Deposit and Return Scheme for Scotland (Designation of Scheme Administrator) Order 2025: child rights and wellbeing impact assessment

Child Rights and Wellbeing Impact Assessment

1. Brief Summary

Type of proposal:

Scottish Statutory instrument

The Deposit and Return Scheme for Scotland (Designation of Scheme Administrator) Order 2025 (‘the designation order’)

The Deposit and Return Scheme for Scotland (Designation of Scheme Administrator) Order 2025 formally names an organisation as the Scheme Administrator (SA) for Scotland’s Deposit and Return Scheme (DRS). The Order grants to the SA the necessary functions to operate and manage DRS effectively. The SA has responsibilities such as setting the amount of the deposit for drinks containers, and keeping registers of producers and return points. It will also aim to make sure consumers have access to return points.

The designation order is being made at the end of an application process run by Scottish Ministers for an SA.

Following that application process Scottish Ministers decided to name the ‘UK Deposit Management Organisation Limited’ as the SA.

Intended purpose of the Designation Order

• Formal designation of the SA: The order ensures that the SA is legally required to operate the DRS for drinks containers made of polyethylene terephthalate (PET) plastic, aluminium and steel drinks containers in Scotland.
• Legal basis for SA Functions: The order provides a statutory framework for the SA’s duties, including financial management and operational oversight of the DRS. Some of the key functions which impact upon consumers are listed below:
  • The SA must provide an operational plan to the Scottish Environment Protection Agency (SEPA) which explains how the SA will operate the DRS. SEPA will regulate the scheme.
  • The SA will set the amount of the deposit for drinks containers – the amount which a consumer will pay and be refunded when the empty bottle or can is returned. The SA will also issue a logo to be placed on drinks containers to show that the deposit can be refunded.
  • The SA must collect empty drinks containers from return points (usually groceries retailers), and pay them a fee to cover the reasonable costs associated with operating a return point.

• Alignment with DRS in other parts of the UK: The designation order ensures that the SA in Scotland can work together with equivalent SAs for schemes in England and Northern Ireland.

Start date of proposal’s development: June 2024

Start date of CRWIA process: October 2024

2. With reference given to the requirements of the UNCRC (Incorporation) (Scotland) Act 2024, which aspects of the proposal are relevant to/impact upon children’s rights?

The proposed Designation Order and the overarching DRS policy are not directly relevant to the requirements of the United Nations Convention on the Rights of the Child (UNCRC) as outlined in the UNCRC (Incorporation) (Scotland) Act 2024.

While the proposal does not have a direct impact on children's rights, once the SA is designated, it will be responsible for an operational DRS. This may contribute to indirect benefits such as cleaner environments and a reduction in litter that promote better health and safer play spaces by reducing litter in parks, beaches, and other public spaces. These indirect effects align with general principles of the UNCRC’s requirements and once implemented, will impact several key areas.

Cleaner surroundings foster better physical health for children. DRS once implemented will result in reduced pollution and litter which can help lower the impact and incidence of respiratory and other health issues linked to environmental conditions. Access to clean, natural areas benefits physical and mental health across all age groups, including children. (Article 24: Health and Health Services).

DRS should decrease cleanup costs by reducing litter and boosting recycling. The money saved may be reinvested into community services that benefit children, such as schools, parks, and recreational facilities. The scheme also encourages community participation, fostering a sense of unity and improving children’s social wellbeing.

By reducing litter, the DRS creates cleaner, safer spaces for children to play, learn, and engage in their communities. Fewer hazards and a more pleasant environment enrich recreational opportunities for all. (Article 31: Leisure, Play, and Culture).

DRS serves as a valuable educational tool, teaching children about recycling, environmental stewardship, and sustainability. Early exposure to these concepts cultivates a lifelong sense of responsibility toward the environment. (Article 29: Goals of Education – Respect for Urban and Natural Environments).

3. Please provide a summary of the evidence gathered which will be used to inform your decision-making and the content of the proposal

Consultation / feedback from stakeholders

We recognise the importance of involving young people in discussions about policies that impact their environment and future. When consulting on the introduction of DRS in 2019, the Scottish Government engaged with third sector organisations representing a range of stakeholders, including children and young people. Feedback suggested that the introduction of DRS and the expected reduction of litter would improve young people’s perceptions of their own neighbourhood.^[1]

Key links to analysis of consultation responses from stakeholders and public:

A Deposit Return Scheme for Scotland full business case – stage 1

As part of the full business case consultation exercise, an electronic survey captured the views of people, of all ages, including young children (less than 12 years old), from across Scotland. Key themes included the accessibility of the scheme; ensuring that it is easy and understandable to use; being able to return containers to an extensive network of return points to incentivise all ages and enable everyone to be able to participate; and providing manual return points in rural areas.

The Welsh Government has also engaged with these groups in their document “Consumer research to inform the design of an effective deposit return scheme”. We have based many of our findings on this recent report.

