67. The Scottish Government has identified four investment objectives to be delivered by the introduction of DRS:
(i) Improving recycling quantity;
(ii) Improving recycling quality;
(iii) Encouraging wider behaviour change around materials;
(iv) Delivering maximum economic and societal benefit for Scotland during the transition to a low carbon world.
68. Scottish Ministers are clear that these objectives must be delivered for the whole country, including rural areas and the islands, and the scheme has been designed with this in mind.
69. Some of the key elements of the policy design are there to ensure this is realised. These include:
- An obligation on all retailers to act as a return point, to ensure return points are accessible across Scotland and not just in major population centres;
- A requirement on producers to arrange a collection of containers from retailers, free of charge, to ensure that retailers in rural locations do not incur costs associated with transporting materials for recycling;
- A 90% collection target, delivering a high-performing scheme that maximises performance across the country and engages all of our communities;
- The ability to establish voluntary return points, to provide capacity in circumstances where the number of containers being returned in an area exceeds the retail return point capacity;
- Flexibility in the operation of take-back services so as to ensure that distance sellers continue to provide deliveries to island communities;
- Passing the cost of transporting collected scheme packaging from local councils to producers, as a form of extended producer responsibility.
70. The process of completing this Islands Communities Impact Assessment has supported the further ‘island-proofing’ of the policy. Engagement with over 150 individuals and organisations from island communities across Scotland identified three impacts that were significantly different:
ii. Distance sales take-back
iii. Transient populations
71. Consideration has been given to each of these impacts and, where necessary, additional mitigations have been incorporated into the Regulations to establish the scheme.
72. Further, in order for a producer to be registered or a scheme administrator to be approved as part of the scheme, they must supply an operational plan detailing how they intend to meet their legal obligations. This includes how they intend to meet their obligations to collect scheme packaging from all return points and other relevant retailers, including those located on islands. Approval or registration can only be granted if their operational plan details how they intend to comply with this obligation.
73. Through the combination of these measures, we are confident that the policy does not only look to accommodate islands communities but is optimised for them. The overall impact will be significantly positive, supporting the development of a circular economy, acting to address the climate crisis, and preventing litter and plastic pollution escaping into our natural environment.