Chamber and committees

Deposit and Return Scheme for Scotland Amendment Regulations 2022 [draft]

Letter from the Marine Conservation Society on the Deposit and Return Scheme for Scotland Amendment Regulations 2022 draft, 24 January 2022

Dear Members of the Net Zero, Transport and Energy Committee,

To help us move towards a Circular Economy, the Marine Conservation Society has supported the implementation of an all-in Deposit Return Scheme (DRS) in Scotland for almost ten years, including support for the Association for the Protection of Rural Scotland-led Have You Got The Bottle? campaign starting in 2015.

We understand the Committee will shortly be reviewing proposed regulations that will postpone the already delayed implementation date of Scotland’s DRS. After reviewing the proposals and the accompanying evidence, we recommend that members vote down these regulations and request Scottish Government table new ones that include strict fiduciary measures to ensure proposed milestones and implementation date are met and no more taxpayers’ money is wasted. We are concerned that by allowing further delays to DRS it will set a precedent for delays and loosening of requirements regarding future extended producer responsibility interventions needed to achieve a circular economy. In the midst of an intertwined climate emergency and nature crisis, Scotland’s environment cannot afford any further delays.

Every year, our Beachwatch citizen science project has gathered evidence of thousands of drinks bottles and cans strewn on Scotland's beaches, demonstrating why a DRS is urgently needed. We were sufficiently concerned that our Great British Beach Clean 2021 results were released early for the first time in 28 years, highlighting that 92% of surveyed beaches in Scotland had littered drinks-related items (bottles, cans and lids), with one on average recorded every 3m. Scotland’s seas and beaches are bearing the brunt of the delays to DRS.

The Scottish Government have to ensure that Circularity Scotland and the relevant parts of industry have appropriate oversight, governance and motivation to hit milestones and targets. Without strict fiduciary, or even punitive, measures to finally keep DRS on track, we are deeply concerned that it may never be implemented, and we may never see the proven benefits of increased recycling rates, lower carbon emissions and less litter ruining Scotland’s streets, countryside, beaches and seas.

The Marine Conservation Society wants to see DRS in Scotland delivered quickly, efficiently and without further delay as the next step toward a circular economy. To help fight the climate emergency and nature crisis, the DRS is an essential building block, alongside the promised Circular Economy Bill with targets for reuse and repair and other measures, that we need to get on and deliver. Time is running out.

Thank you for your consideration. If you would like any further information, please do not hesitate to contact me.

Yours sincerely,

Calum Duncan

Head of Conservation Scotland

Marine Conservation Society