Evidence from other UK governments consultation on DRS:

Welsh Government: Consumer research to inform the design of an effective deposit return scheme

The qualitative research in this document consisted of two key strands:

• In-depth interviews with 30 adults and six children aged 11-15, preceded by an online diary exercise amongst adults, recording real-time current consumption and disposal behaviour for drinks in containers, to explore in-depth individual responses to the scheme.
• Group discussions with 70 people, to encourage the sharing of views and enable a more discursive consideration of likely use and ideals for the scheme design. The quantitative research consisted of two online panel surveys: a 20-minute survey with 4,057 adults aged 16 or over and a 15-minute survey with 603 children aged 11 to 15.

The findings suggest younger survey participants are more likely to find recycling burdensome, and to agree that it is only worth doing environmentally friendly things if it saves them money. The introduction of a DRS may have an impact on the purchasing and consumption of in-scope drinks containers, particularly for children aged 11-15. 48% of children within this age group reported that they would reduce the number of bottles and cans they buy by a lot or a little.^[2]

This research found that cash/coins were the favoured deposit refund by surveyed children aged 11-15 over (76%), although electronic methods such as returning via debit card or a smartphone app were appealing to younger adults.

This group also thought large supermarkets would be the most convenient way to return containers, although other centrally and locally placed return points would also be used.

Evidence from existing research/reports/policy expertise

The Scottish Government published a full business case setting out details of the proposed deposit return scheme in May 2019. This followed a public consultation in 2018.

The preparations in place to deliver DRS in Scotland prior to these revised proposals have helped inform an aligned approach with England and Northern Ireland, based on significant engagement and feedback from stakeholders.

A joint policy statement was published which sets out to achieve maximum alignment across the schemes in Scotland, England, Northern Ireland and Wales to make them as simple as possible for consumers and businesses across the UK. This policy statement provides a key evidence base for this proposal.

The following package of DRS impact assessments^[3] informed the DRS development process more widely:

• Deposit return scheme for Scotland: Full Business Case Addendum.
• Deposit Return Scheme for Scotland: Full Business and Regulatory Impact Assessment.
• Deposit return scheme for Scotland: Equality Impact Assessment.
• Deposit return Scheme for Scotland: Fairer Scotland Duty Assessment.
• Deposit return scheme for Scotland: Islands Communities Impact Assessment.

There is anecdotal evidence that there may be wider societal benefits from a DRS. In Ireland, a DRS has been operating since 1 February 2024. Re-turn, the organisation that runs the scheme there, has established a charity fundraising initiative supporting six national children’s charities. As of the 1 February 2025 over €90,000 had been raised for the initiative and over 2,000 schools, clubs and community organisations registered fundraising activities.⁴

More widely DRS aligns with calls to action from the Children’s Parliament on circular economy issues, including having more recycling points in Scotland, and protecting coastlines and cleaning up beaches and rivers.⁵

This information will be shared with the SA who will operate the scheme, to help inform how it works for children and young people.

4. Further to the evidence described at ‘3’ have you identified any 'gaps' in evidence which may prevent determination of impact? If yes, please provide an explanation of how they will be addressed

A potential gap in evidence is the lack of recent direct engagement with children and young people in Scotland to understand their views and perspectives on the DRS policy and this specific proposal on the designation order.

However, we have utilised existing evidence from research elsewhere in the UK to gain information on the views of children and young people. We also know that similar schemes successfully operate in over 50 countries and are used every day by children and young people. We fully recognise the importance of involving young people in discussions about policies that impact their environment and future and will continue to engage with representative organisations via our wider circular economy work.

The Scottish Government assessed the SA candidate’s application to operate DRS. The application included a commitment to communicate with consumers, including children and young people, to promote understanding and awareness of DRS.

5. Analysis of Evidence

The evidence indicates that the proposal does not have a direct impact on children's rights. However, once the SA begins to operate DRS, there is likely to be a largely positive impact on the rights and wellbeing of children and young people in Scotland.

By reducing litter and promoting recycling, the scheme will contribute to cleaner, safer environments where children can play, explore, and learn. This aligns with Article 6 of the UNCRC (the right to life, survival, and development), as a healthier environment directly supports children’s wellbeing and ability to thrive.

Furthermore, DRS encourages a culture of environmental responsibility. By involving children and young people in recycling efforts, the scheme fosters awareness of sustainability and individual accountability for the environment, contributing to their education and personal development in line with Article 29 (the goals of education, including respect for the natural and urban environment).

The DRS operating in the Republic of Ireland demonstrates the wider societal benefits of DRS, with charitable donations benefiting national children’s charities.

Overall, DRS has strong potential to promote children’s rights under Articles 6, 24 (the right to health), and 31 (the right to leisure and play) by improving the quality of their environment and encouraging sustainable practices. By addressing the identified challenges through targeted interventions, we can ensure that the scheme delivers its intended benefits for all children and young people.

6. What changes (if any) have been made to the proposal as a result of this assessment?

No changes have been made to the proposal because of this assessment. However, we recognise the importance of continuing to engage with children and young people. The Scottish Government is committed to working in partnership with stakeholders who represent children and young people, to assess the full impacts of policies as part of the wider Circular Economy and Waste Route Map. This ongoing engagement will help us refine supporting measures to ensure the scheme is effective when it launches.