Is Scotland ready for the deposit return scheme?

24 March, 2023

From 16 August, Scottish hospitality operators will have to pay a 20p deposit for every single-use drinks container consumed on-site. It will form part of the nationwide deposit return scheme (DRS), the first to be implemented in the UK, which aims to see an additional 76,000 tonnes of material recycled each year.

Under the DRS, any container made of PET plastic, steel, glass or aluminium will have to be safely stored on hospitality premises and collected for recycling by the scheme administrators, Circularity Scotland (CSL).

The programme, which is being spearheaded by Scotland's circular economy minister, Lorna Slater, has been designed to capture 90% of registered containers for recycling and aims to cut carbon emissions by four million tonnes of CO2eq emissions over the next 25 years.

However, industry figures have expressed serious concerns that the scheme lacks clarity. Colin Wilkinson, managing director of the Scottish Licensed Trade Association (SLTA), said:

"Among the whole industry, I think most people are of the opinion that the DRS is really not fit for purpose at the moment. There's lots of questions unanswered, there's confusion about how this system's actually going to work, and a lot of people don't even understand the very basics of it."

Registration for producers closed on 28 February, following the announcement on 21 February of a £22m support package to reduce some of the up-front charges.

Hospitality businesses were asked to register from 1 March and, with less than six months to go until the official launch date, they are running out of time to prepare.

David Harris, Chief Executive of Circularity Scotland, the company running Scotland’s Deposit Return Scheme (DRS), told MSPs there is a “great deal to do” before the initiative is due to come into force on 16 August, but insisted the not-for-profit body is “working round the clock to deliver”.

He described the start date as an “immovable object” as he told MSPs on the Net Zero, Energy and Transport Committee that the organisation had initially identified September or October to bring in the scheme – conceding even these had a “degree of risk”.

Harris said:

“At the time when we were appointed as scheme administrator, at that point the deadline for the scheme was July 2022. Within the application to be scheme administrator we made clear we could not deliver that.

Following that we made representations to government around how we saw the scheme going live, we identified the period of September to October 2023 as deliverable, but it contained a degree of risk and did not allow for a great deal of contingency.”

He went on to describe the current start date as being “an immovable object in terms of the date we need to hit”, adding: “We can’t buy extra days but what you will see in the organisation is we are continually applying more resource.”

Harris said he does “not expect” all possible return points for DRS to be “up and running and functioning on August 16”.

New SNP leader Humza Yousaf has promised a grace period for small producers, but Harris warned such a move could see these firms lose out. He said:

“On the grace period for small producers, we really want to help small businesses with the transition to a deposit return scheme operating. Everything you do with deposit return has unforeseen and potentially unpredictable adverse consequences.

“We have to be very careful that small producers, who may be relieved at having a grace period, do not find that they are commercially disadvantaged.

“I think they have to be very careful what they wish for with some of these elements, they may be pleased at not having to address deposit return quickly, but they may find the business from a sales point of view is disadvantaged.”

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