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Participation of small producers is vital to the success of the scheme and we believe we have taken their needs into consideration in designing DRS.

We have consulted extensively with businesses of all sizes that will be affected by the implementation of Scotland’s Deposit Return Scheme. We are not aware that any producers have decided to cease doing business in Scotland, although we are aware that some have expressed concerns about whether they will continue to sell their products in Scotland.

This is one of the reasons why we have applied a de minimis for the SEPA registration fee. This will remove a cost for businesses operating below the current VAT threshold, benefiting around 1,600 of the more than 4,000 anticipated producers selling into the Scottish market

We are analysing the text of the Act to understand how it could interact with Scotland’s Deposit Return Scheme (DRS), but in order to assess impact fully we need to understand the UK Government’s intentions for its own DRS. We have not yet seen their response to their recent consultation.

Since July 2021 SEPA has advised that the same vehicle that is used for delivery can be used for the backhaul of scheme packaging provided that:

• the haulier is a registered waste carrier ;
• where backhaul is carried out in a vehicle used to transport fresh food, there is sufficient separation and a barrier to prevent contamination of waste materials with organic matter.

This advice was published as part of a series of DRS Frequently Asked Questions on SEPA’s website on 8 March 2022.

The figure is based on Circularity Scotland Ltd’s assessment of its expected annual turnover as scheme administrator once it is in steady state.

We anticipate that implementation and operation of DRS will generate a range of business and employment opportunities in the extensive infrastructure and logistics required for the scheme, for example in the construction and operating of sorting and bulking centres.

The number of Reverse Vending Machines (RVMs) that will be used in Scotland’s Deposit Return Scheme (DRS), was estimated at 3,021. This information can be found in Table 2 on page 19 of the revised Business and Regulatory Impact Assessment (BRIA).

The BRIA also indicates that the cost of an RVM could vary from around £19,000 to £25,000 for smaller models, and around £30,000 for a larger machine.

The costs associated with operating of Return Points, including RVMs can be found in Table 1 on page 5 of the Full Business Case Addendum .

The identification and acquisition of DRS-compatible RVMs is a matter for the Scheme Administrator, Circularity Scotland Ltd, and retailers to manage. This is consistent with the industry-led approach to DRS.

As a private business, the remuneration of Circularity Scotland Ltd staff is not shared with the Scottish Government, nor is it subject to Ministerial approval.

The number of reverse vending machines (RVMs) was based on analysis of data that identified retail locations in Scotland, the store type and the sales area. This estimated that there would be approximately 3,021 automatic return points using RVMs and 14,386 manual return points.

The decision on whether to install a RVM will be for individual retailers to make.

There is a duty in the Waste (Scotland) Regulations 2012 for local authorities to provide a collection for glass. The Deposit Return Scheme (DRS) is for single-use drinks containers; local authorities will continue to collect all other glass not captured by DRS.

The Scottish Government does not hold figures relating to the proportion of glass recyclate for non-scheme articles. However, including glass in DRS will bring significant environmental and economic benefits. The inclusion of glass will save over 1.2 megatonnes CO2 equivalent over 25 years and will also reduce the amount of harmful glass litter in our environment. In addition, DRS will significantly increase the quantity and quality of glass recyclate, creating an aggregated and high-quality feedstock for reprocessing. This will include clear glass, which we understand to be in high demand.

Return Point operators are responsible for ensuring that the Reverse Vending Machines (RVM) that they use meet the specifications supplied by the Scheme Administrator, Circularity Scotland Ltd (CSL).

The costs of operating a Return Point, including the RVM, is offset by the Retail Handling Fee paid by CSL to Return Point operators per in-scope container they process.

As stated in the Final Business Regulatory Impact Assessment, it is anticipated that floor space implications associated with the installation of Reverse Vending Machines (RVM) are likely to be modest. Generally, it is expected that high-volume retailers will choose to introduce RVMs as they will be able to process returns with greater efficiency, while low-volume retailers will choose to operate manual collection and return, as the costs and space requirements of an RVM may be prohibitive.

Whichever method is adopted, retailers will be able to charge a handling fee from the scheme administrator to fully compensate them for the costs involved in the collection, checking and storage of used containers.