Chamber and committees

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.

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 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.

The Final business and regulatory impact assessment (BRIA) of 2021 has a figure for fraud of £108 million, not £74.3 million. You can find details in Table 2 which can be downloaded here: https://www.gov.scot/publications/deposit-return-scheme-scotland-final-business-regulatory-impact-assessment/ .

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.

The model used to inform that BRIA deals with local authorities as a collective group and it is therefore not possible to provide detailed calculations for individual local authority costs and benefits in relation to recycling. You can view the full report here: https://www.gov.scot/publications/deposit-return-scheme-scotland-final-business-regulatory-impact-assessment/ .

Landfill tax is considered a ‘transfer payment’ under HM Treasury guidance and is therefore not included in BRIA calculations.

Circularity Scotland Ltd, the industry-led Scheme Administrator for Scotland’s Deposit Return Scheme (DRS), is responsible for determining the number and location of counting and sorting centres and the associated staffing requirements.

Under the producer responsibility principle, the costs of these centres will be borne by industry.

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 most up to date information available regarding the impact of Scotland’s Deposit Return Scheme on retailers, including information about the use of Reverse Vending Machines (RVMs) can be found in the amended Final Business and Regulatory Impact Assessment (BRIA), which was published on 22 December 2021 and can be downloaded from the Scottish Government’s website here: https://www.gov.scot/publications/deposit-return-scheme-scotland-final-business-regulatory-impact-assessment/ .

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.