Publication - Publication

A Deposit Return Scheme for Scotland - Equality Impact Assessment

Published: 4 Jul 2019
Part of:
Environment and climate change
ISBN:
9781839600050

A further assessment of the potential for equalities impacts from deposit return and proposed mitigation of any negative impacts.

27 page PDF

388.0 kB

27 page PDF

388.0 kB

Contents
A Deposit Return Scheme for Scotland - Equality Impact Assessment
Full Equality Impact Assessment: A Deposit Return Scheme for Scotland

27 page PDF

388.0 kB

Full Equality Impact Assessment: A Deposit Return Scheme for Scotland

Description of Policy

Title of policy/ strategy/ legislation  Design of a deposit return scheme for single-use drinks containers.
Minister Roseanna Cunningham, MSP, Cabinet Secretary for Environment, Climate Change and Land Reform
Lead Official Donald McGillivray, Deputy Director, Environmental Quality and Circular Economy
Directorate Environment and Forestry Directorate
New policy and/or legislation The Scottish Government intends to lay regulations before the Scottish Parliament to establish a deposit return scheme later in 2019.

Full EQIA

A partial equality impact assessment (EQIA) was published[1] as part of the Scottish Government’s public consultation on the design of a deposit return scheme (DRS) for single-use drinks containers which took place between 27 June and 25 September 2018. 

This document serves to update on the research, data and wider evidence gathered for the partial EQIA. The document should therefore be read in conjunction with the partial EQIA, as together both documents constitute the full EQIA for the DRS in Scotland.

The full EQIA serves to focus in on some of the key issues identified in the partial EQIA and considers what mitigations could be put in place to reduce the risk of disadvantage that may unintentionally be caused by the introduction of a DRS in Scotland. 

A final EQIA will be produced and published following passage of the legislation to establish the scheme.

Policy Aim 

Scottish Ministers intend to introduce a deposit return scheme for single-use drinks containers.

This new policy forms part of Scottish Government’s wider ambition to develop a more circular economy which keeps products and materials circulating in a high-value state of use for as long as possible – maximising resources to benefit the economy and the environment. 

The work to establish the scheme is underpinned by four key strategic objectives:

1. Increase the quantity of target materials collected for recycling

2. Improve the quality of material collected, to allow for higher value recycling

3. Encourage wider behaviour change around materials

4. Deliver maximum economic and societal benefits for Scotland

A Programme Board, chaired by the Scottish Government, is responsible for providing strategic direction and overseeing the delivery of the scheme.  

The Preferred Scheme Design 

The Scottish Government announced the key features of its deposit return scheme on 8 May.  The preferred scheme design is detailed through the Deposit Return Scheme Full Business Case Stage 1[2] and has been informed by extensive public consultation, international best practice and engagement with a broad range of stakeholders. 

Public Consultation:

The public consultation was open between June and September 2018, and 54 questions were posed.

The consultation received 3,215 submissions, which included 1,048 campaign responses organised by campaign group Have You Got the Bottle[3]. Of the remaining responses, 159 were from organisations and 2,008 from individuals.

There was widespread agreement amongst both organisational and individual respondents that a well-run and appropriately targeted DRS could provide opportunities in relation to improving the environment, changing people’s attitudes to recycling and littering, and building the circular economy. 

Respondents identified potential benefits (for employment, small retailers, charities and individuals) and risks (both general and specific) of establishing a DRS in Scotland. They also suggested ways to maximise opportunities and mitigate risks.

An independent analysis[4] of the consultation responses was completed by Griesbach & Associates and Jennifer Waterton Consultancy. This was published by the Scottish Government on 21 February 2019.  

International best practice:

A number of international schemes have been researched, with Zero Waste Scotland having visited eight currently in operation across Europe.  Each one operates in different circumstances with different legal and fiscal systems, with a number having operated for several years meaning behaviours and systems are embedded. Therefore no direct comparators are possible. Nevertheless, this research has informed thinking on how different elements of Scotland’s scheme should interact in order to achieve the desired results.

