- Asked by: Fergus Ewing, MSP for Inverness and Nairn, Scottish National Party
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Date lodged: Monday, 14 March 2022
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Current Status:
Answered by Lorna Slater on 29 March 2022
To ask the Scottish Government, regarding its proposed Deposit Return Scheme, whether it will publish all (a) correspondence, (b) communication and (c) other documents between it and Circularity Scotland related to any conflict of opinion on the (i) detail of estimates of the number of (A) items to be recycled, (B) return locations and (C) Reverse Vending Machines required, and (ii) consideration of the wording and content of Annex F of the Deposit Return Scheme for Scotland Final Business and Regulatory Impact Assessment (BRIA), published in December 2021.
Answer
The position taken by Circularity Scotland Ltd (CSL) in respect of container and return point numbers, as I understand it, is set out at Annex F of the amended Business and Regulatory Impact Assessment (BRIA) for our Deposit Return Scheme (DRS) published in December 2021.
CSL’s position in respect of number of reverse vending machines is that they expect roughly 3,000 of these as set out in the Full Business Case for DRS.
CSL had no sight of the content of the amended BRIA in advance of publication.
- Asked by: Fergus Ewing, MSP for Inverness and Nairn, Scottish National Party
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Date lodged: Monday, 14 March 2022
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Current Status:
Answered by Lorna Slater on 29 March 2022
To ask the Scottish Government, regarding its proposed Deposit Return Scheme, what its position is on (a) the estimates by Circularity Scotland that (i) 2.7 billion items would require to be recycled, (ii) 37,000 return points are needed and (iii) 6,000 Reverse Vending Machines are required and (b) whether its conclusion, as set out in Annex F, paragraph 5, page 152 of the Deposit Return Scheme for Scotland Final Business and Regulatory Impact Assessment (BRIA), published in December 2021, stating that “We remain committed to the assumptions set out in Table 3 as our final and best, estimate of the costs and benefits” remains valid, and what information it has on the position of Circularity Scotland regarding the figures used by the Scottish Government in Table 2 on page 19 of the Deposit Return Scheme for Scotland Final Business and Regulatory Impact Assessment (BRIA), published in December 2021.
Answer
As set out in Annex F to the amended Business and Regulatory Impact Assessment (BRIA) for our Deposit Return Scheme (DRS), published on 15 December 2021, we consider that there is a degree of uncertainty attached to the figures proposed by Circularity Scotland Ltd (CSL) for the number of scheme articles and return points under DRS. For that reason our final and best estimate remains that set out on p19 of the amended BRIA.
Nevertheless, as Annex F shows, even if we were to adopt these two figures there would continue to be a strong economic case for DRS.
We have seen no evidence for higher numbers of RVMs than the roughly 3,000 assumed in the Full Business Case Addendum and I understand that CSL is continuing to work from this figure. That is therefore the figure modelled in the updated Final BRIA that was published in December last year.
- Asked by: Fergus Ewing, MSP for Inverness and Nairn, Scottish National Party
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Date lodged: Monday, 14 March 2022
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Current Status:
Answered by Lorna Slater on 29 March 2022
To ask the Scottish Government, in relation to A Deposit Return Scheme for Scotland: Full Business and Regulatory Impact, published in July 2019, whether it will provide full details of the evidence base it used for its estimates for the number of (a) items in scope, which was estimated at 1.7 billion containers and (b) return points which was estimated at 14,386 manual and 3,021 automatic; whether these estimates were based on a consultants report, and, if so, whether it will publish that report and details of the evidence base used for that report.
Answer
The information presented in the version of the Business and Regulatory Impact Assessment (BRIA) published in July 2019 has been superseded.
Please refer to the amended Final BRIA published in December 2021 which can be accessed here: https://www.gov.scot/publications/deposit-return-scheme-scotland-final-business-regulatory-impact-assessment/ .
- Asked by: Fergus Ewing, MSP for Inverness and Nairn, Scottish National Party
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Date lodged: Monday, 14 March 2022
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Current Status:
Answered by Lorna Slater on 29 March 2022
To ask the Scottish Government whether, during the policy development period and leading up to the publication of the Deposit Return Scheme for Scotland Final Business and Regulatory Impact Assessment (BRIA), published in December 2021, the proposed Deposit Return Scheme was referred for consideration to the Scottish Government Regulatory Review Group, and if this is not the case, what the reasons are for its position on this matter.
