Frequently Asked Questions
We have compiled a comprehensive list of Frequently Asked Questions about Scotland’s Deposit Return Scheme, to help answer as many of your questions about the scheme as possible.
Drinks producers will be able to register with SEPA from 1 January 2022, and must re-apply each year by 1 March.
All producers will need to be registered by the time the scheme is fully operational for their products to be saleable in Scotland.
Producers will be able to appoint the scheme administrator to register with SEPA on your behalf.
SEPA will be the regulator for all offences under the Regulations and will have powers of investigation and enforcement to establish whether these have been complied with.
A range of enforcement tools will be made available to SEPA through amendments to the Environmental Regulation (Enforcement Measures) (Scotland) Order 2015, including the power to impose fixed or variable penalties for non-compliance, and to accept an enforcement undertaking. For more serious offences, SEPA can report the offence to the Procurator Fiscal, for prosecution through the court system.
The Scottish Environment Protection Agency is the regulator.
SEPA is the enforcement authority for the Deposit Return Scheme as set out in the Deposit and Return Scheme (Scotland) Regulations 2020 and will build on their experience of regulating schemes like the Producer Responsibility for packaging, waste electricals and batteries. Their duties include producing a public register of producers, publishing reports and statistics on the operation of the scheme and carrying out audits and inspection, ensuring compliance is non-negotiable.
SEPA has set up a mailbox for enquiries: firstname.lastname@example.org
SEPA will also publish more detailed guidance for producers, retailers and return points to help you meet your obligations.
SEPA’s powers will include the ability to:
· Enter onto commercial premises
· Carry out examination and investigation
· Make test purchases and returns
· Question staff of producers, return point operators, retailers or the scheme administrator
· Require documents and information (including digital records)
When you register you will need to provide:
contact details for your business, and a named contact person
If you register directly with SEPA (rather than through the Scheme Administrator) you will also need to submit an operational plan, outlining how you will meet your obligations.
The registration fee will vary according to the size of the businesses:
· For producers with an annual turnover of £85,000 or lower, there will be no registration fee
· For all other producers, the registration fee will be £360
No – there is no requirement for retailers to register with SEPA.
However the Scheme Administrator will need to keep an up to date list of all return points so that it can arrange for the collection of containers, reimbursement of deposits and payment of handling fees.
Zero Waste Scotland was tasked by the Scottish Government with advising on the design of Scotland’s Deposit Return Scheme, and is working with partners to provide support and advice on its implementation.
45 countries and territories around the world have deposit return schemes. These include: the Scandinavian countries (Norway, Denmark, Sweden, Finland) Germany, Estonia, Lithuania, some states in Australia (including Queensland and New South Wales) and some American states (including California, Connecticut and Hawaii), Netherlands, Iceland and provinces of Canada.
We want to make sure we have the best possible scheme for Scotland, reflecting its needs and unique characteristics. Scotland’s scheme is the result of intensive engagement and research with scheme operators around the world.
Deposit return schemes are used across the world as a way of encouraging more people to recycle drinks containers, such as bottles and cans. They work by charging anyone who buys a drink a small deposit for the bottle or can that it comes in. They get this money back when they return the bottle or can to a collection point to be recycled.
The scheme will go live for consumers on 1 July 2022. Parts of the regulations will come into force earlier to enable various scheme actors to prepare for the operation of the scheme.
All drinks (both soft and alcoholic) that come in PET plastic, metal and glass. Containers of these material types, sized from 50ml to three litres, inclusive, are part of the scheme.
All types of drinks will be included in the scheme, but some types of containers will not. Mixed material pouches, cartons, HDPE (the plastic that most bottles milk comes in) and cups are excluded. The exclusion of HDPE means that, in practice, very few dairy items will be included in the scheme.
The exclusion of HDPE means that, in practice, very few dairy items will be included in the scheme. However, milk or milk-related products contained in PET and glass bottles or cans will be included. As deposits only apply to single use containers, reusable glass milk bottle schemes will not be included in the scheme.
As part of the 2019-20 Scottish Budget, the Scottish Government signalled its agreement in principle to the use of charging in relation to disposable drinks cups.
The Expert Panel on Environmental Charging and other Measures published its recommendations in July 2019. The Scottish Government is currently considering these recommendations, which include a charge on single-use cups.
Deposit return schemes for drinks containers have been proven to work internationally. This is because the scheme can focus on a small number of material types which capture almost an entire market segment.
Schemes have resulted in increased quality collections and have also helped to reduce litter.
As drinks containers are used by almost everyone in Scotland, they provide an important opportunity to influence the behaviour of the entire population.
