Deposit return scheme for Scotland: BRIA

Full business and regulatory impact assessment (BRIA) assessing the regulatory impacts of deposit return for drinks containers for businesses in Scotland.

2.0 Purpose and Intended Effect

2. Scotland’s household recycling rate has increased substantially in the last decade. The latest figures, published in September 2018[1] by the Scottish Environment Protection Agency (SEPA), confirm that in 2017 the recycling rate reached 45.6%.

3. This has been driven by substantial investment by central and local government in kerbside collections. The result has been a dramatic increase in the number of households who have access to recycling facilities. All 32 local authorities are now nearing completion of these rollouts, covering most of the properties in their area.

4. The rate of growth has, however, been slowing. Since 2014 and the introduction of a new methodology for calculating recycling rates, it has only increased by 2.8%. A complex range of factors contribute to this limited improvement and further interventions are required to stimulate growth in recycling rates in order to achieve national recycling targets: 70% of all waste recycled and a maximum of 5% to landfill by 2025.

5. In September 2017, the Scottish Government announced in the Programme for Government (PfG) that it would move to implement a deposit return scheme (DRS) for Scotland for single-use drinks containers[2]. The 2018 Programme for Government reaffirmed this commitment. The scheme will be tailored to meet Scotland’s specific needs, and with the specific aims of increasing recycling rates and reducing littering.

6. The consideration of a DRS is referenced in the Scottish Government’s circular economy strategy Making Things Last – A Circular Economy Strategy for Scotland (MTL)[3] published in February 2016. The strategy sets out the aims of cutting waste and carbon emissions, reducing reliance on scarce resources, increasing productivity and improving resilience.

7. Towards a Litter-Free Scotland[4] (TLFS), published in June 2014, is Scotland’s first national litter strategy with a focus on litter prevention. This is being delivered by encouraging people to take personal responsibility through activities related to infrastructure, information and enforcement. The aim of the strategy is to reduce the estimated £46 million of public money spent removing litter and flytipping from the environment each
year and the wider negative impacts of litter; at least a further £361 million in costs on our society and economy. It will also enable the lost value
of resources to be recovered; littered material could be worth at least
£1.2 million a year.

8. A Marine Litter Strategy for Scotland[5] (MLSS) was launched in 2014 as a sister document to Towards a Litter-Free Scotland, focused on protecting Scotland’s coastal environment as a major resource. This will contribute to collaborations under the OSPAR Convention (Convention for the Protection of the Marine Environment of the North East Atlantic)[6] and the Marine Strategy Framework Directive.

2.1 Objectives

9. It is proposed that a Scottish DRS will:

  • Increase the quantity of target materials collected for recycling.
  • Improve the quality of material collected, to allow for higher value recycling.
  • Encourage wider behaviour change around materials.
  • Deliver maximum economic and societal benefits for Scotland.

10. Achieving these strategic objectives will help Scotland progress towards its 2025 waste targets, accelerating Scotland’s transition from a ‘linear’ economy which is environmentally unsustainable and energy and resource intensive, to a more resource efficient and sustainable circular economy.

11. Growing global and national populations are expected to increase commodity price volatility and constraints on resources availability, which could lead to adverse social and economic effects. Adoption of circular economy measures like a Scottish DRS should help to provide resilience to such shocks and constraints, and aid in delivering significant environmental benefits and economic opportunities.

12. By placing a financial value on select single-use drinks containers, a DRS will encourage consumers to return them for recycling, reducing the likelihood that they will end up as litter and increasing the likelihood they will be recycled. This will, in part, help to address a growing global concern about the volume and impact of plastic pollution, particularly in marine landscapes.

13. Separate and material-specific collection of select packaging materials under a DRS will also generate higher quality, higher value material streams.

14. The fit with Scottish Government policy has already been indicated in the background sections above. The UK Department for Environment and Rural Affairs (DEFRA), Welsh Government and Northern Ireland Executive recently consulted on a potential DRS for England, Wales and Northern Ireland[7].

15. The introduction of DRS will clearly have an impact on businesses in Scotland. As a form of producer responsibility, it will require those businesses to take responsibility for the environmental impact of their products and for the costs of managing products at end of life. We have had a system of producer responsibility for packaging in place in the UK since 1997 and that system has helped to drive significant increases in recycling. However, more must be done and the European Commission[8] with reference to its Circular Economy Package, support DRS as an effective response to the challenge we face.

2.2 The Preferred Scheme Design

16. 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.

17. Businesses that sell drinks to be opened and consumed on-site, such as pubs and restaurants, will not have to charge the deposit to the public and will only be required to return the containers they sell on their own premises.

18. 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.

19. Non-retail spaces will be able to act as return locations. These could include recycling centres, schools or other community hubs. The only difference with retailers is that they will be required by legislation to provide a return service and others will be able to apply to opt in.

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

21. 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.

22. Schemes that run 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 almost double the current capture rates for the materials that are in scope. 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.

23. 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 not returned will continue to be returned through other recycling facilities.

24. The schematic in Annex A illustrates the preferred scheme design for a Scottish DRS.

2.3 Rationale for Government Intervention

25. With reference to the National Performance Framework, the scheme is expected to support the National Outcomes:

  • We value and enjoy our built and natural environment and protect it and enhance it for future generations
  • We reduce the local and global environmental impact of our consumption and production

26. Relevant National Indicators are:

  • Improve people’s perceptions of their neighbourhood
  • Increase natural capital
  • Improve the state of Scotland’s marine environment
  • Reduce Scotland’s carbon footprint

27. The introduction of a DRS for Scotland will contribute to objectives set out in the Climate Change (Scotland) Act 2009[9], and the Climate Change Plan: Third Report on Proposals and Policies 2018-2032[10] (RPP).

28. The RPP was published in February 2018. This sets out plans to achieve decarbonisation of the economy in the period to 2032, making progress towards the target of reducing emissions by 80% by 2050.

29. Resource use and waste generation are recognised as key sources of greenhouse gas generation and the Scottish Government reports on progress against both territorial and consumption emissions.

30. United Nations Draft Resolutions on Marine Litter and Microplastics[11] (2017) and Management of Marine Debris[12] (2014), both reference the role that DRS can have on preventing the harmful escape of plastics into marine environments.

31. In 2015, the Scottish Government signed up to support the United Nations Sustainable Development Goals[13]. The ambition behind the goals is to end poverty, protect the planet and ensure prosperity for all as part of a new sustainable development agenda. A DRS will have a positive impact on a number of these goals, most explicitly Goal 12: Responsible Consumption and Production.

32. In May of 2018 the European Commission’s Circular Economy Package[14] was approved. The legislation aims to move supply chains towards a circular economy maintaining the value of products, materials and resources in the economy for as long as possible. This includes more ambitious recycling targets and full cost recovery of recycling costs from producers.



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