Duncan Midwood, Chief Executive and Co-founder of DDRS Alliance, explains how a digital system alongside a traditional DRS could help solve the UK’s glass problem.
A UK Deposit Return Scheme (DRS) was first announced by Michael Gove in 2018, with a proposed launch date of August 2023. The launch of a DRS scheme to include PET plastic, metal cans and glass was part of the Conservative manifesto on which they were elected in 2019.
The first of two public consultations was launched in 2019 which showed that 86% of the respondents were in favour of glass being included.
By the time the outcome of the second consultation was published in January 2023, the UK Government had concluded that glass should not be included, citing “the addition of glass will add additional complexity and challenges to delivery of DRS, in particular for the hospitality and retail sectors, as well as additional consumer inconvenience.”
The UK Government’s U-turn on glass inclusion resulted from powerful lobbying from the UK glass industry and a refusal to look at other ways glass could be introduced into the DRS.
Following last year’s General Election, the new Labour Government reaffirmed its intentions to launch the UK DRS in October 2027 without glass, with Scotland and Northern Ireland committing to the same timeline and in-scope materials.
However, the Welsh Government remained committed to including glass as an in-scope material in its scheme.
The impact of EPR ‘indictive fees’
From August 2024, the UK Government issued a series of extended producer responsibility (EPR) ‘indicative fees’ that used packaging weight to scale the packaging charges for the scheme.
As a result, significantly, and some would claim unfairly, loading glass with much higher charges per unit than the lighter materials of aluminium and plastic.
All of a sudden (actually after much analysis, discussion and counter-lobbying), the glass industry started to get their head around the fact that glass in a DRS is far more cost-effective and less likely to distort the market than glass outside a DRS; for example, in the UK EPR scheme.
Essentially the glass industry had made a miscalculation and error of judgement and now faces the challenge of challenging their own logic and argument.
In November 2024, the Welsh Government shook the DRS discussion by issuing a statement that it was not able to continue in the joint UK-wide process and that it would ‘go it alone’ on a DRS for Wales.
This, not surprisingly, created great concern and consternation across the UK drinks industry and is now seen as the biggest threat to a performing and cost-effective UK-wide DRS which is likely to create greater confusion for the UK consumer. I agree!
Where are we now on DRS policy across the UK?
To bring us fully up to date, in January 2025, DRS legislation was passed into law.
As a result, we find ourselves in a situation where we have a three-nation commitment to a DRS, where Northern Ireland is aligned behind England and Scotland, still feeling battered and bruised from the heavy-handed treatment from the UK Government, has capitulated and reluctantly agreed to play to England’s rules.
We have the Welsh Government, the clear UK leader (and second globally) in recycling performance and circularity, working on a ‘DRS+’ that will be future-proofed and deliver much greater performance than a 1984-designed DRS preferred by the UK Government.
We also have a glass industry that is facing an existential challenge and is struggling to find a way to re-argue the very opposite position to that they so vigorously argued previously. What a mess!
How on Earth can we find an elegant DRS solution for the UK in light of all this? We only have to look West to see how simple Ireland have made it. While not perfectly, at least they got on with it (though, it must be said, without glass)!
Facts about the inclusion of glass in a DRS
Below are some facts:
Firstly, 86% of respondents in the 2019 UK-wide consultation expressed the view that glass should be included in a UK DRS.
Secondly, in order for glass to be collected via a conventional DRS (using reverse vending machines (RVMs) as the primary collection vehicle), separate modules of an RVM, or completely separate machines, need to be provided at a significant incremental cost.
Glass has to be collected separately from PET plastic and metal cans (which can be co-mingled) in order to achieve acceptable recycling rates.
Thirdly, 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 effectively! 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 in order to be counted and the retailer reimbursed. All clear so far?
Fourthly, the breakage of glass in a retail environment means that additional measures must be put in place to ensure safe handling and noise containment.
Fifthly, certain retailers, such as fast food restaurants, are not able to take glass back in their stores (for health & safety reasons) and so would be seeking exemption from a universal return-to-retail model.
Finally, returning glass drink bottles to retail in an RVM-based 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 may well have the impact of significantly reducing the amount of glass that is actually recycled across the UK. DDRS Alliance believes that all glass should be collected via a single point of collection, such as kerbside
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. We agree!
DDRS Alliance believes strongly that glass, and indeed other mainstream drink packaging formats, such as paper-based cartons, should be 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 additional cost, complexity and inconvenience to consumers and hospitality, and is likely to actually reduce 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 a good idea and it would be counter-productive in delivering the environmental benefits of a DRS.
DDRS Alliance recommends a solution that enables glass to be included in a UK-wide DRS without requiring glass containers to be returned to retail, which would avoid any potential market distortion in the UK due to some packaging formats being in and some out of scope.
In essence, DDRS Alliance proposes a common (UK-wide) DRS solution featuring an RVM (conventional) DRS system for plastic bottles and aluminium cans and a digital solution for glass bottles.
In summary, the DDRS Alliance solution would deliver:
- A UK-wide, single DRS solution that aligns all 4 UK nations and can be delivered within, or close to, the timescales set by the UK Government;
- A DRS solution for glass that utilises existing kerbside collections;
- A solution where specified regions or nations can choose to have glass returns activated or not – without complexities at producer-level;
- A solution that enables Wales to continue their journey to establish a reuse framework while delivering a solution to support the rest of the UK deliver needed recycling improvements.
How it would work
Digital DRS requires all containers in the programme to be serialised, so each container should carry 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 now being driven by retailers and GS1 to replace conventional barcodes with 2-D codes targeting a 2027 roll-out.
The DDRS Alliance solution would therefore require that all glass products that are in scope would be mandated to carry the unique QR code for all UK products (that are not exempted).
This would be delivered through a range of technology solutions (which are fully proven 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.
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 so 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 liked it, retailers agreed that it was simple to operate and it demonstrated how an incentive can be provided to boost the existing kerbside collection process.
As a key next step, industry and all UK governments need to work together on scoping out how the glass drinks industry can implement UK-wide serialisation on their products, which products would be exempted and how the Digital DRS solution could be implemented. DDRS Alliance, as the only not-for-profit body focused on Digital DRS, is ready to provide leadership and support.
DDRS Alliance is currently scoping a major pilot demonstrating how effective a Digital DRS solution would work with glass bottles.
It is all about willingness, ambition and focus on the bigger picture – putting the environment and public opinion above internal commercial expedience. As glass ceilings go, this one is ready to be shattered!
