Below are a number of questions that have been asked about the operation of the Deposit Return Scheme in Scotland. If you have any questions about DRS that aren't covered in our guide or below, get in touch with us by emailing [email protected]
DRS will go-live in Scotland no sooner than October 2025.
Reverse Vending Machines and Manual Handling
Q: Does the machine have to be inside the store? Can it be outside?
A: They can be outside, they’re exempt from business rates and there are permitted development rights for them to be outside the store.
Q: What does the Government anticipate will be the percentage of returns?
A: The target is for 70% of the containers to be returned in the first year, then 80% in 2024 and 90% thereafter.
Q: Have either Government specified what the consumer education on DRS is likely to be?
A: Circularity Scotland have a responsibility for communicating how DRS will operate, and they’re planning to start the communications programme on this with an allocated budget from June. Realistically there will be an expectation for retailers to explain the process to customers in stores.
Q: Is there enough resource available for anyone who wants a reverse vending machine to have one?
A: There are lots of different RVM operators talking to retailers at the moment, but it’s unlikely that there’ll be 100% implementation and installation of RVMs on day one because of how busy everyone is expected to be.
Q: How will deliveries that include containers in scope through partners like Uber Eats and Deliveroo be affected?
A: The expectation of the scheme is that if a container is delivered online, it is collected in some way. There is a requirement for large retailers to enable returns of products delivered, but it’s likely that the majority of returns will end up being done in store.
Q: How confident are we that EPOS integration is going to work and will there be costs involved?
A: The EPOS integration elements have been published, and feedback so far is that the IT infrastructure should have been happening 18 months ago so it is a challenge but the information is now avaialble so work should be ongoing on getting integration sorted ahead of the implementation date.
Q: How does the accountancy process work for retailers when it comes to the 20p deposits?
A: Retailers purchase product that has a deposit on it, which is then refunded through returned containers either after seven days with manual returns or up to 30 days through reverse vending operations.
Q: Who is going to police and regulate the scheme in Scotland?
A: SEPA are the agency that are overseeing the enforcement of the Deposit Return Scheme in Scotland. There are fines set out in the regulations, which are set at up to £10,000
Q: If the target is for 80% of containers to be returned in the first year, what happens to the 20% of containers that don’t get reclaimed (unredeemed deposits)
A: The unredeemed deposits go back into the system to fund its operation.
Q: From a producer’s point of view, the 20p is put on at the start of the supply chain. Where does the 20p get dealt with at the start? We’re putting 20p cost onto every bottle we sell into wholesale, but we’re separately paying a producer fee.
A: The entirety of the 20p has to be returned to the scheme, in addition to any associated producer fees.
Exemptions
Q: Have any applications for exemptions been refused or denied yet?
A: Only those applications that are approved have been published to date.
Q: How long does the process take to get an exemption decision?
A: Zero Waste Scotland estimate that a decision will be made on an application within 35 days.
Q: Is there a cut off date for the exemption application date 35 days before the implementation date of 16th August?
A: To be confirmed - check back for more information.
Rest of the UK
Q: What lessons can we learn from the appointment of the Deposit Management Organisation (DMO) in Scotland?
A: Getting the infrastructure set up quickly is going to be important, and we have the opportunity to learn from operations in Scotland and in Europe. ACS is working with the Government on the role of the DMO.
Q: What happens if someone buys a container outside of Scotland and takes it back to Scotland?
A: It will depend if that container has a unique SKU / barcode in Scotland. If it doesn't have a barcode that is recognised through the scheme, it shouldn't be accepted.
Q: What about when a scheme is in place in England and Wales? Can containers be returned everywhere?
A: The ambition is that you will be able to purchase and return containers in any part of the UK, and the DMOs will work together to ensure that the deposit monies are allocated to the right scheme.
Q: What happens with voucher redemptions? Can they be redeemable at chains or just individual stores?
A: To be confirmed - check back for more information
