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Getting Ready for Scotland’s Deposit Return Scheme

Scotland will soon be the first part of the UK to introduce a deposit return scheme for drinks containers. This will change the way we recycle. 

Scotland’s Deposit Return Scheme will make it easier for everyone to recycle their used bottles and cans. This will help in the fight against climate change. 

Hospitality businesses, like restaurants, bars, cafes and hotels sell millions of bottles and cans each year. These businesses will have a key role to play. The scheme will go live on 1 July 2022. 

Businesses that sell drinks to take away (cafés and takeaways) and those that sell drinks to be consumed on-site only (pubs and restaurants) will have different obligations.

If you sell any drinks for off-site consumption, you will have to charge the deposit to your customers on those drinks, and operate a return point (please refer to Businesses that sell drinks to take away). 

On-site consumption

On-site consumption is when a drink is sold with the intention that it is consumed on the premises. 

Bottles and cans

Containers

All drinks producers must register with SEPA, who will publish a list on who is part of the scheme. 

All products sold in scheme containers in Scotland are included, regardless of where they are bottled or produced. 

All drinks – soft and alcoholic – are included in the scheme if they come in the following materials:

  • PET plastic – e.g. most bottled water and many fizzy drinks
  • Steel and aluminium – e.g. many fizzy drinks and canned beers
  • Glass – e.g. bottles of wine or premium soft drinks

Containers between 50ml and 3 litres in size are included in the scheme.

Any milk or milk-related products which come in cans, PET or glass bottles will be included.

Deposits only apply to single-use containers, so re-usable glass milk bottle schemes will not be included.

Handling Fee

All businesses acting as a return point will receive a handling fee to cover the costs of participating in the scheme. If you sell drinks to take away, you will receive the full handling fee.

When selling drinks for on-site consumption, the handling fee will be limited to the cost of materials used for collection and storage of containers at the return point. For hospitality businesses that sell drinks exclusively for consumption on-site, the fee will only cover any additional costs associated with participation in the scheme.

As these businesses already handle drinks containers, this will be the cost of materials used for collection and storage of containers at return point. This means a likely saving on waste collection costs for these businesses. In the case of a retailer providing a takeback service, they will receive a handling fee which covers the delivery costs associated with return of packaging.

The expectation is that the handling fee will be agreed by retailers and producers through a scheme administrator.

Collections

The scheme administrator(s) will be responsible for collecting empty containers for recycling form all return points and on-site consumption businesses. This will be done free of charge: a saving for those businesses currently paying for the removal of containers by waste management companies.

 

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Selling drinks to take away

Businesses that sell drinks to take away must charge the 20p deposit. All businesses selling drinks in scheme containers to be taken away will need to operate a return point.

The customer gets the 20p deposit back when they return the empty container to the place they bought it, or to another return point.

All businesses selling drinks in scheme containers to be taken away will need to operate a return point. This obligation applies to each store. So if you have multiple outlets, all of them must act as a return point.

As a return point you must:

  • Accept scheme containers returned by consumers
  • Redeem the deposit for each container returned. This will be reimbursed by the scheme administrator in addition to receiving a handling fee
  • Keep the packaging for collection by a producer or scheme administrator. Bags or storage will be provided or costs of these will be covered by the handling fee. 
  • Provide: a complaints procedure; the contact details for making complaints; and the contact details for SEPA

It is also likely that return points will have to register with administrators of the scheme.

Retailers will be able to refuse to accept an empty bottle or can if:

  • It is not identifiable as scheme packaging
  • It is soiled
  • It is not intact
  • It is not empty
  • The scheme administrator has not carried out a collection in accordance with their operational plan
  • It is a single proposed return by a consumer that is disproportionate to the number of containers sold in an average single transaction

 

Collecting the bottles and cans

You have two options for collecting containers for the public.