Stakeholder engagement: 

Evidence has been gathered from a wide range of stakeholders through interviews, workshops and strategic conversations to inform Ministers proposals for DRS

Summary of preferred scheme design:

The preferred scheme design enables consumers to take single-use containers back and redeem a 20p deposit from any retailer selling drinks covered by the scheme. 

Businesses that sell drinks to be opened and consumed on-site, such as pubs and restaurants, will have the choice as to whether to charge the deposit to the public and will only be required to return the containers they sell on their own premises.

Online retailers will be included in the scheme. This means that those customers who are dependent on online delivery, because for a variety of reasons they are unable to travel to shops, are able to easily get back the deposits paid on containers. 

Non-retail spaces will be able to act as return locations. These could include recycling centres, schools or other community hubs. While retailers will be required by legislation to provide a return service, non-retail spaces will operate on an opt-in basis.

Bigger retailers with more space may install machines to both collect the bottles and cans and enable people to redeem deposits. Smaller retailers with less space have the option to return deposits over the counter, collecting the containers manually. 

The scheme will include plastic bottles made from PET (the most common type of bottle for products such as fizzy drinks and bottled water), aluminium and steel cans and glass bottles. 

Schemes which operate on similar principles in places such as Scandinavia and the Baltic states capture up to 95% of eligible drinks containers for recycling. Scotland’s DRS will target a return rate of 90%. This is significantly higher than the current capture rates for the materials that are in scope of our proposals. 

Having a deposit level which provides a sufficient incentive to return containers, together with provision of high coverage of return points, means that this target is ambitious but achievable. This target will be written into legislation for the Scheme Administrator to deliver.

It is important to note that the true national recycling rate for the containers targeted through Scotland’s DRS will be slightly higher than the scheme capture rate itself. This is because some items will continue to be returned through other recycling facilities.  

The impacts of the preferred design scheme:

This preferred scheme design is expected to deliver a high return rate for containers in scope. As such, it most closely matches the environmental ambitions which underpin the policy.

The scheme design offers flexibility for consumers and the opportunity to maximise the capture rate by adopting return to any place of purchase, including online retailers. This means that return locations will be in the same places where individuals are purchasing the containers, ensuring ease of access for consumers regardless of where they live. 

The preferred deposit level is 20p. This is within the range of deposit levels adopted by successful international schemes, adjusted for inflation. It is the median deposit level suggested by responses to the public consultation.

The impact of the deposit on groups protected under equalities legislation was explored in the partial EQIA. There is little perceived difference in the impact between either a 10p or 20p deposit, assuming that convenience of the scheme allows individuals and households to redeem deposits frequently and easily. 

Who will DRS affect? 

The partial EQIA document explored in broad terms the likely impact of DRS on different groups in Scottish society.  The work undertaken since completing the partial EQIA has examined these potential impacts in greater depth.

It is important to note that the protected characteristics covered through an EQIA are often not independent of each other and some people may have to deal with complex and interconnected issues related to experiencing disadvantage at any one time.  

Potential Positive Impacts:

As outlined previously in the partial EQIA, the potential positive impacts of a DRS will include an increase in the number of drinks containers recycled, reduction in litter, potential job creation opportunities and wider social benefits, including opportunities for consumers to donate deposits to charities and/or community groups. 

What might prevent the desired outcomes being achieved?

Achieving the desired outcomes will be dependent on businesses and consumers adopting new behaviours to effectively deliver a DRS.  

Ensuring high participation of consumers will be key to the scheme’s success. There are a number of scheme design considerations that are fundamental to ensuring that everyone can equally participate in the scheme and these are the primary focus of this full EQIA.  

Work Undertaken for Full EQIA

The partial EQIA presented some preliminary and indicative impacts for consideration during the consultation period and was based on a broad range of research, data and evidence gathering. 

This document builds on the partial EQIA by providing in-depth consideration around key elements of DRS, supported by extensive further engagement with equality stakeholders. This work was undertaken to increase understanding of some of the evidence previously gathered and to inform mitigation measures that may assist with minimising potential negative impacts.

