[UPDATED] Scottish Government “implored” to reconsider DRS flat fee

The Scottish Government has been “implored” to consider the “hugely negative environmental consequences” of approving its deposit return scheme (DRS) regulations in their current form.

The Aluminium Packaging Recycling Organisation (Alupro) says the Scottish Government has failed to fully consider the potential unintended consequences of DRS regulations in their current form as MSPs meet later this week (29 April) to answer questions and finalise key elements.

Aiming to tackle plastic pollution, increase recycling rates, improve recyclate quality and minimise litter, Scotland’s DRS is expected to come into force in 2022.

The scheme will see a deposit value added to the price of a beverage products in store, which will be refunded to the customer when empty packaging is returned to a designated collection point.

Under the proposed regulations, a flat deposit fee of 20p will be applied to all sizes of container. Alupro says this could see customers charged an additional £4.80 upfront for a 24-can multipack, while only 80 pence for the same volume of drink packed in four large plastic bottles.

We implore the Scottish Government to consider the hugely negative environmental consequences of approving the regulations in their current form…

It says, in this scenario, independent research suggests two thirds of consumers would be likely to opt for larger plastic alternatives, resulting in what it calls the “unnecessary production” of c.82 million additional plastic bottles.

Rick Hindley, executive director at Alupro, commented: “While we are fully supportive of a well-designed DRS, we remain deeply apprehensive about a number of points outlined within the regulations in their current form.

“It is our primary concern that a flat deposit fee will unfairly distort the market and result in a tidal wave of unnecessary plastic bottles – a key issue that the scheme is fundamentally trying to solve.

“What’s more, the majority of consumers buy multipacks, and, at the point of purchase, these will become almost twice as expensive as the equivalent volume in plastic if a DRS is introduced with the same deposit fee.

“This would not only be a significant additional upfront cost for household budgets, but also result in more customers switching to plastic.”

Alupro suggests that the deposit amount should not be specified in the regulations and the scheme administrator should set the variable deposit fee based on the size of container, which it says is “normal practice” in other countries with high performing DRS systems.

“What’s more, we also believe that it would be prudent for the Scottish Government to allow itself greater flexibility and scope to react to the market after the covid-19 pandemic,” Mr Hindley added.

Flat deposit

A number of aluminium and metal bodies have also raised similar concerns regarding the flat deposit fee, including the Metal Packaging Manufacturers Association and the UK Can Makers.

Alupro says the Scottish Government has “failed to consider” the valuable views the packaging industry and is now calling for MSPs to vote against the regulations, as they are currently drafted, at this week’s Environment, Climate Change and Land Reform Committee meeting (29 April).

Mr Hindley added: “It’s a tremendous shame that, despite the ECCLR supporting our call for a variable deposit, and for the scheme administrator to set the deposit, last time they reviewed the proposals, this has seemingly been ignored by the Scottish Government.

“In addition, some of the information the government has used to justify the proposal is both incorrect and misleading.

“We implore the Scottish Government to consider the hugely negative environmental consequences of approving the regulations in their current form and raise these concerns at the Environment, Climate Change and Land Reform Committee meeting later this week.”

Update 30 April

the Environment, Climate Change and Land Reform Committee has voted through Scotland’s proposed introduction of a national deposit return scheme (DRS).

The regulations will now be subject to a vote in the Scottish Parliament, after which the scheme will become law.

In comment, Rick Hindley, executive director at Alupro, said: “While we are obviously disappointed that the scheme has been voted through in its current format, we were hugely encouraged by the clear concerns raised again by the Committee regarding the adverse impact of rolling-out a flat 20p deposit fee.”

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