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With less than a year to go until the Deposit Return Scheme goes live in Scotland, what are the key things that drinks producers need to know?
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1. As a producer, how will the Deposit Return Scheme affect me?
The Deposit Return Scheme (DRS) will transform how Scotland recycles. From August 2023, everyone who buys a drink sold in a single-use containers in Scotland between 50ml and 3l will pay a 20p deposit, which they will get back when they return their bottle or can. The scheme will be the most comprehensive of its kind anywhere in the world and will help to collect the billions of drinks containers sold in Scotland each year, reducing littering, increasing the quantity and quality of material collected for recycling and playing a significant role in protecting Scotland’s environment.
This means that everyone who makes or imports drinks that are sold in single-use bottles (glass or plastic) or cans in Scotland is legally obligated to participate in the scheme. As a producer, you are required to charge the 20p deposit on every relevant product you make available for sale in Scotland, as well as arranging for the collection of containers, and paying a handling fee to retailers and return point operators.
2. What is Circularity Scotland’s role?
The DRS regulations allow for the creation of an official scheme administrator, a body that operates to run the scheme on behalf of producers. This means that producers do not have to take on the burden of collecting and recycling the containers within the scheme themselves. Circularity Scotland was set up by industry in 2021 to fulfil this role. It is a not-for-profit commercial organisation that aims to administer DRS in Scotland as efficiently and cost effectively as possible.
We have been working at pace to create the infrastructure to deliver the scheme, securing commercial funding to support the set-up phase of the scheme, appointing Biffa as our logistic partner to collect containers from across Scotland and operate the recycling centres, and recruiting a first-class team with the experience and expertise to deliver an infrastructure project of this scale. We are continuing to work with industry, government and all the relevant authorities to help prepare for the introduction of the scheme from August next year.
3. Do I need to collect all the containers I produce myself?
No – if you choose to appoint Circularity Scotland as your scheme administrator, you will not need to collect bottles and cans yourself. Instead, we will arrange for our logistics partner to collect containers from thousands of return points throughout Scotland – and we will manage the refund of the deposit to retailers and hospitality premises on your behalf. All producers that register with us will pay a Producer Fee per container to cover the cost of administering the scheme, which will be set annually and reflect the prices for the materials collected in the scheme. The better the market for recycled materials, the lower the fee will be.
4. Will I need to change how I package and label products?
The regulations do not require producers to change their labels or the barcodes they use on products. However, introducing a new barcode for sale in Scotland will help the scheme to run more efficiently and cost effectively and ensure that all containers are easily accounted for. To ensure ease of the process, every product will need to carry a barcode which will uniquely identify containers when they are returned.
As a result, the producer fee will be lower for businesses that choose to introduce a new barcode for Scotland. In addition, producers can choose to add a consumer logo to their products – helping to make it clear that containers are within the deposit return scheme and making it simpler for consumers to understand.
5. What do I need to do now?
All producers must register before the 28th February 2023 to be able to sell drinks products in Scotland. Circularity Scotland will do this for you, if you register with and appoint us as your scheme administrator. You can also register directly with SEPA (The Scottish Environmental Protection Agency). Registration with Circularity Scotland for producers opens on the 1st December 2022 and we recommend you register as early as possible.
We know that this will have a significant impact on how drinks producers in Scotland operate and we have provided full information on our website – www.circularityscotland.com – where you can sign up for future updates.
