Deposit return scheme for Scotland: SEA

This strategic environmental assessment (SEA) post adoption statement details the environmental considerations that have gone into the design of the deposit return scheme for Scotland.

4. How opinions expressed on the consultation have been taken into account

4.1 Overview

4.1.1 Consultation lies at the heart of any meaningful assessment or appraisal process and is based on the key principle that plan and programme making is better where it is transparent, inclusive and uses information that has been subject to public scrutiny.  In this context Zero Waste Scotland, at the direction of the Scottish Government, has sought to ensure that those with an interest in, or who are affected by, the DRS should have the opportunity to present their views on the consultation documentation. 

4.2 Public Consultation

4.2.1 Public consultation was held, from 27 June 2018 to 25 September 2018[18] to obtain the opinion of individuals and organisations on the proposed scheme, the design of any DRS and the options considered and the possible impacts of such a scheme.  Views were obtained through the completion of a 54 question questionnaire (which was also embedded within the DRS consultation document[19]).  The consultation documentation also included the Environmental Report along with a Partial Business Regulatory Impact Assessment, a Scottish Firms Impact Test, an Equality Impact Assessment, a Strategic Outline Case and an Outline Business Case.

4.2.2 A detailed analysis and response to the completed public consultation on DRS was published by Scottish Government in a separate document (21 February 2019).  This section of the PAS addresses those elements of the public consultation which specifically pertain to environmental issues. 

4.3 Consultation on the Environmental Report

4.3.1 The Environmental Report was published to accompany the public consultation documentation on DRS.  To direct consultee responses, the Environmental Report included five questions concerning baseline information presented, the assessment findings, proposals for mitigation and for monitoring.

4.3.2 Consultation responses to the Environmental Report were received from the three statutory consultees (SEPA, SNH and HES):

  • SEPA stated that it was “content with the adequacy and accuracy of the ER. With regard to the topics within our remit we welcome the clarity with which the potential effects of all the alternatives have been presented in the ER, together with mitigation measures and discussion of interrelated effects with potential changes in other policy areas which may occur over the lifetime of the scheme.”
  • SNH stated that it “agrees with the conclusion of the Environmental Report.  We welcome the amendments made to the assessment which address our concerns as set out in the scoping report. Firstly, we note that Biodiversity, Fauna and Flora has been scoped into the assessment. We are also content with the updated overview of the relevant plans, programmes and strategies (PPS).”  SNH also highlighted a number of instances where it was important to ensure consistency between the detailed assessment and its summary.
  • HES stated that they “agree with the findings of the assessment in relation to the historic environment.”

4.3.3 In addition, responses to the public consultation document were analysed for content relevant to the SEA. A total of 714 responses to individual questions were identified.

4.3.4 Approximately 90% of responses were from individuals, with the remainder from organisations, including:

  • public sector organisations;
  • food and drink producers;
  • environmental, conservation, food and health charities;
  • recycling and waste management organisations;
  • packaging manufacturers;
  • environmental consultancies;

4.3.5 The main opportunities identified by respondents are summarised as follows:

  • 96%[20] of respondents who referenced litter expect that the DRS will have a positive impact upon litter; 
  • 92% of respondents who referenced biodiversity expect a positive impact upon biodiversity;
  • 90% of respondents who referenced landscape and townscape expect a positive impact upon landscape and townscape;
  • 74% of respondents who referenced climate change expect that a DRS will provide a positive impact upon Scotland’s efforts toward mitigating climate change;
  • 82.5% of respondents who referenced the quality of materials collected expect that the DRS will provide better quality materials;
  • 9% of respondents who provided SEA related comments believe a DRS will provide opportunities for Scotland to showcase the achievements of a DRS and our wider environmental efforts;
  • 8% of respondents who provided SEA related comments stated that a DRS will provide an opportunity to develop greater awareness of waste and environmental issues in Scotland;
  • 4% of respondents who provided SEA related comments expect that a DRS will catalyse investment and improvement in reprocessing equipment to provide high quality materials;
  • 3% of respondents who referenced packaging believe that the DRS will provide an opportunity to develop innovative, sustainable solutions;
  • 3% of respondents referenced the circular economy and believe the DRS will be an excellent opportunity to support Scotland’s efforts to instil a circular economy.

4.3.6 The main risks of concern which could jeopardise a DRS, by number of respondents, were:

  • 11% of respondents who provided SEA related comments expressed concern that low participation in the scheme could risk jeopardising the DRS
  • 11% of respondents who provided SEA related comments highlighted that limited accessibility to facilities could risk the success of the DRS.

4.3.7 The main recommendations proposed by respondents include:

  • 21% of respondents who provided recommendations relevant to the SEA suggest that educating users on how to use the DRS, and highlighting the benefits of the DRS, could maximise opportunities;
  • 11% of respondents who provided recommendations relevant to the SEA suggest that the operator should ensure easy access / ease of use to maximise opportunities;
  • 8% of respondents who provided recommendations relevant to the SEA suggest that the DRS should be a UK wide initiative;
  • 7% of respondents who provided recommendations relevant to the SEA suggest enforcement practices such as fines, laws etc. should be introduced for public and/or organisations to ensure participation in the DRS;
  • 4% of respondents who provided recommendations relevant to the SEA suggest that any DRS operator should work with local authorities to utilise available fleet, staff and infrastructure.

Responding to the Consultation

4.3.8 The high number of responses to the DRS consultation is welcomed by the Scottish Government.  It is evident that DRS is a topic that has attracted considerable public interest and that overall, the majority of respondents appear to view a DRS as offering a positive opportunity for Scotland’s environment.  In particular, a high proportion of respondents identified a DRS as having positive effects on litter, material quality, waste targets, biodiversity, landscape and climate change.  This corroborates other assessments and extensive modelling work undertaken.

4.3.9 The SEA consultation process confirmed that maximising participation in, and accessibility to, the DRS system will be critical to ensuring the greatest possible material capture rate and associated environmental benefits.  The issue of ensuring participation and accessibility have been taken into account in developing the preferred option, as summarised in Table 4.1.

Table 4.1: Mitigating Risk to Scheme Performance 


Proposed mitigation effort

Low Participation

  • The risk of low participation will be mitigated by ensuring the system is convenient to use (adopting a return to retail model with national coverage) and has a sufficiently compelling deposit level; both of which are associated with higher performing schemes elsewhere.
  • Consumer communications will also enhance understanding of how to use the system, particularly at launch, and a further advantage of a return to retail model is that it is highly visible for consumers both in terms of communicating recycling messages and visibly demonstrating participation by fellow citizens.


  • Accessibility concerns will be mitigated by ensuring convenience for users through the adoption of a return to retail model with national coverage. This model will include on-line retailers.
  • They will be addressed by considering placement of return points to minimise access issues, for example by avoiding steps at access points or ensuring automated return points have apertures at suitable heights.

4.3.10 Respondents to the consultation made a series of recommendations.  The Scottish Government has chosen a DRS model that aligns with these recommendations.  Adopting a return to retail model with national coverage and an appropriate deposit level, covering a range of materials and supported by consumer information, will ensure recommendations made in terms of scheme information, access, coverage and regulation are addressed.  This is also detailed in Section 5.1.



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