Specifically, this has involved:

  • An update of evidence from annual surveys, including the Scottish Household Survey 2017 and ONS data contained within the partial EQIA
  • A review of the electronic survey completed by members of the public as part of Zero Waste Scotland’s Programme of public consultation events 
  • A review of information gathered as part of workshops run before and during the public consultation
  • Engagement with individuals, groups, and organisations involved in equality and Fairer Scotland work
  • Interviews with RVM manufacturers
  • Additional information gathered from local authorities who provide an assisted kerbside collection service for those who require support with their bins and/or recycling boxes
  • Analysis of the responses to questions specifically posed on the published partial EQIA as part of the Scottish Government’s public consultation
  • Results of a Disability Equality Scotland electronic survey specifically on DRS

We have contacted and engaged with a variety of stakeholders on the equality impact of the scheme, directly and through workshops, including:

Learning Link Scotland Age Concern UK Capability Scotland
Dyslexia Scotland Scottish Poverty Alliance Inclusion Scotland
Equality and Human Rights Commission  CEMVO Scotland (Ethnic Minority Voluntary Sector) Development Trusts Association Scotland 
Age Scotland Young Scot Census Team
32 Scottish Local Authorities Disability Equality Scotland Scottish Council for Voluntary Organisations 
Reverse Vending Machine Manufacturers Scottish Trades Union Congress / Scottish Union Learn Equality Officers

Summary Reflection

A final EQIA will be produced and published on the scheme design once the regulations to establish DRS have been passed by the Scottish Parliament.

Consequently, this full EQIA is not intended to be a final definitive statement of impacts. The full EQIA does however explore options to maximise participation in DRS by all members of society. The evidence gathered will continue to inform the planning and implementation of  DRS

Summary reflections from the evidence gathering and engagement to date indicate that the preferred scheme, and the changes this will bring, could potentially have an impact on some people and/or communities, directly or indirectly, and in different ways. This document outlines these in detail and sets out how any potential negative impacts should be mitigated.

Interaction with Other Policies:

The links with following policies, which have now come into force, were identified in the partial EQIA.

  • European Union Circular Economy Package[5]
  • UK Government’s Soft Drinks Sugar Levy[6]
  • Scottish Government’s Minimum Unit Price on Alcohol[7]

Extent/Level of Full EQIA:

The evidence captured in the section entitled Data and evidence gathering, involvement and consultation has been drawn from a range of sources and has looked in greater depth at some of the key issues highlighted in the partial EQIA. The sources include: updated statistics from Scottish Household Survey 2017; information from the Zero Waste Scotland’s public consultation events and survey; engagement and interviews with equality groups; analysis of the public consultation on the partial EQIA; information provided by and interviews with local authorities on assisted kerbside collection services; and interviews with RVM manufacturers.

A full list of references is provided at the end of this document.

Stage 2: Data and evidence gathering, involvement and consultation

This section includes the results of the evidence gathering undertaken for the purposes of this assessment, including qualitative and quantitative data, and outlines the source of that information, whether national statistics, surveys or engagement with those involved in promoting equality as well as equality groups.

In the partial EQIA a broad range of research, data and evidence gathering was highlighted against each of the protected characteristics. On this occasion, we have instead chosen to align evidence to those key features of the scheme which are most likely to impact on public participation:

  • Public communication
  • Accessibility of return points
  • Operation of reverse vending machines
  • Participation of those who use online grocery retailers
  • Participation of those who use local authority assisted kerbside collection services

This reflects and highlights the fact many of the considerations relevant to DRS are likely to cut across multiple protected characteristics, with the evidence highlighting age and disability as key areas for consideration.  Finally, we have gathered evidence on the cross-cutting considerations which are necessary in order to ensure DRS is compliant with the legislative and regulatory framework concerning the promotion of equality.

Evidence gathered and strength/quality of evidence

Source (full reference details in appendix)

Data gaps identified and action required

Public Communication

In 2017, 1% of adults aged 16 to 24 reported not using the internet, compared to 24% per cent of those aged 60 to 74 and 63% of those aged 75 and over. The method of accessing the internet also varies with age, for example, 93% of 16 to 24-year olds use a mobile phone, compared to 53% of those in the 60-74 years bracket. There is a clear relationship between age and internet use, with lower usage rates among older people. 

