Duncan Midwood, Chief Executive & Co-Founder of DDRS Alliance, explores the debate around whether to include glass in the UK’s deposit return scheme.
A Deposit Return Scheme (DRS) for the UK was first announced by Michael Gove in 2018, with a proposed launch date of August 2023. The first of two public consultations was launched in 2019 which showed that 86% of the respondents were in favour of glass being included.
The launch of a DRS scheme to include PET plastic, metal cans and glass was part of the Conservative manifesto, on which they were subsequently voted into power, later in 2019.
In 2021, a second consultation was launched in which an economic assessment showed that including glass had a 35% higher net present value (NPV) compared to excluding glass.
By the time the response to this second consultation was published in January 2023, the UK government had concluded that glass should not be included, citing that “the addition of glass will add additional complexity and challenges to the delivery of DRS, in particular for the hospitality and retail sectors, as well as additional consumer inconvenience.”
Scotland and Wales’ DRS objectives
However, the Scottish and Welsh governments remained committed to including glass in their DRS proposals.
I believe that the UK government’s change of direction on glass resulted from powerful lobbying from the glass industry and a refusal to look at other ways glass could be introduced into the DRS.
The launch date of a UK DRS has been pushed back three times and recently the four UK governments issued a joint policy statement stating a planned launch date of October 2027. Will this be the last time it is delayed?
The Scottish government first announced plans to launch a Scotland-only DRS in April 2021; however, this was delayed until July 2022 due to COVID-19 and then again until 2023.
Against a backdrop of significant industry opposition, the Scottish government pushed forward with their plans, deferring the launch to 2024.
However, only a matter of months before the proposed launch of the Scottish DRS, the UK government, in effect, refused to permit Scotland to implement a DRS as they claimed it breached the UK Internal Market Act 2020.
After discussions and negotiation, the UK government stated that it would permit the Scottish government to implement its DRS on the condition that glass was removed from scope (to align with the desired position of England and Northern Ireland).
This was deemed unacceptable by the Scottish government and it decided to defer the launch of a Scottish DRS to align with the rest of the UK – at that time, October 2025.
Since then, the Scottish government has capitulated and agreed to remove glass from scope.
However, the Welsh government said it believes that including glass in its DRS scope is critical to achieving its environmental ambitions.
The latest launch “commitment” from the UK government has now been set at October 2027 – essentially 6 and a half years after Scotland first planned to launch and five launch date deferrals later!
As a result, we find ourselves in a situation where the scope of materials in a UK-wide DRS is not aligned across the four nations – England and Northern Ireland wish to exclude glass, Scotland has reluctantly conceded defeat and Wales is standing strong in insisting glass should be in a DRS.
This is raising strong concerns from many DRS stakeholders of future fall-outs and delays – the UK government has stated its intention to use the UK Internal Market Act to force Wales to change its position on glass, as it did with the Scottish government.
Facts about the inclusion of glass in a DRS
Below are some facts – the rest is opinion (data-based or otherwise!).
- 86% of respondents to the 2019 UK-wide consultation expressed the view that glass should be included in a UK DRS.
- For glass to be collected in a conventional DRS (using reverse vending machines, or RVMs as the primary collection vehicle), separate modules of an RVM, or completely separate machines, need to be provided at significant incremental cost.
- Glass has to be collected separately from PET plastic and metal cans (which can be co-mingled).
- Glass bottles collected through RVMs must be broken to avoid potential fraud, but not into small pieces, as small pieces of glass cannot be sorted and recycled.
- This means whether it’s a small 150ml glass bottle or a large spirit bottle, all must be broken into “4, 5, or 6 separate parts”. For manual take-back, the reverse is true – the bottles must be kept whole to be counted and the retailer reimbursed.
- The breakage of glass in a retail environment means that additional measures must be put in place to ensure safe handling and reduce noise.
- Certain retailers, such as fast food restaurants, are not able to take glass back in their stores and would likely seek an exemption from a universal return-to-retail model.
- Returning glass drink bottles to retail in a DRS would mean that a much smaller fraction of glass would be left in kerbside returns (such as jam jars and non-drink bottles), reducing the effectiveness and viability of separate glass collections at kerbside (in fact some local authorities in Scotland, in anticipation of the DRS being launched, announced they would cease collecting glass separately at kerbside). This might have the impact of significantly reducing the amount of glass that is recycled across the UK.
How to break the glass ceiling
Most environmentalists agree that glass, being a mainstream drink packaging material which is readily recyclable, should feature in any DRS. After all, a DRS is, at its core, an incentivised solution to encourage the public to return drink containers for recycling.
DDRS Alliance believes strongly that glass, and indeed other mainstream drink packaging formats, such as paper-based cartons, should be ultimately included in a UK DRS, even if not from day one.
Unfortunately, as discussed above, including glass within a conventional return-to-retail DRS model (utilising RVM’s as the primary return mechanism) incurs significant cost, complexity and inconvenience to consumers and potentially reduces the amount of glass that is effectively recycled.
So DDRS Alliance also believes that force-fitting glass into a pure RVM-based DRS is not desirable and would be counter-productive in delivering the benefits of a DRS.
That’s why DDRS Alliance recommends a solution that enables glass to be included in a UK-wide DRS, but without requiring glass containers to be returned to retailers and that avoids any potential market distortion in the UK due to some packaging formats being in and some out of a DRS.
In summary, the DDRS Alliance solution delivers:
- A DRS solution for glass that utilises existing kerbside collections.
- A solution that is common across the whole UK drinks industry for glass containers.
- A solution where specified regions or nations can switch on a deposit return mechanism without impacting those that choose not to.
- A solution that can sit alongside an RVM-based model for other materials.
How it would work
Digital DRS depends upon all containers in the programme to be serialised – that is, carrying a unique identifier (or code). This is likely to be a QR code which could also replace the current product barcode and would provide much richer information to the brand, producer, retailer and consumer of the product.
This is consistent with a major programme being driven by GS1 to replace conventional barcodes with 2-D codes and could easily sit alongside this change in retail
For glass to be included in a DRS, it would require all in-scope products to have a unique code. In my view, this means that this requirement would have to be mandated (by legislation or by an industry agreement).
This would be delivered through a range of technology solutions (which exist today) and a review of exempted products (such as some imported products and those from micro-producers).
With all in-scope glass drink products carrying the unique code, those retailers who are located within a region that is operating the glass DRS scheme, for example, Wales, would charge a deposit, and those who aren’t, wouldn’t, and the drinks sold in a DRS zone would be able to be returned for the deposit redemption, and those that are not within the zone would not have active codes and would not be able to be returned for any reward.
This way, producers manufacture to one UK-wide specification, there would be no cross-border fraud, and the active DRS zones are controlled via the unique coding by the deposit management organisation or their agent.
Next steps
The principle of kerbside-only returns running alongside retail returns for other materials has been demonstrated successfully in the DDRS Alliance’s trial in Brecon, Powys in 2023.
Consumers understood how it worked and the trial demonstrated how an incentive can be provided to boost the existing kerbside collection process.
As a key next step, industry and government need to work together on scoping out how the glass drinks industry can implement UK-wide serialisation on their products, which products may be exempted, and how a Digital DRS solution could be implemented.
DDRS Alliance, as the only not-for-profit body representing leading organisations purely to develop and deliver a Digital DRS, is ready to provide leadership and support.
It is all about willingness, ambition and focus on the bigger picture – putting the environment and public opinion above internal commercial expedience.
Do you want to learn more about the biggest innovations in resource management? Explore upcoming CIWM webinars and develop your professional knowledge. CIWM members have exclusive free access to all its webinars.