There will be opportunities to improve the recycling of other types of packaging through the Extended Producer Responsibility reforms, which have recently been consulted on by the UK government.
There will also be an opportunity to look at other materials in the future.
The Scottish Government has said it is open to the idea of adding further materials in the future, once the scheme has reached a “steady state” of operations.
Scotland’s Deposit Return Scheme will improve recycling rates and reduce litter in Scotland, as well as helping to tackle climate change. It will do this by incentivising a positive behaviour change and making it easy to do the right thing.
A deposit return scheme presents opportunities for economic benefit to Scotland, through reduced impacts of litter, increased material quality and carbon savings.
Recyclable materials are worth more money if they are well separated rather than mixed together. This also creates options for recycling the materials into higher quality new products.
A broad range of social and economic benefits have been identified through Zero Waste Scotland’s work on deposit return. We are working, together with other partners such as Scottish Enterprise, Highlands and Islands Enterprise, and Scottish Development International, to realise these benefits by providing compelling evidence to producers on why these should be adopted in Scotland.
Re-use is always the best option where possible and we would always encourage people to make use of re-use options wherever possible. There are a number of business drivers which influence the decision to adopt single use packaging. With hundreds of millions of single-use PET, glass, steel and aluminium drinks containers in circulation in Scotland, deposit return is the most effective and practical way to manage and reduce their environmental impact.
Scotland’s Deposit Return Scheme has been designed to:
More bottles and cans will be recycled and produce a better quality of recyclate. We currently recycle just half of all containers. By the third full year of operation, Scotland's Deposit Return Scheme will be capture nearly 2 billion drinks containers a year for recycling. That’s 90% of all containers included in the scheme.
It will increase the quality of recycled material collected and make better use of our existing resources. The scheme will also increase the number of items being recycled into items of the same use – for example, bottles being recycled back into bottles. This is a particular benefit to industry, which has an increasing demand for recycled content of high quality.
There is more information on our recycling page.
Scotland’s Deposit Return Scheme will reduce the harmful emissions that are contributing to the climate emergency by reducing the amount of plastic, steel, aluminium and glass that goes to landfill or incineration.
Recycling is more energy efficient than making new aluminium, glass or plastic. Scotland’s Deposit Return Scheme will reduce emissions by around 4 million tonnes of CO2eq (carbon dioxide equivalent) over 25 years.
Bottles and cans represent a significant proportion of the litter we see on our streets and in our green spaces. The wider impacts of litter cost our society and economy £361m. By incentivising people to do the right thing with their empty bottles and cans – return them for recycling – the scheme will reduce littering, potent.
To learn more, see our litter page.
The decision to include glass will contribute significantly to the overall aims of Scotland’s Deposit Return Scheme, not least by reducing our CO2eq emissions by more than 1.2 million tonnes over 25 years. We have set out the full rationale for including glass bottles here: Why glass bottles are in
Scotland’s Deposit Return Scheme is being introduced under legislation relating to powers which are devolved to Scotland.
A public consultation on proposals to establish a deposit return scheme for England, Wales and Northern Ireland ran from February to May 2019.
The UK government has said that the specific details, including the material and drinks to be included in scope, will be developed further and presented in a second consultation.
The Scottish Government is open to working with the other administrations on DRS. However, the Scottish Government has stated this must be on the basis that their level of ambition matches that being shown here in Scotland. We are hopeful that the bold approach we are taking here in Scotland will provide a blueprint for future action across the UK.
Following consultation with stakeholders and an independent review, the Scottish Government chose July 2022 as the earliest go-live date that would give high confidence of successful delivery. They chose to lay the regulations so that industry and consumers would have clarity on what the scheme will look like and be given a clear timetable for delivery. The timetable will also provide time for businesses to respond to the coronavirus pandemic and the Scottish Government will continue to monitor developments closely.
Circularity Scotland Ltd were appointed as the scheme administrator in March 2021. They are an industry-led, privately-owned body operating on a not-for-profit basis.
It will be for individual producers and retailers to meet their responsibilities under the scheme although it will be open to producers to appoint the scheme administrator to discharge their obligations on their behalf.
This is a similar approach to that taken by other deposit return schemes around the world. Deposit return is an example of extended producer responsibility, whereby producers are given a significant responsibility – financial and/or physical – for the treatment or disposal of post-consumer products.
Deposit return is a type of extended producer responsibility. Producers will be partly responsible for the costs of the scheme, which will likely be delivered through a body comprising relevant industry representatives.
Producers are companies who own any brand of drink, sold in Scotland, within containers included in the deposit return scheme. Financial contribution will be through a producer fee, charged on each container they place on the market. The level of the producer fee will be determined by the administrators of the scheme or the costs of delivering the service directly.