This analysis of this evidence is unchanged from the partial EQIA which suggests that online, digital and social media channels are an effective way of targeting young people.  However, there may be more effective channels for engaging older people and those experiencing socio-economic disadvantage.

Scottish Household Survey 2017[8].

It was highlighted in the partial EQIA that individuals with learning difficulties may require additional support to participate in the scheme. 

For example, an estimated 1 in10 people in Scotland has dyslexia - 500,000 people across all ages. Proportions vary across specific communities (for example, in prison, rates of dyslexia are 60% and in farming communities, 20%). 

People who experience dyslexia can encounter a complex range of learning differences with reading/writing, processing information, organisation issues, short term memory, remembering sequences, following instructions and visual stress. 

To assist this community, Dyslexia Scotland has its own:

- Youtube channel;

- A website for children (8-18yrs); 

- Tailored Information packs.

Interview with Dyslexia Scotland, 2018.

Some stakeholders have commented on the impact that DRS may have on people with early stage Dementia or Alzheimer’s and raised the question of what will be done to mitigate issues for people affected by such conditions.

Interviews with Dyslexia Scotland, Learning Link Scotland and STUC Equality Officer, 2018.

Accessibility Of Return Points

In 2017, over a quarter of adults (28%) reported a long-term physical or mental health condition.  It is not unreasonable to conclude that such conditions could limit the ability of individuals to access return points.

The Scottish Household Survey statistics 2017.

Evidence was gathered through an electronic survey, organised by Disability Equality Scotland (DES), to explore the potential impact of DRS on disabled people. 

Respondents typically raised the impact of their disability on their ability to return containers. A requirement for additional storage at home and the proximity of return locations were highlighted as key considerations. 

Respondents consistently highlighted the importance of local return points and that these should include local shops.

Disability Equality Scotland (DES) Electronic Survey Analysis October 2018.

Experience in other countries operating DRS seems to suggest that scheme accessibility can best be facilitated through a return to retail model accommodating both manual and automated takeback.  The inclusion of small retailers and local shops can help to maximise participation by everyone in both urban and rural communities.

Zero Waste Scotland interviews with RVM manufacturers on 28 September 2018: RVM Systems, TOMRA and Envipco.

Operation Of Reverse Vending Machines (RVMs)

Accessibility of the scheme would be supported by:

  • siting RVMs in accessible locations
  • ensuring RVMs are user-friendly 
  • ensuring that the required accessibility standards are met in respect of these facilities

Zero Waste Scotland interview with stakeholders 12 April 2018.

Information from the RVM manufacturers, based on their experience of operating their technology in other countries, suggests that the provision of a network of accessible, local drop off points and return locations, including RVMs, will enable participation of people experiencing mobility, disability and/or health issues. 

There are examples of larger retailers in other countries making physical modifications to enable greater access to RVMs for people using a wheelchair or experiencing other disabilities such as visual or hearing impairments.

Zero Waste Scotland interviews with three RVM manufacturers on 28 September 2018: RVM Systems, TOMRA and Envipco.

Experience in other countries suggests that small stores often do not operate RVMs due to space constraints.

Zero Waste Scotland interviews with three RVM manufacturers on 28 September 2018: RVM Systems, TOMRA and Envipco.

The scheme’s target operating model, including the specification for RVMs, will need to ensure return points are accessible in order to maximise opportunities for participation.  

In particular, the specification for RVMs will need to afford retailers a degree of flexibility, allowing them to select and operate the machine which best meets their needs.

Research indicates that the utilisation of RVMs is often regulated through legislation. Regulation can extend to, for example:

  • Considerations around the location of RVMs.
  • Considerations around the number of RVMs to be operated on individual premises, taking account of building, planning and health and safety standards. 

The locational placement of RVMs is often the responsibility of the Scheme Administrator.

Zero Waste Scotland interviews with three RVM manufacturers on 28 September 2018: RVM Systems, TOMRA and Envipco.

