Deposit and Return Scheme for Scotland Regulations 2020 (as amended): island communities impact assessment

Impacts which may be potentially significantly different for island communities

51. The following issues were considered to have the potential to have different impacts for island communities, and are a combination of positive and negative impacts.

52. The issues identified were:

i. Transport and storage

ii. Waste management and litter cleansing

iii. Transient populations

Impacts on transport and storage

53. Groceries retailers will be required to act as return points, unless they have applied for, and have been granted an exemption by the SA. Other types of organisations that sell scheme articles, for example hospitality venues, food to go stores and mobile caterers, will not be required to host a return point, but will be able to apply to host a voluntary return point, as will premises that do not sell scheme articles. ^[22]

54. The impact on transport capacity was a unique island impact identified in the screening assessment and transport was a recurring theme in previous engagement events.

55. These issues are explored in more detail below.

i. Transport and storage

56. Transport and storage of DRS materials were identified as having a potential differential impact for island communities.

57. The 2020 ICIA undertaken for the introduction of a DRS in Scotland highlighted that ferry capacity was restricted on a small number of routes.^[23] Island councils depend on ferry transportation for inter-island and island-mainland transfers of waste. Cancellations or changes to ferry schedules, and variable availability of capacity due to competing demands from the tourism and fisheries sectors, are key challenges.

58. DRS collection targets increase to 90% in year 3 of the scheme. Any increase in collection quantities of targeted waste streams could have implications for the carefully calibrated and already challenging operational and logistical arrangements. Therefore, the impacts of the proposed reforms may place additional pressures on space availability on ferries.

59. Combined pressures arising from upcoming policy changes are likely to increase the need for storage of separated waste streams and potentially for longer durations when ferry capacity is limited. This may be exacerbated during times of year when other cargoes are prioritised over waste (disruption, seasonal availability, prioritisation of perishable goods). ^[24] Some of these impacts have been felt already from regulatory requirements for segregated storage of householder DIY waste and waste containing persistent organic pollutants (POPs), which include many waste electrical and electronic equipment (WEEE) items, adding to the competing demands on space in house waste recycling centres (HWRCs) and transfer stations.

60. As transport and storage of collected scheme materials is the responsibility of the SA, they will need to work with island local authorities and service providers to ensure efficient services are maintained.

61. The introduction of DRS will change the way the materials are transported (collecting scheme packaging in a different way to current arrangements) and will separate more material for recycling (as target materials will be collected apart from the wider waste stream).

62. Previous ICIA research^[25] identified that there are unlikely to be any specific requirements for containers to be on a particular sailing, as they are not fresh produce or components within a complex supply chain.

63. The specific arrangements for the transport of material will be an operational matter for the SA to agree with ferry operators. Consideration must also be given to the requirement of collected materials to be stored until off island transport can be arranged which may require additional infrastructure.

64. The SA will also need to work with local authorities and/or other relevant waste management providers to consider wider implications of the scheme on ferry routes.

65. It is not anticipated that this policy will directly exacerbate the transport issues faced by island communities. However, future service design should be mindful of transport capacity, to ensure that there are not unintended consequences for island authorities.

ii. Waste management and litter cleansing

66. In 2024^[26], across Scotland 87% of people agreed that litter is a problem, with 43% believing that litter in general has increased in their local area in the past year. The most common types of litter identified by those surveyed were food containers (71% of respondents), plastic drinks bottles (66%), cigarette buts (65%), and drinks cans (63%).

67. Keep Scotland Beautiful Local Environmental Audit and Management System (LEAMS) for 2023/24 identified drinks related containers as the second most commonly littered items (12.6%) after smoking related items (46%).^[27]

68. All of the islands’ local authorities currently collect scheme packaging for recycling via kerbside collections. These materials are exported from the islands for reprocessing.^[28] DRS will remove a significant number of these materials, made from PET or aluminium/tin from kerbside collections and bring banks. This could result in a loss of revenue for these items. However, research suggests that local authority recycling services run at a loss.^[29]

69. Benefits of DRS include a likely reduction in littering of single-use drinks containers and a reduction in waste and recyclate disposal costs for local authorities.

70. A Scottish Islands Survey identified that littering varies by island. Shetland Outer Islands are most likely to report that their local area is clean and litter free (73%) while Arran, Bute and the Cumbraes are the least likely to be surveyed as litter free (53%).^[30]

71. Marine litter is an enormous challenge for island communities, and many are taking action by campaigning for change and carrying out regular beach cleans.

72. A recent study by Marine Scotland suggests that more than 90% of plastic in Scottish seas comes from Scottish littering on land. Scottish littering puts about 1,000 tonnes of macro plastic into Scottish seas each year (uncertainty range 700 to 2,500 tonnes).^[31] Island communities may be disproportionately impacted by beach litter, because a significant proportion of the population lives close to beaches, and beaches are an attraction for tourists, who contribute to the local economy. There are potential impacts on health and well-being, as well as wider considerations for the economy, biodiversity and the local environment.

73. The Scottish Islands Federation (SIF) in partnership with the Marine Conservation Society carry out beach surveys to monitor marine litter. In 2023 they identified plastic as the most abundant litter material found on each island group, and on the islands overall (99.7% of all items). This is 17% higher than figures reported from mainland surveys. ^[32]

74. While almost half of the marine litter arising on islands is from fishing, 25% of the litter surveyed was attributed to public sources.^[33] The items recorded include PET bottles, bottle caps and cans.

75. The environment and wildlife are significant drivers in attracting visitors to Scottish Islands, who want to enjoy an unspoilt landscape and coast. The presence of litter has an impact on their enjoyment of this environment, and therefore any reduction in litter could have positive impacts in attracting more tourists and spending for local businesses^[34].

76. The introduction of DRS will have significant benefits in reducing littering of scheme drinks containers. DRS has received widespread support from environmental organisations because of the expected impact on litter reduction.

77. DRS is likely to bring a positive overall impact to island communities, with reduced costs to local authorities and a reduction in littering. Therefore, no further exploration of waste management and litter cleaning costs is required.

iii. Transient Populations

78. For most island communities, transient populations are linked to tourism and an increased number of visitors during summer months. However, other specific events can impact upon island populations (for example, the Tiree Music Festival, where the number of attendees is three times the population of the island). Information published by Visit Scotland shows the number of tourists by local authority area.^[35]

79. Feedback from stakeholders during previous consultation exercises, indicated that many island visitors bring drinks containers onto the islands. The result is that a higher number of drinks containers are likely to be disposed of on islands, than are actually purchased there.

80. A challenge identified in previous engagement events is that the amount of scheme packaging likely to be returned to groceries retailers during seasonal peaks would significantly exceed the volumes being sold. This could create challenges for local retailers, both in terms of storage of scheme packaging and cash-flow issues related to refunding deposits.

81. This is a particularly significant impact for those islands where there is only one retailer.

82. DRS regulations allow for the establishment of voluntary return points, and it may be reasonable to assume that these will be provided in areas where demand will be high, as they benefit the host business through increased footfall.^[36]

83. It will be the responsibility of the SA to ensure materials are captured to meet the collection targets and to establish suitable return point network across the islands.

84. A large proportion of visitors to the Scottish islands are domestic visitors (from the UK).^[37] Alignment of the DRS scheme across England and Northern Ireland will allow for better understanding of the scheme and support uptake.

85. Provided there is a suitable return point network across island communities, it is not expected that transient populations will have a significantly different impact to impacts experienced in other parts of Scotland.