uk

Supporting public behaviour change and purchasing

6.32 The review indicates that Scotland's ecological footprint could be reduced by identifying where there would be net environmental benefits from encouraging households to replace functioning but inefficient appliances and vehicles with newer ones, and provide financial and other incentives, or support existing initiatives, to encourage households to do this, as described earlier for cars and white goods. Like the green public procurement programme, this also incentivises greener product design by boosting market share for high efficiency products, as well as leading to greenhouse gas emission savings. It would be important to confirm that this leads to net environmental benefits. It is also necessary to consider the marginal cost of abating carbon, and other environmental impacts, through such policies compared to other options for reducing emissions.

6.33 Various options could be implemented to further increase the uptake of energy and water efficiency measures in households. Clear metering can lead to reduced energy and water use. Supplying free or subsidised smart meters that clearly display a household's energy use, and what it is costing them, would provide households with clear information about the cost of energy-using products that they have, encourage more parsimonious use and incentivise increased consideration of energy performance in future purchases. Trials have indicated such meters directly lead to about a 5% reduction in household energy use (Energy Saving Trust, 2008: 7), and there is potential for greater savings over time through behaviour changes arising from the increased awareness. Metered water supplies and charging in England have also led to reductions in water use there.

6.34 Improving the labelling of warrantees and consumer rights regarding longer lifespans could also be considered, to increase awareness and use of these rights, which will incentivise more durable design.

Planning system regulations

6.35 Existing building regulations describe what is necessary to make new build housing "zero carbon". England has a target to make all new build housing zero carbon by 2016, with Wales having an even more stringent target. The "Sullivan Report" reviewed options for Scotland for low carbon building standards and made proposals for consideration by the government (see SBSA, 2007).

Alternative production and consumption models

6.36 Implementing product service systems, remanufacturing, and other substantially different consumption and production models, could have substantial environmental benefits. This review highlighted that there is, in some areas, potential to realise major reductions in per unit (of functionality) environmental impacts, but research is needed into the specifics of Scottish manufacturing to identify where these savings could be made, and how to achieve them.

Supply side - awareness raising and capability building

6.37 Dissemination to business, discussed above, represents a key way to build ecodesign capability. However, barriers to uptake still exist in company culture and awareness, in incompatibilities in waste management and recyclates services, and in capabilities to access markets for green products.

6.38 Awareness of the large and increasing benefits of ecodesign needs to be increased among designers, manufacturers and setters of design specifications. This would involve clear statements of the primary importance of green criteria by public procurers, by business procurers and by retailers. Inasmuch as standard criteria are used, the same central first contact point for business advice could be promoted and used to provide detailed information about the criteria.

6.39 Encouraging business cultural change through management buy-in and environmental champions could also be promoted further, as Envirowise attempts ¹⁷ ( HLSTC, 2008). Adoption of environmental management systems, such as EMAS and ISO 14001, can also be promoted to help with this cultural change.

6.40 Market mechanisms will also provide clear signals to business, with increasing demand for greener product providing incentives to companies to adapt their products accordingly.

6.41 Awareness raising of ecodesign principles can be promoted through more vigorous support of ecodesign awards and competitions. Awards highlight best practice and clarify the benefits, and encourage going beyond the statutory minima ( HLSTC, 2008: 23).

6.42 The capability of businesses to access the expanding green product markets will be increased through the services provided by existing business support bodies. Further support for tendering for GPP may be appropriate - such as Sell2Wales, a site to help SMEs develop tenders for public sector contracts in Wales (Welsh Assembly Government, 2009).

Engagement with other levels of government and business

6.43 The Scottish Government has opportunities to actively encourage other levels of government to take suitable actions, both at the UK level and with the relevant European bodies as they develop EU product eco-design policies.

6.44 Engagement with business and Local Authorities is also important. WRAP's engagement in this area highlights the importance of coordinated efforts. This is especially important to help achieve a closed-loop materials system, where product design needs to be shaped to fit with how waste is being managed, which in turn needs to be shaped to produce consistent and reliable quantities and qualities of recyclates if they are to be fed back into the economy as raw materials. Local Authority and business activities might usefully be coordinated further in this area to maximise potential reductions, reuse, recycling, etc, and minimise waste arisings and landfill. The successful work of WRAP and the Courtauld Commitment shows that voluntary agreements can deliver significant and ambitious goals as long as collective negotiations between stakeholders occur. Active discussions in this area between stakeholders could be promoted or WRAP might be encouraged to further expand its activities into product design and into further industries.