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Scotland’s retailers support a well-designed deposit return scheme as an opportunity to improve recycling and encourage consumers towards a circular economy.

Our Members are hard at work delivering the infrastructure to make the scheme work. They will invest over £200 million this year in reverse vending machines and store refits to accommodate the return point systems. They have had project teams in place for over a year working on delivering an immensely complex scheme. Hundreds of people are already hard at work turning the concept of DRS into a reality.

Nonetheless, we are very concerned the Scottish model will not deliver the desired objectives. Instead, a mixture of mistaken design and operational issues mean there is an increasing risk this will land in a manner which will be costly, confusing, and complex for consumers. We have publicly raised our concerns on this here: https://brc.org.uk/news/2023/src-last-chance-saloon-if-scotland-s-drs-is-to-launch-well-in-august/

If that is the case it will leave our customers poorer, less likely to engage positively with the scheme, and puts the wider environmental objectives we want to see delivered at risk.

We do not believe this has to be the case. However, if the scheme is to be launched successfully on August 16th, 2023, we believe the following steps are required:

  • Urgently deliver an operational blueprint to allow retailers to implement the scheme
    • Recent weeks have seen some good progress on providing clarity on the key issues, such as the rules on VAT and Non-Domestic Rates Exemptions for Reverse Vending Machines.
    • However, key issues including the price shown to customers, the guidance on the collection system, and guidance on items which cannot be taken back in a RVM are still outstanding. 
    • If this cannot be completed by the end of February it will be impossible for retailers to guarantee the scheme can be delivered clearly and consistently to consumers in August.
  • Remove retailers from the requirement to provide online takeback
    • The SRC has opposed making retailers provide an online takeback model since 2017 on the grounds it is environmentally and economically unaffordable.
    • The Scottish Government acknowledged this in December but is yet to publish regulations.
    • At this late-stage retailers cannot deliver any form of takeback model, even for a limited customer base.  If this requirement is not removed many retailers will have to consider whether it is viable to continue serving all online customers in the manner they currently do.
  • Allow small stores to opt-in to the scheme
    • The current exemption model is unwieldy and bureaucratic and seems unlikely to allow small format and food to go retailers to be exempted from the scheme.
    • Allowing shops under 280 sq. m. to opt out would allow the scheme to be optimised around a smaller number of stores which will reduce cost and complexity; whilst allowing those who want to be part of DRS to remain in the scheme.

I’m aware this is just a short summary of the key issues, if you’d like any more detail then please don’t hesitate to contact Ewan MacDonald-Russell