1. Manual return

The public hand over empty containers at the counter and you issue a cash refund. You store the empty containers until they are collected. All deposits you pay out will be reimbursed by the scheme administrator. 

2. Reverse Vending Machines (RVMs)

People put their empty bottle or can in the machine and get the 20p deposit back. RVMs normally give out a voucher that can be used against the value of purchases, or to claim a cash refund at the till. All deposits you pay out will be reimbursed by the scheme administrator. 

If you decide to get an RVM for a store or return point, there are a range of manufacturers to choose from.

 

Cash flow

The flow of deposits is cost-neutral. This is how they flow through the scheme.  

  • You pay 20p deposit on every item of stock you buy from a wholesaler or drinks producer
  • You receive 20p from customers when they buy a drink in your premises
  • You pay 20p to people when they bring an empty container to your store 
  • You receive 20p from the scheme administrator for every bottle or can that you collect

 

Pricing and customer information

You must:

  • Ensure all in-scope containers the deposit charged on them
  • Make it clear the container is part of the scheme
  • Display the deposit value separately from the product price 
  • Display information about how to redeem the deposit

 

Exemptions

You can apply to Scottish Ministers for an exemption from acting as a return point.  

Retailers can apply to Scottish Ministers for an exemption from acting as a return point. Hospitality outlets that sell drinks exclusively for on-site consumption and duty free shops are automatically exempt. 

There are two criteria which must be satisfied for any retailer to be granted an exemption. This is to ensure the core principle of accessibility in all local areas in maintained: 

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 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. 

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On-site

If you sell drinks for consumption on-site, for example in a bar or restaurant, you will be able to choose whether to charge the 20p deposit or not. This is because the container is not expected to leave the premises.

However, if you sell any in-scope drinks to be taken away, you will be required to charge a deposit and operate a return point.

No return point

If you sell only drinks for consumption on-site, you don’t have to operate as a general return point for scheme containers.

You will have to return the containers you’ve sold on-site to the scheme administrator for recycling. As such, you’ll pay the 20p container deposit to the retailer or wholesaler, which you get back from the scheme administrator when you return the containers.

Businesses selling drinks to be consumed on site that do not apply a deposit will not be expected to receive returns from outside their own business. 

However, if you sell any in-scope drinks to be taken away, you will be required to charge a deposit and operate a return point.

Cash flow

The flow of deposits is cost-neutral. This is how they flow through the scheme:

  • You pay 20p deposit on every item of stock that you buy from a wholesaler or drinks producer
  • You receive 20p from the scheme administrator for every bottle or can that you return

Because you won’t be passing the deposit on to your customers, you will be responsible for collecting the empty bottles and cans from within your premises. 

Handling fee 

All businesses acting as a return point will receive a handling fee to cover the costs of participating in the scheme. If you sell drinks to take away, you will receive the full handling fee. When selling drinks for on-site consumption, the handling fee will be limited to the cost of materials used for collection and storage of containers at the return point. 

The expectation is that the handling fee will be agreed by retailers and producers through a scheme administrator. Businesses will not be paid for staff time and storage because they already handle and store these containers. The handling fee covers only additional costs, e.g. consumables.

All deposits you pay out will be reimbursed by the scheme administrator.

Collections

The scheme administrator(s) will be responsible for collecting empty containers for recycling. This will be done free of charge: a saving for those businesses currently paying for the removal of containers by waste management companies.

Small Bakers Briefing

If you own or run a bakery in Scotland, deposit return will also apply to you.

Old stock

During the initial period of the scheme, it is anticipated that shops will have some stock that was purchased before the go-live date. If this applies to your products, you can sell them as normal.
    
However, it must be clearly shown at point of purchase that these are not part of the scheme and cannot be exchanged for a deposit.

It’s your responsibility to:

  • Display the deposit clearly, highlighting which of your items are part of the scheme 
  • Display the deposit value separately from the product price

Have a question?

Go to Frequently Asked Questions

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