Evidence suggests that adaptations to RVMs can assist disabled people.  Information from the RVM manufacturers demonstrates the potential for flexibility in machine specifications, including in relation to reach and height.  Other optional features can include:

  • Colour, size and font of text
  • Automatic production of receipt
  • Use of visuals and graphics
  • Voice activation
  • Touch screen
  • Interactive screen
  • Dual language

In order to maximise accessibility, RVM suppliers suggested that machines should be:

  • intuitive
  • user-friendly
  • self-explanatory

Zero Waste Scotland interviews with three RVM manufacturers on 28 September 2018: RVM Systems, TOMRA and Envipco.

Engagement with both equality groups and RVM manufacturers emphasised the importance of design and planning of local return points and RVM locations to ensure accessibility and convenience, including for example:

  • well-lit spaces
  • visible signage
  • posters
  • local guidance
  • colour-coded maps
  • signposts
  • child-friendly/user-friendly machines

Zero Waste Scotland interviews with three RVM manufacturers on 28 September 2018: RVM Systems, TOMRA and Envipco.

Interviews with Dyslexia Scotland, Inclusion Scotland, Learning Link Scotland and STUC Equality Officer 2018.

It is evident that many equality groups have expertise in guiding the design and delivery of services to maximise accessibility.  This experience and understanding should be harnessed to assist in the design of the DRS and RVMs.

Interviews with Dyslexia Scotland, Inclusion Scotland, Learning Link Scotland and STUC Equality Officer 2018.

Evidence suggests there may be, on occasion, a need for staff working at return points to support customers in accessing RVMs.

Zero Waste Scotland interviews with three RVM manufacturers on 28 September 2018: RVM Systems, TOMRA and Envipco.

Participation Of Those Who Use Online Grocery Retailers

The proportion of households with home internet access is highest in large urban areas (87%) and remote rural areas (86%), and lowest in remote small towns (80%).

Scottish Household Survey 2017.

Gaps in internet access and use remain amongst certain groups including those in deprived areas, those in social housing and those on low incomes. 19% of adults living in the 20% most deprived areas in Scotland reported not using the internet compared with 15% in the 20% least deprived areas.

Home internet use tends to increase with household income, although the gap is lessening over time. In 2017, 63% of households with incomes of £15,000 or less had home internet access, increasing to 99% of households with incomes over £40,000

Indications are that a digital divide remains along a number of dimensions, including age and socio-economic disadvantage. 

Scottish Household Survey 2017.

Stakeholders consistently identified that many of those who use online shopping will have little choice but to rely on some form of take-back service to be provided at the point at which their groceries are being delivered if they are to be able to redeem their deposit. 

Interviews with Equality Officers, STUC Equalities Disabled Workers Committee.

Respondents to Disability Equality Scotland’s membership survey consistently highlighted the reliance of disabled people on online shopping. 

Disability Equality Scotland (DES) Electronic Survey Analysis 2018.

Evidence suggests that online shopping is increasing in the United Kingdom, both in terms of value and growth. The average value of weekly online sales in food stores has more than doubled between 2010 and 2016, reaching £141.9m.

The Statistics Portal: Online grocery shopping in the United Kingdom[9]

Mintel research shows that online grocery shopping is growing, with many young people opting to shop online. Almost two thirds of young people in UK (62%) aged 25-34 are current online grocery shoppers, as well as 57% aged 35-44 and 56% aged 16-24.

Mintel Research Report on Online Grocery Shopping[10]

Participation Of Those Who Use Local Authority Assisted Kerbside Collection Support Services

Information and data gathered by directly contacting all 32 Scottish local authority waste service managers highlighted the need for further clarification on:

  • how residents who currently receive an assisted kerbside collection service will be able to participate in the scheme without assistance.
  • The role of councils in communicating the interaction of DRS with existing kerbside collection arrangements. Many councils currently provide information concerning kerbside collections digitally in order to minimise costs. 

Analysis of the information requested by Zero Waste Scotland from all 32 local authorities on the assisted kerbside collection service they offer their residents.  

