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.

6.0 Consumer Assessment

138. It is important to consider the impact of the introduction of a DRS on the consumer, taking into account consumers of specific industries, firm types and businesses of different sizes. As per guidance, consumer impact is assessed against the questions below.

Table 6. Consumer Assessment Questions

Q1. Does the policy affect the quality, availability or price of any goods or services in a market?

The policy will apply a 20p deposit on eligible drinks containers. This deposit will be reimbursed once the consumer returns the container to a return point. Any potential pass-through of increased costs on producers to consumers will be considered in the Final BRIA. The impact of the deposit is assessed in the DRS Equality Impact Assessment and Fairer Scotland Impact Assessment.

A number of businesses have highlighted the additional production, warehousing and distribution costs that would arise as a result of the introduction of a DRS in Scotland in advance of the rest of the UK. These costs are linked to the introduction of distinct Scottish labelling as a fraud prevention measure for the scheme.

Producers in particular have indicated that these increased costs could influence the number of product ranges supplied to the Scottish market, with lower volume products likely to be most at risk. The scheme design seeks to mitigate this risk by introducing a degree of flexibility around the fraud prevention measures to be adopted by producers. It is not the intention to mandate distinct Scottish labelling on products and it will be left to producers (working with the scheme administrator) to identify the most effective and efficient combination of fraud prevention measures for the purposes of the scheme.

Q2. Does the policy affect the essential services market, such as energy or water?


Q3. Does the policy involve storage or increased use of consumer data?

The methods of payment for the returned deposit to consumers are yet to be confirmed, however one option is to return the deposit via an online payment system, such as paypal or similar. This would require the consumer to register their personal details, resulting in the storage of consumer data either via a third-party platform or via a directly managed system. In this instance, it would be the responsibility of the Scheme Administrator to ensure that consumer data was stored appropriately and securely as per regulation.

Q4. Does the policy increase opportunities for unscrupulous suppliers to target consumers?

Unscrupulous suppliers could place drinks on the Scottish marketplace without paying a deposit into the scheme. If consumers pay a deposit, they would lose this when the container was not accepted by automated or manual return point. The issue of fraud is discussed in the Full Business Case Stage 1 and mechanisms are presented in order to limit these potential impacts.

Q5. Does the policy impact the information available to consumers on either goods or services, or their rights in relation to these?


Q6. Does the policy affect routes for consumers to seek advice or raise complaints on consumer issues?




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