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Deposit Return Scheme

Is Scotland's Deposit Return Scheme Ready?

On 16th August 2023, Scotland’s Deposit Return Scheme goes live but is the scheme ready yet? Retailers are complaining that they haven’t had enough information, and there are still too many questions that need answers. Stores are concerned about hygiene issues and staff handling dirty containers. They have also voiced their concerns about the way that multipacks will be handled, and how stores should react if drinks purchased in other parts of the UK are returned to stores in Scotland. Some stores are worried that it isn’t clear whether they will qualify for an exemption and how they are supposed to store containers ready for collection.

What we do know:

Zero Waste Scotland’s deposit return scheme claims it will reduce emissions by around 4million tonnes of CO2eq over 25 years and reduce the impact of litter by an estimated £61m annually.

Under the scheme, retailers that sell drinks will have a legal requirement to register as a return point for packaging that is part of the scheme. The scheme includes single use containers made of PET plastic, glass, steel or aluminium between 50 ml (like miniatures) and 3 litres (such as a beer keg).

Twenty pence added to the price for each item will serve as a deposit when the container is returned. People will need to return their containers to reverse vending machines or over the counter. They can obtain cash, a digital or physical token or a discount voucher.

Retailers need to ensure they are familiar with the scheme as they have a legal responsibility:

Retailers need to ensure they are familiar with the scheme as they have a legal responsibility:

  • to accept returns of empty drinks containers for recycling
  • only to sell drinks from registered producers (it is the producer’s responsibility to ensure the consumer is aware the container is part of the scheme)
  • only to sell drinks to consumers in Scotland that a producer has made available for sale in Scotland (these might have a Scotland specific bar code)
  • to charge the 20p deposit when selling a drink that is part of the scheme
  • to make it clear to the customer that the drink is part of the scheme and a deposit applies
  • to clearly display the price of the deposit (20p) in any place that a drink is displayed for sale
  • to display clear information on how the customer can redeem the deposit
  • to operate a return point or takeback service (unless exempt)
  • to store returned empty containers in a safe way, following the Duty of Care code of practice
Bottles for recycling

According to Zero Waste Scotland, 17,000 return points have been set up around Scotland in shops, restaurants, community centres, forecourts and shopping centres. Stores can apply for an exemption on two grounds only; proximity or environmental. Retailers can choose either to install an RVM machine on their premises, or accept returns manually, accepting containers by hand and issuing a cash deposit. Used containers are then stored in bags and collected by the scheme administrator.

The scheme is intended to be cost-neutral to retailers. Retailers will receive a handling fee for taking part in the scheme to compensate them for the costs associated with taking part; for the shop space and staff time required to accept returned drinks containers etc. Costs will be reimbursed to stores on a per container basis, via a handling fee paid by the scheme administrator.

Scheme criticisms

Criticisms of the scheme include those that suggest the scheme will create a trade barrier between Scotland and the rest of the UK which would disadvantage Scottish producers. Others fear that the scheme is too complicated for small producers and that consumers face disruption and higher prices. Some producers worry that the scheme is in danger of failure because of the additional costs involved in the administration of the scheme – and the lack of firm guidelines.

There is currently a Judicial review case lodged by the Belshill retailer and former president of the Scottish Grocers Federation, Abdul Majid, which challenges the legality of retailer handling fees imposed by the scheme's administrator, Circularity Scotland. The case is due to be heard on 30th March 2023.

Environmental pressure mounts for the rest of the UK to follow suit – and some fear that the Scottish scheme will be harder to run if there isn’t a similar scheme set up in the rest of the UK.

Stores in England, Northern Ireland and Wales will surely be following with interest to see how well the scheme is rolled out and how effective it is.

We will update you with answers and further plans for the scheme when information becomes available.

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