Achieving Regulatory Compliance

Equality law makes clear that bringing about equality may mean changing the way in which services are delivered, providing extra equipment and/or the removal of physical barriers. This is the duty to make ‘reasonable adjustments’. 

The Scheme Administrator will require to be proactive and anticipatory in taking steps to remove or prevent any obstacles.

The Equality Act 2010[11]

Equality and Human Rights Commission (EHRC) Guidance: Equality Law and What it Means for Business[12]

Experience from other countries shows us that standards for the operation of deposit return schemes are often determined through national regulations and/or legislation. For example, the Americans with Disabilities Act (ADA) outlines standards that require to be met for RVMs regarding reach heights for people who use wheelchairs.  

Americans with Disabilities Act[13]

Guidance on the 2010 ADA Standards for Accessible Design[14]

Research on standards suggests that British Standard BS 8300-1:2018 and BS 8300-2:2018 provide guidance on designing accessible and inclusive environments, how to approach inclusive design and how to adopt a strategic approach to access and inclusion in design process.

Guide To Designing Accessible And Inclusive Environments: The British Standard BS 8300-1:2018 and 8300-2:2018[15].

Stage 3: Assessing the quality of the impacts and identifying opportunities to promote equality

The partial EQIA was based on broad-based research, data and evidence gathering. It contains the potential impacts – negative, positive and neutral – which were considered for each of the protected characteristics and other socio-economic considerations as outlined in the Fairer Scotland Duty.  

Based on the evidence gathered through the partial EQIA and this full EQIA, we believe the preferred scheme design for DRS has the potential to impact on the protected characterstics as follows:

Identified Considerations

Age

Disability

Sex/ Gender

Pregnancy & Maternity

Gender Reassignment

Sexual Orientation

Race

Religion or Belief

Marriage
& Civil Partnership

Public communication 

x x x x x x

Accessibility of return points

x x x x x x x

Operation of RVMs

x x x x x x x

Participation of those who use online frocery retailers

x x x x x x x

Participation of those who use local authority assisted kerbside support services

x x x x x x x

For brevity, in the following tables the updated evidence considers the protected characterstics collectively and the impact of Ministers preferred scheme design for DRS on those charactersitics. 

This is an indicative assessment of the potential impacts and mitigations and will be subject to further review and revision during the implementation of the scheme design and for the final EQIA.

Do you think that the policy impacts people?

Positive

Negative

None

Reasons for your decision

Eliminating unlawful discrimination, harassment and victimisation

X

Ministers’ preferred scheme design for DRS is detailed through the Deposit Return Scheme Full Business Case Stage 1 which in turn has been informed by the evidence outlined in this full Equality Impact Assessment.  We have not identified any evidence to suggest that the proposed scheme will result in unlawful discrimination.

Advancing equality of opportunity

X

As outlined earlier in this document, it is clear that many of the key features of the proposed scheme design have the potential to impact on equality of opportunity across the range of protected characteristics.  Steps have been taken throughout the development of the scheme design to maximise equality of opportunity for public participation and these are outlined below: 

Public communication: Accessible communication and inclusive engagement will be central to ensuring high participation and equality of access to the scheme. 

As work progresses in preparation for the scheme’s implementation, it will be crucial to ensure that DRS communication and engagement activity has a strong equality focus.  This will allow us to ensure that people with a range of needs and characteristics will be able to clearly understand what the DRS is, how it works, where they can find their nearest return point, what they can return and how they can redeem their deposit.  

Comprehensive, multi-channelled and inclusively designed communication and engagement programmes and materials will be key to achieving this. 

Accessibility of return points: The evidence gathered to date suggests that the location of return points, their accessibility and convenience of use should be prioritised.  The preferred scheme design has taken account of this by proposing that a return to any place of purchase model will be adopted as part of the scheme, meaning that members of the public will be able to return containers to any retailer who sells single-use drinks containers covered by the scheme.   Non-retail spaces will also be able to act as return locations. These could include recycling centres, schools or other community hubs.