A privately-owned and operated scheme will give drinks producers direct control and accountability for the running of the scheme. Producers have a range of transferable skills and experience from their businesses that can help ensure the deposit return scheme is as effective and efficient as possible. This model is tried and tested across much of Europe, including Scandinavia, Eastern Europe and Germany.
It is anticipated that the scheme will be paid for through three sources of funding: unredeemed deposits, revenue from the sale of materials and any producer fees charged by the scheme administrator.
Importers have the same obligations under the Regulations as domestic producers.
Producers will have to make sure that they collect the deposit when selling scheme containers and then refund it once empty containers have been collected.
In all deposit return schemes that are currently operating there are some unreturned containers. The unredeemed deposits in the Scottish scheme will be used to fund the operation of the scheme.
It is unlikely every single scheme container will be returned. The target capture rate for the scheme is 90% which is significantly in excess of the current recycling rate for drinks containers. The regulations commit producers to achieve this in the third full year of operation.
The deposit return scheme will capture containers that are in scope. For other drinks containers, people will still be able to recycle these in kerbside and public recycling bins.
13 May 2020: Regulations passed by the Scottish Parliament
1 January 2022: producers can register with SEPA and start to place deposit-bearing containers on the market
1 July 2022: the scheme goes live for consumers. All drinks containers purchased by retailers for sale to a consumer in Scotland must bear a deposit and retailers who sell drinks must start acting as return points.
The bottles and cans collected by the scheme will be recycled. Deposit return won’t just increase the volume of materials recycled, it will also increase the quality of recycled material available in Scotland. Materials will be collected separately, which enables more of them to be recycled into items of the same use or quality. Deposit return promotes a circular economy for drinks containers, where the plastic, metal and glass collected can be used again in making new bottles and cans. This uses fewer natural resources and less energy.
The capture rate is the percentage of target containers captured by the deposit return scheme. The draft regulations set a target of capturing 90% of the items placed on the market in Scotland by year three.
There is a demand from reprocessors in Europe for the high-quality plastic and metal that comes outs of deposit return schemes and we are working to explore economic opportunities for Scotland.
On 30 October 2020, new planning rules came into effect that remove the need for planning permission for a reverse vending machine and associated structures, subject to certain criteria being met.
The criteria, which include things like the size and location of the RVM, were designed to be as inclusive as possible without adversely impacting the local environment.
You can learn more about the full criteria here.
Members of the Implementation Advisory Group are providing industry expertise and advice on practical issues related to the operation of the scheme and how it interacts with production, retail and hospitality industries.
Scotland's Deposit Return Scheme is a chance to dramatically increase the recycling rate for the more than 2 billion drinks containers included in the scheme. Making that happen will require the support and expertise of the people that produce and sell those drinks, and we’re pleased to have the involvement of representatives from across a range of sectors.
Deposit return schemes have already proven very successful abroad, and some of the organisations represented on this group have experience of operating in those markets. With so much evidence and expertise to draw on, we can make Scotland’s Deposit Return Scheme truly world leading.
The membership is designed to represent those groups that will have a legal obligation under the scheme.
The Scottish Government is clear that the deposit should not be subject to VAT. Discussions are ongoing with the UK Government to reach a final position on this matter.
We have produced a video guide to the scheme’s cashflow, which you can see on our cash flow page.
It’s important that the deposit is set at a level which is easy to remember and will incentivise people to do the right thing, if the scheme is to capture 90% of materials. 20p has been chosen for these reasons.
20p is a similar value to the level of deposit in successful schemes abroad and is in keeping with what people have told us they want to see – 20p was the mean level suggested by responses to the Scottish Government’s public consultation.
Not only will 20p give us the best chance of delivering our environmental goals, it will also make life easier for consumers.
The Scottish Government has published an Equality Impact Assessment and a Fairer Scotland Impact Assessment, which ensure potential impacts of the deposit have been considered as part of scheme design.
Producers, or the scheme administrator on their behalf, will be required to pay a reasonable handling fee charged by return point operators, reflecting the costs they have incurred.
The expectation is that the handling fee will be agreed by retailers and producers, likely through the scheme administrator.
From cutting our carbon emissions, to reducing the amount of litter on our streets, we want Scotland’s Deposit Return Scheme to deliver the maximum possible environmental benefits.
To make that happen, we need to give people a clear incentive to return all of their empty bottles and cans, regardless of their size.
A variable deposit would run the risk of giving the message that it’s more important to return some items than others.
