Provide clear and consistent, real and total carbon content labelling on produce, products and services (showing production; processing; transport; and usage emissions) to enable people to make informed choices.

Estimates suggest that over 80% of Scotland’s carbon footprint comes from all the goods, materials and services which we produce and use. Often, we throw away these goods after only using them once or a small number of times. Examples of this include fast fashion and single-use plastics. The Scottish Government agrees that carbon labelling is a way of helping individuals to fully understand the carbon content of the goods and services they purchase and consume. Providing people with this information will help them to make more informed choices about their purchasing habits, and encourage more sustainable consumption.

There are a number of issues with carbon labelling, particularly for products that arrive in Scotland from other UK nations or abroad, given current trading agreements and laws. The other key issue is to ensure consistency in the methodology of carbon measurement across the whole lifetime of goods and services. Some of these issues are explored further in this section.

Following analysis of the Assembly’s recommendations, the Scottish Government will take the following actions:

  • We will explore the feasibility of implementing food carbon labelling in Scotland.
  • We will undertake a feasibility study to explore implementation options for product carbon labelling in Scotland, and the benefits and challenges associated with each.

Recommendation 35: Food Carbon Labelling

Within 5 years, to have fully implemented food carbon labelling, similar to nutritional labelling, that shows real and total carbon content - not the offset carbon footprint.

Children’s Parliament: Label all food and everyday items with where they are made and their impact on the environment.

Children’s Parliament: Make environmentally friendly things in shops cheaper and easier for people to choose. This would involve making sure shops promote and display environmentally friendly options instead of non-environmentally friendly options.

 

Scottish Government Response

The Scottish Government supports the principle of this recommendation and we commit to exploring the feasibility of implementing food carbon labelling in Scotland, both in terms of determining the most effective mechanism and related timescales.

 

We agree it is critical that individuals are provided with the necessary information to make informed choices about the food they eat. This recommendation aligns closely with the Children’s Parliament Call to Action to ‘label all food and everyday items with where they are made and their impact on the environment’. As an example, recently, the food menus at the COP26 Blue Zone in Glasgow included labels showing the amount of carbon emissions associated with each meal.

Currently in the UK, food labelling has a voluntary ‘traffic light’ system for calorie, fat, saturates, sugars and salt content information. Our understanding of this proposal is that there would be a similar mandatory system for the carbon emissions associated with food production, processing and transport.

The recommendation calls for food carbon labelling to be fully implemented within five years. It is not possible to assess the viability of this timescale until we have fully considered the range of evidence and investigated which approach would secure the greatest impact. At this stage, we are working through a number of challenges that have been identified in relation to this activity:

  • Similar schemes proposed in other nations have come under criticism for the costs to business;
  • The UK Internal Market Act could render regulations in this area ineffective. While the regulations would apply to goods produced in or imported directly into Scotland, the market access principles of the Act mean we could not impose those standards on goods coming into Scotland from other parts of the UK, nor could we prevent those goods from entering the Scottish market, provided these satisfy regulations set elsewhere in the UK;
  • The most appropriate methodology to measure carbon emissions (e.g. through a carbon calculator app) would need to be assessed, given different farming practices;
  • The impact of adding a carbon label to the existing traffic light legislation or as an additional label would need to be explored; and
  • The reach of the scheme would need to be decided, for example whether it covers food served in restaurants and cafes.

To secure a full assessment of this, we have committed to undertaking a feasibility study which will look at the Assembly’s recommendation and potential impact and implications of implementing it, including the challenges outlined above. Significant consultation with stakeholders will be undertaken before key decisions are made.

Wider work is already underway which is also of direct relevance to this recommendation. For example, the SNP manifesto committed to introducing a ‘Sustainably Scottish’ brand for food producers to showcase their green credentials. Work on this brand is still at an early stage. It will work slightly differently to carbon labelling, in that it will be voluntary and the brand will be available to all food producers, manufacturers and suppliers that can meet standards on provenance and low carbon operations.

To support the brand’s development, we have commissioned consumer research into attitudes towards sustainability and the interest of Scottish businesses of being involved, as well as exploring how other nations have implemented similar schemes.