Return points will be able to operate both manual and automated take-back arrangements, thereby removing a potential obstacle to the participation of smaller retailers who may not be in a position to accommodate an RVM.

Operation of Reverse Vending Machines (RVMs): 

Evidence gathered suggests it is important that all RVMs are accessible in terms of both their location and operation.  

The provision of modified RVMs, alongside RVMs of standard design, will be key in enhancing access to the scheme as will the provision of support in those retail settings operating RVMs.  These are factors which will be considered as part of the work the Scottish Government’s DRS Implementation Advisory group.

Participation of those who use online grocery retailers:  Online shopping is a service that is relied on by many people including disabled people and those who live in rural areas. Accordingly, the preferred scheme design proposes that online retailers be required to operate a take-back service for their customers. This means that those customers who are dependent on online delivery, because for a variety of reasons they are unable to travel to shops, are able to easily get back the deposits paid on containers.

Participation of those who use local authority assisted kerbside collection support services: Further work is required to understand what additional support can be offered to those individuals who currently receive assisted kerbside collection services in order to aid their participation in DRS.  We will consider this as part of our ongoing discussions with local government about the implementation of deposit return.

Promoting good relations among and between disabled and non-disabled people 

X

The DRS preferred scheme design is unlikely to impact on the promotion of good relations between disabled and non-disabled people.

Stage 4: Decision making and monitoring (Identifying and establishing any required mitigation action)

Have positive or negative impacts been identified for any of the equality groups?

The potential for negative impacts from this policy have been identified. Through
this work, though, measures to effectively mitigate these impacts have also been identified – some of these have been reflected in the scheme design and others will be addressed as part of implementation work. 

It is important to note that the protected characteristics considered within this full EQIA are not independent of each other and some people may have to deal with complex and interconnected issues related to experiencing disadvantage at any one time.  The preferred scheme design outlined in the Deposit Return Scheme Full Business Case Stage 1 takes steps to mitigate any potential negative impacts on equality groups and prioritises the promotion of equality of opportunity to participate in the scheme.

As we enter the implementation phase of the scheme, the following steps may prove helpful to further mitigate the potential for any negative impacts to be realised:

  • Principles and practice of inclusive design, using the BS8300 Standard, should inform implementation acitivity going forward.
  • The accessing of further expert advice in inclusive design could assist in the implementation of a scheme that maximises participation by all.
  • A range of functional modifications to RVMs should be considered to aid participation amongst all members of society. 

Is the policy directly or indirectly discriminatory under the Equality Act 2010[16]?

There is no evidence that the policy is directly or indirectly discriminatory under the Equality Act 2010.

If the policy is indirectly discriminatory, how is it justified under the relevant legislation?

N/A

If not justified, what mitigating action will be undertaken?

N/A

Describing how this Full Equality Impact analysis has shaped the policy making process so far

The full EQIA has helped to highlight in more depth specific areas of interest identified through the partial EQIA. It aims to inform the considerations of the Scottish Parliament in respect of the regulation and operation of a DRS in Scotland and to reduce and counter any disadvantages that may unintentionally be caused by its introduction.

We will continue to engage with equality representative groups to explore appropriate measures to mitigate against any negative impacts that a DRS may have on any particular groups.  That engagement will inform the final EQIA which will be produced and published following passage of the secondary legislation required to establish the scheme.

Monitoring and Review

We believe it is essential to monitor some of the suggested mitigation measures contained within the full EQIA by identifying and gathering relevant information to assess the extent to which the measures are enabling full participation in the scheme. 

These will be outlined in more detail within the final EQIA, including: when the monitoring and evaluation will take place; and who will be responsible for undertaking it.

Stage 5: Authorisation of EQIA

Declaration:  I am satisfied with the full equality impact assessment that has been undertaken for the Consultation on the Design of a Deposit Return Scheme for Drinks Containers in Scotland and give my authorisation for the results of this full assessment to be published on the Scottish Government’s website. 

Name: Donald McGillivray

Position: Deputy Director, Environmental Quality and Circular Economy


Contact

Email: DRSinScotland@gov.scot