Scotland is targeting a capture rate of 90% for all the materials included in the scheme. A deposit of 20p has been chosen because it will be most effective at making this happen.
Setting a single deposit is supported by best practice from international schemes and 20p is consistent with deposit levels set abroad.
It is also in keeping with what people have told us they want to see – 20p was the mean level suggested by responses to the Scottish Government’s public consultation.
Not only will 20p give us the best chance of delivering our environmental goals, it will also make life easier for consumers.
A producer is a drinks brand owner or importer into the UK market, or the website operator, for online sales.
The administrators of the scheme will be responsible for deciding on the most efficient and effective measures for minimising fraud and informing the consumer that containers are part of the deposit return scheme. This could include the adoption of specific on-pack labelling and/or a Scottish specific barcode. For more information, see Information for Producers.
Yes - including online retailers will make sure that the scheme is inclusive and accessible to all. This will be especially important for people that have restricted mobility, or anyone who relies on online grocers for their food shopping.
Online retailers will not act as a return point - they will have to offer a takeback service.
They will charge the 20p deposit on drinks in scheme containers and consumers will have the option to have scheme containers purchased online collected by or on behalf of the seller from the place they were delivered.
The retailer must provide this takeback service for free but may charge temporary fees. These temporary charges must not exceed the value of materials used in facilitating the collection e.g. cost of bags and tags.
Online, or other distance sellers, who wish to sell drinks in scheme containers to consumers in Scotland will have to comply with the scheme, regardless of where they are situated.
Bottles and cans should be empty. The bottle or can should be whole and the product barcode should be legible.
It will be an offence to sell a drink in a scheme container in Scotland if the producer of that drink is not registered with SEPA.
Retailers will require to check that the producer of that drink is registered with SEPA and will only be required to accept the return of scheme containers which can be identified as such. It is likely that producers will compile a register of these products to support the operation of the scheme.
Deposit return schemes incentivise maximising the quality of material, by using the income from selling that material to reduce the cost incurred by producers.
The correct collection approach will need to be decided for each material. For glass, the value is maximised by keeping different colours separate and allowing glass bottles to be recycled into new glass bottles. This also has the largest environmental benefits.
Yes – if you sell any of the materials covered by the scheme, then you must accept all materials included in the scheme when they are returned.
Retailers selling drinks in scheme containers to take away from their premises will automatically be required to operate a return point. There will be no registration requirement for these retailers.
Persons or bodies that would like to operate a return point from somewhere other than retail premises will need to apply to Scottish Ministers to be registered as a 'voluntary return point operator'.
Producers will be responsible for arranging collection of scheme containers from retailers acting as a return point and from voluntary return point operators. Producers may appoint a scheme administrator to collect material on their behalf.
All retailers that sell drinks in scheme containers to take away will be required to operate a return point. This will make sure that all consumers, wherever they live, are able to access a local return point, which will make it easy for people to return their empty scheme containers and ensure a high capture rate.
There will be flexibility in how this obligation is discharged. For example, a retailer could be granted an exemption from having to operate a return point from their premises if there is an alternative return point of equal convenience available nearby that has agreed to accept scheme containers on their behalf.
Applications for exemptions will be considered by Scottish Ministers.
Retailers offering distance (e.g. online) sales of scheme containers will have to offer free takeback services allowing the purchaser to return any scheme containers they have purchased from that retailer.
The drinks containers can be collected manually or through a reverse vending machine (RVM).
An RVM is a machine that scans containers when they are returned and enables the customer to get their deposit back. The returned materials are stored in the machine and are collected by the administrators of the scheme for recycling.
‘Manual return’ works by collecting containers in plastics bags or similar, which will then be collected by the scheme administrators.
It will be up to individual retailers to decide whether they wish to install a reverse vending machine or accept returns manually. However, there is no need to take any action at this stage – guidance will be provided by the administrators of the scheme.
With a reverse vending machine, the consumer puts their empty container into the machine. It will then verify that the container is deposit-bearing. It will redeem the consumer’s deposit, for example with a voucher, or a digital credit, for the correct deposit amount. The consumer can then use the voucher against their shopping bill or request their money back from the till.
For a manual return, a member of store staff has to check the container is eligible before refunding the consumer their deposit.
Producers will be responsible for arranging collection of containers from retailers who have acted as a return point.
It is expected they will fulfil this collectively, as a scheme administrator, and will register return points so that they can arrange an appropriate collection schedule.
This may be via dedicated collections or by utilising backhauling. Collection frequency will vary by return location depending on the storage space they have available.
Businesses can apply to Scottish Ministers for an exemption from acting as a return point. There are two different routes through which an exemption can be granted.
