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 evidence
30. The proposed DRS is intended to apply across Scotland and does not specifically target particular groups, geographical locations or sections of society. It is, however, important to ensure that the impact on those who experience socio-economic disadvantage is considered. This may be experienced through low income, low wealth, material deprivation, area deprivation or socio-economic background.
31. The Business Regulatory Impact Assessment (BRIA)[15], Equalities Impact Assessment (EQIA)[16] and an Island Communities Impact Assessment (ICIA)[17], have been updated alongside this Fairer Scotland Duty Assessment (FSDA) to reflect proposed changes to the current DRS legislation.[18] The socio-economic outcomes considered in this assessment have links with the potential impacts identified in the EQIA and the ICIA. This document should be read in conjunction with the other impact assessments.
32. The possible impacts of the introduction of a DRS on lower-income households have been assessed based on the available evidence.
33. The introduction of a DRS will result in new associated fees and/or costs for producers and retailers. It is assumed these costs, in whole or in part, will be passed on to the consumer in the retail price of the goods.
34. It is the SA’s responsibility to set the producer registration fee, which will be reflective of the costs faced and their revenue streams of unredeemed deposits and material revenue. The recently launched Republic of Ireland scheme ‘Re-Turn’ has published producer registration fees of €0.0125 per can and €0.02 per PET container. Once converted to GBP, and estimating an 83% pass through rate, this could result in £0.009 and £0.014 per can and PET container respectively, above the cost of the redeemable deposit. [19]
35. The 2019 FSDA[20] included a basic table laying out the likely scale of additional outlay faced by individuals based on the 2020 DRS policy. That scheme design included glass containers and assumed a 20p deposit rate.
36. The removal of glass and the increased minimum size threshold in the DRS legislation mean fewer drinks will now be sold with a deposit. This reduces the initial outlay consumers will be required to make, although this change will predominantly affect households buying glass drinks containers.
37. The SA will determine the deposit level, and while this could be higher than 20p, it could also opt for a lower deposit for smaller containers specifically and/ or for containers sold in multi-packs. This would change the initial outlay required and benefit households buying drinks in these formats.
38. It is worth noting that since 2019, inflation has increased since the cost of food and drink. A 20p deposit, would represent a smaller proportion of the weekly grocery shop than was estimated in 2019.[21]
39. The 2019 analysis, suggested that DRS would result in an initial additional outlay of around £1.40 for those individuals falling within the lowest 10% household income group, rising to approximately £1.80 for the second lowest household income decile (as defined by the Office for National Statistics). While this money can be reclaimed, it may be spent on servicing further deposits and so cannot be redirected to other priorities.
40. This forecast assumed that there is high public participation in the DRS and acknowledges it will be more expensive for customers who choose not to, or cannot, redeem their deposits.