This finding does not however preclude future use of primary law as a mechanism for fulfilling the SG commitment to align. Indeed, at least one of the Bills currently before the Scottish Parliament – the Circular Economy (Scotland) Bill – is intended to “maintain alignment with the direction of EU policy” by enabling Ministers in Scotland to set 23 statutory circular economy targets by regulation (see Circular Economy (Scotland) Bill and its 20 See United Nations Convention on the Rights of the Child (Incorporation) (Scotland) Bill: Policy Memorandum (2020) para. 5 Available: https://www.parliament.scot/-/media/files/legislation/bills/s5-bills/united-nations-convention-on-the-rights-of-the-child-incorporation-scotland- bill/introduced/policy-memorandum-united-nations-convention-on-the-rights-of-the-child-scotland-bill.pdf (Accessed 12 January 2024) 21 See Patient Safety Commissioner for Scotland Bill: Explanatory Notes (2022) para. 96 Available: https://www.parliament.scot/- /media/files/legislation/bills/s6-bills/patient-safety-commissioner-for-scotland-bill/introduced/explanatory-notes-accessible.pdf (Accessed 12 January 2024) 22 Examples include: Regulation (EU) 2017/745 on medical devices; Regulation (EU) 2017/746 on in vitro diagnostic medical devices; and Regulation (EU) No 1901/2006 on medicinal products for paediatric use; Directive 2001/83/EC on the Community code relating to medicinal products for human use. 23 Circular Economy (Scotland) Bill [AS INTRODUCED] 2023, June 13 parliament.scot Available: https://www.parliament.scot/- /media/files/legislation/bills/s6-bills/circular-economy-scotland-bill/introduced/bill-as-introduced.pdf (Accessed 10 September 2023): section 6(3).