The first route is by getting agreement from another return-point operator to take back containers on your behalf. This might be a nearby store or voluntary return point established by someone other than a retailer.
You have to show that:
• this alternative return point is within reasonable proximity to your premises
• if the exemption is granted, this will still provide consumers with reasonable access to a return point.
The second route is to provide evidence to satisfy Ministers that there is no reasonable way for you to operate a return point on your premises without risking being in breach of relevant legal obligations such as food safety.
Exemption applications will be accepted from January 2021. The Scottish Government worked with representatives of the retail sector and other relevant stakeholders to develop guidelines to support businesses in making an application.
Zero Waste Scotland does not sell or provide advice on reverse vending machines. There are several commercial manufacturers. Advice will be provided by the administrators of the scheme.
If you sell any drinks for consumption off-site, you will have to charge the deposit to your customers and operate a return point. To find out more, please visit our Hospitality page.
Vending machines will have to sell items that are deposit bearing and have the deposit clearly displayed, separate from the sale price.
Organisations and businesses that have a vending machine only and don’t have a shop selling singe use drinks to take away, do not have to act as a return point for containers.
Businesses that sell drinks exclusively be opened and consumed on-site, including many pubs, bars and restaurants, will not have to charge the deposit to the public and will only be required to return the containers they sell on their own premises.
As a result, while pubs, bars and restaurants are included in the scheme, their interaction with their customers will remain largely unchanged.
When buying stock, for example from a wholesaler, these businesses will pay the 20p deposit on those items in the same way that shops will. These deposits will be refunded after the containers are picked up, free of charge, for recycling.
Visit our hospitality page for more.
Community organisations, such as schools, will have the opportunity to act as return points for empty containers.
Communities will also benefit from less litter, and the collective benefits of tackling climate change.
Consumers could choose to donate their deposit to a charity or good cause. Based on the experience of other international schemes, this may be facilitated by the administrators of the scheme and return points.
Decisions on any charities or community groups to be registered to receive donations will be a matter for consideration by the administrators of the scheme. One of the main ways we have seen charities and community groups benefiting abroad is by donations.
We would encourage interested charities and community groups to engage with the scheme once a scheme administrator is in place.
The Scottish Government has established an Implementation Advisory Group to provide expertise and advice on the implementation of the scheme.
You may be represented through your membership of one of the bodies listed below - if so, it's best to put your questions through them.
Find out more here.
Zero Waste Scotland’s online content hub will be updated in the coming weeks and monthsis regularly updated with relevant news and information.
You can also sign up to our newsletter below to receive updates on the deposit return scheme.
If you have questions relating to the regulation of the scheme, you can contact SEPA via email@example.com
The scheme has been designed to be as accessible as possible. That’s why all places that sell drinks to take away, including online retailers, are included. If you buy your food shop online, the retailer will collect your empty containers and return your deposit.
The scheme has been designed to be inclusive to people in all communities, by ensuring it is as easy to return a scheme drinks container as it is to buy one.
Consumers will be able to return their empty scheme containers to wherever they purchased them from (or an equally accessible equivalent), and online retailers will be obliged to offer a takeback service.
This means that people living on Scotland’s islands and in remote communities will be able to participate in the scheme easily and will be able to get their deposit back however they get their shopping.
The Scottish Government has undertaken an Islands Communities Impact Assessment. This looks at any challenges that will be unique to Scotland's islands and sets out measures to mitigate against them.
Before the launch of the public consultation on 27th June 2018, Zero Waste Scotland undertook a full programme of engagement with key stakeholder and representative bodies for trade, industry, manufacturers, retailers, and local authority groups.
These activities included a one-day stakeholder event, key stakeholder groups, 1-1 interviews, gathering of written evidence, and a programme of communications including a stakeholder newsletter.
During the consultation phase, we heavily promoted the opportunity to input to all stakeholders, via all our communications channels and nationwide programme of engagement, with events in all 32 local authorities. We continue to engage with all of the key groups and parties interested in a deposit return scheme.
We also provide regular updates through our online hub, depositreturn.scot, and our newsletter, which you can sign up to below.
Scotland’s Deposit Return Scheme will mean that local authorities will have less waste to handle, as well as reducing risk of contamination in collections, due to single-use drinks containers being collected through retailers.
The scheme will also mean less litter, which is good for residents and council budgets.
Local authorities stand to make savings from reduced litter clean-up costs for which they are currently responsible for in many of our public areas. There will be further benefit to local areas in terms of reducing the indirect costs associated with litter, such as negative impact on house prices, community well-being and tourism.
If a local authority-run facility, such as a school, sell drinks to take away, they will be considered a return point.