Undergraduate degrees are completely free for EU students in Scotland, as they are for Scottish students. There is a course fee of about £1800, but SAAS will pay this for both Scottish and EU students if it's your first degree. However, EU students do not get any access to maintenance grants or loans.
If you already have an undergraduate degree, you pay £1800 a year, whether you're Scottish or EU.
Similarly, EU students can study in England, and will get access to the same £9000 a year tuition fee loan that English students do (and repay it under the same '9% over 21k' terms, although, as for English students, this is adjusted to local cost of living if they move abroad after graduating). However, as in Scotland, EU students studying in England will not get any access to maintenance loans.
Source: an EU student about to start in Scotland in a few months.
If you are an English student and this rankles, remember that you can take advantage of any of the fantastic-quality and free tertiary education systems available to you throughout Europe that you choose ...