Scotland being part of a UK-wide deposit return scheme (DRS) would be “beneficial”, according to the respondents of the Scottish Government’s consultation into how a DRS could be implemented in the country.
The Scottish Government last year undertook a public consultation to explore options for establishing a deposit return scheme (DRS) in Scotland.
The consultation paper, A Deposit Return Scheme for Scotland, discussed the key features of a scheme and set out different options for its operation – without putting forward a preferred option.
The Scottish Government has now published an analysis based on the 3,215 responses. These comprised responses from 159 organisations, 2,008 individuals and 1,048 postcard campaign respondents submitted by supporters of the Have You Got The Bottle (HYGTB) campaign.
Respondents saw the benefits of UK-wide DRS system in terms of cost efficiency, consistency and fraud prevention.
A majority of both organisations and individuals thought that being part of a UK-wide DRS system would be beneficial, according to the published summary of results. Organisations were almost unanimous in this view.
However, there was no clear consensus among respondents about whether having a “compatible but separate system” across the UK would have the same effect as a single system – although organisations were more likely than individuals to say that it would not, the Scottish Government says.
Respondents saw the benefits of UK-wide DRS system in terms of cost efficiency, consistency and fraud prevention.
Some individuals (but no organisations) saw risks in being part of a UK-wide (or even a UK-compatible) system. These were in relation to delays in introducing the scheme; possible ‘watering down’ of the system in Scotland; and loss of control over key aspects of the scheme.
Widespread agreement
There was widespread agreement amongst both organisational and individual respondents that a well-run and appropriately targeted DRS could provide opportunities in relation to improving the environment, changing people’s attitudes to recycling and littering, and building the circular economy.
Three particular themes were raised repeatedly – by both individuals and organisations – in relation to a wide range of consultation questions.
- Deposit return in Scotland should not be seen in isolation. Rather, it should be part of a (preferably, UK-wide) comprehensive approach to waste management, recycling and reuse.
- Deposit return in Scotland should be (i) ‘easy to use’ for consumers and other key stakeholders (ie, producers, retailers, manufacturers, etc.), (ii) ‘accessible’ and ‘convenient’ for consumers (including those with disabilities, those without private transport, and those living in rural areas), and (iii) it should be ‘simple in design’, so that people can understand it and use it appropriately.
- The scheme should be evidence-based. Respondents thought there was a need for more (and more detailed) impact analysis and cost-benefit analysis, and they called for lessons to be learned from schemes elsewhere.
“On the go”
The consultation paper considered the types of products that should be included in the DRS and the option of an “on the go” scheme, as seen in Defra’s recent consultation on DRS.
The overall balance of opinion was strongly opposed to a scheme limited to “on the go” products, according to the Scottish Government.
Those in favour of an on the go scheme thought that this would address the main source of litter, be more acceptable and less confusing for consumers and businesses – and avoid duplicating existing kerbside collections.
Those opposed to an on the go scheme highlighted difficulties in defining ‘on the go’; the potential impact on efficiency and cost-effectiveness because of the lower volumes involved; the risk of consumer confusion; and the possibility of market distortion.
Logistics
Respondents were asked for their views on various aspects of the infrastructure and logistics relating to the operation of a DRS. Specific questions focused on the type of take-back system used and the way in which retailer handling fees should be calculated.
In terms of return method, a large majority of both organisations and individuals favoured using a combination of manual take-back and reverse vending machines.
The overall balance of opinion was strongly opposed to a scheme limited to “on the go” products, according to the Scottish Government.
Regarding the retailer handling fee, there were four main suggestions: no handling fee should be paid; costs incurred through collecting and recycling containers should be reimbursed in full; a flat fee for participation in the scheme should be paid; a variable fee should be paid depending on the number and volume of containers collected, the value / quality of the recyclate, and time required to process returns.
There was very little support among respondents for a scheme that involved solely a return to a designated drop-off point. Respondents wanted the scheme to allow either for a model based on take-back to a place that sells drinks, or a mixture of take-back and designated drop-off.
Exemptions
Organisations – particularly those in the retail sector – were more likely to say that there should be exemptions. Respondents identified four groups for possible exemptions: ‘small’ retailers (including ‘corner shops’, ‘small convenience stores’, kiosks, food stands, etc; retailers who did not sell food and drink; some retailers who sell ‘food to go’; and hospitality premises which sell items covered by the DRS for consumption on the premises.
There was a widespread view (among individuals and organisations) that online retailers should be included in a DRS scheme. Those in favour thought there should be a ‘level playing field’ for online and high street retailers.
Those opposed thought that it was unrealistic or impractical for consumers to return empty containers to an online retailer, and that such an arrangement would introduce hygiene and food safety risks (because of the need to use the same vehicles to deliver fresh food and collect empty containers).
Producer responsibility
The consultation paper discussed how a DRS might be financed. Four main scheme costs were identified – refunding deposits; providing return points and issuing handling fees; logistics; and infrastructure and staffing associated with the scheme administrator.
In addition, three income streams were identified: sale of collected materials (if owned by the scheme); producer fees; and unredeemed deposits. The consultation paper invited views on various issues and options related to these costs and income streams.
There was widespread agreement (both among organisations and individuals) that deposit return should be seen as a form of ‘producer responsibility’. However, organisations emphasised the importance of ensuring that this was considered in a ‘holistic way’, alongside other producer responsibility requirements.
Cost and ownership
More than half of all respondents suggested deposit levels of between 15p and 20p. Respondents argued that the deposit level needs to balance the financial impact on consumers, the financial and administrative impacts on retailers and manufacturers and the need to incentivise participation in the scheme.
There was no clear consensus on the best model for system ownership, the Scottish Government says. Public ownership was the most popular option selected by just under half of respondents.
Respondents thought that this model would allow wider environmental and community benefits to be prioritised, ensure transparency, accountability and good governance, and encourage scheme support and ‘ownership’ among members of the public.
However, organisations were more likely to favour an industry-operated not-for-profit model.
