New guidance on the implementation of the Deposit Return Scheme (DRS) has published by the Scottish Government.
Scotland’s Deposit Return Scheme is set to go live on 16 August 2023, following several delays, and cover PET plastic, aluminium, steel and glass.
The Scottish government aims to achieve a 90% collection rate for materials in scope by 2025.
The guidance makes the process of applying for an exemption from DRS regulations much less complex and offers up several new features to support retailers.
These include:
- A new Return Point Mapping & Exemption Support service to help retailers identify an alternative return point, and to remove the requirement to share commercially sensitive information with other retailers.
- Confirmation that the Scottish Government will take the size of a premises into account in determining the risk of breaching obligations relating to environmental health. A retailer is likely to be approved for an environmental health exemption if the footprint of their premises is 100m2 or less, or if they are a food-to-go retailer and the footprint of their premises is 280m2 or less.
- Streamlined evidence and assessment processes that better take into account the challenges facing specialist, food service, and hospitality retailers. This should also speed up the decision making process for Scottish Ministers, and provide clarity to retailers on the outcome of their application.
The guidance has been welcomed by Association of Convenience Stores chief executive James Lowman.
“This is a welcome step forward towards a workable Deposit Return Scheme in Scotland,” he said. “We will work with our members to help them consider whether to seek an exemption or to make their store a return point. This will be a site-by-site decision and this new guidance makes it more likely that the right shops will act as return points in the scheme.
“The UK, Welsh and Northern Ireland governments should note the challenges that Scotland is experiencing in using an exemptions system to define a workable and economically viable network of return points. We need solutions now on how to map the right network of return points to meet our common objective of an effective Deposit Return Scheme operating throughout the UK.”
David Harris, chief executive of Circularity Scotland which will be running the scheme, said: “We warmly welcome this significant intervention from the Scottish Government. We have been working closely with the Minister and her team, as well as Zero Waste Scotland, to agree an approach and this new guidance will help industry to establish an accessible and inclusive network of return points across Scotland in the most effective and cost-efficient way.
“We also welcome the Minister’s indication that she is considering industry’s concerns around online takeback and her commitment to provide further detail on this in the coming weeks.
“With just under a year to go until DRS is introduced, these developments are just one element of how we are actively working with industry, government and all stakeholders to deliver a scheme that will work for Scotland, will transform how we recycle in this country and will help preserve our environment for generations to come.”
Circularity Scotland has also confirmed that it will be able to assist retailers in applying for exemptions, helping to establish shared return points and prevent return point ‘blackspots’. It is hoped that these changes will reduce the overall cost of the scheme and allow Circularity Scotland to recalculate its initial forecast producer fee – the cost per container that each producer is required to pay to meet their obligations under the scheme. CSL will be providing further information to producers on this in the coming weeks.
The fees have caused consternation amongst some retailers, with one store owner raising judicial proceedings as he feels they will adversely impact his business.
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