Deposit return scheme - gateway review: final report

Final report for the deposit return scheme gateway review.

1.0 Gateway Review Conclusion

Delivery Confidence Assessment: Amber/Red

It should be recognised that the DRS Programme has, by intention following extensive consultation, taken a (probably) innovative approach to delivering a DRS for Scotland. Pursuit of the philosophy of Extended Producer Responsibility has directed the responsibility for implementing a DRS in Scotland to industry.

SG and Scottish Ministers retain responsibility for achievement of the Deposit Return Regulations and the strategies from which the regulations are derived, including setting delivery dates and providing assurance to the Scottish community for effective deployment of DRS. Beyond enforcement of the Regulations, SG retains few tools and leverage to drive implementation.

This delivery approach comes with significant challenges to provide governance and leadership whilst also maintaining sufficient public assurance. It also introduces significant time penalties to mature and embed effective collaborative functionality and control. These challenges and impacts are most apparent in the DRS Programme and at this time are yet to be resolved; the difficult transition from government to industry leadership is still ongoing.

The Review Team met with a large number of stakeholders, and are confident that this Report represents a realistic and comprehensive status of DRS, as responsibility transitions from SG to industry, represented by CSL [redacted].

[redacted] The recommendations in this Report are intended to assist SG to manage the transition of responsibility and accountability in a measured way.

As a consequence of these issues, the Review Team finds that a fully functioning and compliant DRS cannot be in operation for the revised August 2023 schedule. [redacted] The Review Team believes that a 'softer' approach to DRS implementation should be pursued but further urgent activity would be required to consider, assess and agree this possibility.

The Review Team found a solid verbal commitment from all parties that a DRS is the ‘the right thing to do’; therefore, the Review suggests that SG should remain resolute, keeping its eye on the longer-term and central benefits identified for the Programme – these are still achievable.

The Delivery Confidence Assessment RAG status should use the definitions below.


Criteria Description


Successful delivery of the project to time, cost and quality appears highly likely

and there are no major outstanding issues that at this stage appear to threaten delivery.


Successful delivery appears probable. However, constant attention will be needed to ensure risks do not materialise into major issues threatening delivery.


Successful delivery appears feasible but significant issues already exist requiring management attention. These appear resolvable at this stage and, if addressed promptly, should not present a cost/schedule overrun.


Successful delivery of the project is in doubt with major risks or issues apparent in a number of key areas. Urgent action is needed to ensure these are addressed, and establish whether resolution is feasible.


Successful delivery of the project appears to be unachievable. There are major

issues which, at this stage, do not appear to be manageable or resolvable. The project may need re-base lining and/or overall viability re-assessed.



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