Answer
The centralised BRIA quality assurance services provided by the Better Regulation team has ceased, their last meeting was in February 2018.
- Asked by: Fergus Ewing, MSP for Inverness and Nairn, Scottish National Party
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Date lodged: Monday, 14 March 2022
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Current Status:
Answered by Lorna Slater on 29 March 2022
To ask the Scottish Government whether Audit Scotland has been consulted on (a) any potential risks of the Scottish Government's approach to the proposed Deposit Return Scheme and (b) the reliability of the estimates and figures on which the 2019 and 2021 BRIAs are based, and, if this is the case, whether it can provide the details of the consultation carried out, and, if this is not the case, whether it will consider seeking advice from Audit Scotland on such issues.
Answer
Audit Scotland provides advice and support to ensure that public money is spent properly, efficiently, and effectively. Scotland’s Deposit Return Scheme (DRS) is financed and administered by industry under the principles of producer responsibility, therefore Audit Scotland is not involved.
- Asked by: Fergus Ewing, MSP for Inverness and Nairn, Scottish National Party
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Date lodged: Thursday, 10 March 2022
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Current Status:
Answered by Lorna Slater on 23 March 2022
To ask the Scottish Government, in relation to its proposed Deposit Return Scheme, what consideration (a) it and (b) Circularity Scotland has given to the potential impact on distributers and wholesalers in Scotland of a need for two separate SKU’s (Stock Keeping Units), in particular in relation to (i) cost and (ii) space implications, in light of the plans for separate labelling requirements for Scotland and the rest of the UK.
Answer
Stock keeping arrangements related to Scotland’s Deposit Return Scheme (DRS) are a matter for industry to determine; our Regulations do not mandate a separate Scottish label or barcode for in-scope containers.
- Asked by: Fergus Ewing, MSP for Inverness and Nairn, Scottish National Party
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Date lodged: Thursday, 10 March 2022
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Current Status:
Answered by Lorna Slater on 23 March 2022
To ask the Scottish Government, regarding its proposed Deposit Return Scheme, whether wholesalers will be permitted during the course of their normal delivery schedule to use the same lorries and vans for back haul of the collection, and uplift of glass bottles, plastic containers and aluminium tins; whether SEPA has been asked to provide advice on this matter, and, if so, when (a) it was first asked to do so and (b) the advice will be published.
Answer
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.
- Asked by: Fergus Ewing, MSP for Inverness and Nairn, Scottish National Party
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Date lodged: Wednesday, 09 March 2022
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Current Status:
Answered by Lorna Slater on 23 March 2022
To ask the Scottish Government how many businesses in the SME sector it anticipates will cease doing business in Scotland as a result of any additional costs of compliance with the proposed Deposit Return Scheme, such as the bar code and labelling requirements.
Answer
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
- Asked by: Fergus Ewing, MSP for Inverness and Nairn, Scottish National Party
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Date lodged: Wednesday, 09 March 2022
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Current Status:
Answered by Lorna Slater on 23 March 2022
To ask the Scottish Government, further to the comments, regarding potential benefits for industry from its Deposit Return Scheme, by the Minister for Green Skills, Circular Economy and Biodiversity at the meeting of the Net Zero, Energy and Transport Committee on 25 January 2022, that the scheme "will generate about £600 million a year" and that "there is a lot of money to be made", whether it will provide a detailed breakdown of this figure in terms of any potential benefits to industry, and how precisely any such benefits will arise.
Answer
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.
- Asked by: Fergus Ewing, MSP for Inverness and Nairn, Scottish National Party
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Date lodged: Wednesday, 09 March 2022
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Current Status:
Answered by Lorna Slater on 23 March 2022
To ask the Scottish Government, in relation to its plans to include glass packaging in a Deposit Return Scheme, whether it has considered the impact on overall glass recycling rates of splitting glass into two waste streams for material collected manually and using reverse vending machines.
Answer
Section 34 of the Environmental Protection Act 1990 requires those handling waste to ensure that it is handled in a fashion that promotes high-value recycling.
Return points, producers and Circularity Scotland, when handling returned scheme packaging, including glass, will therefore have an obligation to promote high-value recycling regardless of whether the glass is collected manually or by the use of reverse vending machines.