Deposit and Return Scheme for Scotland Regulations 2020 (as amended): Fairer Scotland Duty assessment
Fairer Scotland Duty Assessment (FSDA) for The Deposit and Return Scheme for Scotland Regulations 2020 (as amended by the Deposit Return Scheme (DRS) for Scotland Amendment Regulations 2025) and the Deposit and Return Scheme for Scotland (Designation of Scheme Administrator) Order 2025.
Summary of assessment findings and mitigations
65. Based on the evidence gathered, the introduction of a DRS has the potential to impact on those experiencing socio-economic disadvantage. The designated SA will establish the necessary collection infrastructure to ensure maximum participation in the scheme. This includes ensuring sufficient provision of return points.
66. However, the designated SA must carry out a review of the operation of all return points in Scotland once established, including:
a. the number of return points,
b. the location of the return points, and in particular whether consumers have reasonable access to at least one return point,
c. whether there is sufficient access to return points for persons living in villages and rural and areas and on islands.
67. The proposed SA candidate for DRS in Scotland, UK Deposit Management Organisation Limited, has committed in its application to continuous improvement in ensuring equality of access of the DRS.
68. The SA candidate has pledged to provide a DRS that has sufficient coverage for consumers in both urban and rural areas whilst ensuring its network is efficient.
69. The SA candidate will also consider encouraging community collection points which could provide accessible locations for returns and increase return rates for consumers, particularly in rural areas. These have proved popular with consumers taking part in the scheme in the Republic of Ireland.
70. Non-retail spaces will also be able to register with the SA to be able to act as voluntary return points. For example, hospitality venues, food-to-go stores, schools and community centres can choose to host a return point.
71. 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 a large RVM.
72. A clear communications campaign will be key to ensure that consumers understand the benefits of DRS and can fully participate in the scheme. The SA candidate has committed to launching targeted public awareness campaigns to educate consumers on the location of return points, and how to engage with the scheme to obtain a refund of deposits.
73. The Scottish Environment Protection Agency (SEPA) – the environmental regulator - will monitor the designated SA’s compliance with obligations as set out in the DRS regulations. The SA will submit operational plans, detailing how they plan to manage the scheme. This includes reviewing the return point network, the collection of drinks containers, and ensuring it meets collection targets amongst other regulatory obligations.
74. This combination of mitigations should minimise the impact of DRS on specific groups of consumers who experience socio-economic disadvantage.
75. Scottish Ministers are clear that DRS should deliver maximum economic and societal benefits for Scotland. An efficient and well-used DRS will deliver an aggregated and high-quality feedstock of recyclate, offering the potential to bring investment in the required infrastructure to deliver the scheme.
76. It should be noted that there is a potential overlap between those with protected characteristics considered within the EQIA[50] who are also experiencing socio-economic disadvantage. This can result in individuals experiencing cumulative impacts from the planned policy proposal. [51]