Recommendation 36: Declare Travel Carbon Impact

Immediately make it easier for people to make informed choices about how they travel, taking carbon emissions into consideration, by requiring transport providers to declare the carbon impact of flights and train journeys in a clear and meaningful way at the time of booking.

 

Scottish Government Response

The Scottish Government supports this recommendation in part, but does not have the required powers to enact such a measure.

 

The Scottish Government is committed to encouraging modal shift to low carbon forms of transport. However, consumer protection and standards relating to airlines is a matter reserved to the UK Government. We are aware that some airlines already disclose the emissions associated with their flights, and that various independent applications provide this information, but since much of Scotland’s air connectivity is provided by airlines registered and based in other countries, Scotland has limited scope to influence airline operators to voluntarily disclose such information.

While we are not able to require transport providers to declare the carbon impact of flights, we continue to increase the availability of low carbon forms of travel. For example, 75% of rail journeys across Scotland are made on electric trains, and we have committed to make rail passenger services net zero by 2035, five years ahead of UK ambitions. Further commitments that seek to encourage a shift to low emissions transport are included in Goals 5 and 6.


Recommendation 37: Product Carbon Labelling

Require businesses to label products to show the carbon footprint of the production process.

Children’s Parliament: Label all food and everyday items with where they are made and their impact on the environment.

Children’s Parliament: Make environmentally friendly things in shops cheaper and easier for people to choose. This would involve making sure shops promote and display environmentally friendly options instead of non-environmentally friendly options.

 

Scottish Government Response

The Scottish Government supports this recommendation and welcomes moves to explore the feasibility of a carbon labelling standard for consumer products.

 

As with Recommendation 35, this aligns closely with the Children’s Parliament Call to Action to ‘label all food and everyday items with where they are made and their impact on the environment’. Again, the Scottish Government agrees with the principle of ensuring individuals have information on the carbon impact of items they purchase and consume, so that they can make informed decisions. International consumer research completed by the Carbon Trust in 2020 found that two thirds (67%) of consumers were in support of the carbon labelling of products, with the level slightly lower in the UK (63%).

We recognise the need to promote sustainable consumption. This will require a range of measures, potentially including product carbon labelling.

Some of the challenges relating to Recommendation 35 are still relevant here, including the potential cost to businesses, the carbon calculator methodology used and the interplay with international trade agreements. Also, unlike food labelling, product labelling is a matter reserved to the UK Government. As such, any such labelling system would benefit from widespread, international uptake.

This type of activity has been trialled in the UK in the past. In 2007, the Carbon Trust piloted a carbon labelling initiative with a number of retailers with limited success. Other retailers such as Tesco have piloted this but found it too costly. Where other businesses are now using carbon labelling, approaches are inconsistent, meaning it is less useful for consumers.

The recommendation asks for labelling to include the total carbon footprint across the whole lifecycle of a product. For the true carbon impact of a business to be measured effectively, a number of experts are increasingly focussed on the need to include Scope 3 emissions (those that occur in the business’s value chain). This adds a sizeable degree of complexity for many sectors e.g. manufacturing where supply chains can be complex, diverse and multi-national.

At the moment, as with food carbon labelling, this type of labelling is entirely voluntary. The Carbon Trust leads on measuring and labelling products with a variety of labels, such as ‘CO2 Measured’, ‘Reducing CO2’, ‘Carbon Neutral’, and ‘Carbon Neutral Packaging’, to show their sustainability credentials.

Any action against this recommendation will be a long-term goal and will require UK Government and international co-operation. In the short term, we are therefore committing to undertaking a feasibility study to explore implementation options and the benefits and challenges associated with each. The study will also include a benchmarking exercise to understand what similar work has been undertaken elsewhere, and how successful it has been. Stakeholder consultation will again be crucial, including with the British Standards Institute, in particular to discuss the continuity of any scheme.

Photo of Angus Robertson MSP

Cabinet Secretary for the Constitution, External Affairs and Culture, Angus Robertson MSP

“Following on from the inspiring events at COP26 in Glasgow, we must use these recommendations to call on the UK Government to do more on reserved matters. We will therefore press the UK Government to act in order to release Scotland’s full emissions reduction potential."