Return point exemptions

The application process for return point exemptions has been brought in line with updated guidance issued by the Scottish Government on 3rd November 2022.

The updated guidance is available here.

There are two types of return point exemptions applications available: proximity and environmental health.

Proximity exemption: this is relevant if your business has an agreement with another nearby return point to take back containers on your behalf, it is easily accessible, and it is open at similar times to you.

Environmental health exemption: if you can demonstrate that operating a return point put your business in breach of other legislation, such as environmental health, food or fire safety.

The updated guidance and support includes:

1. A new Return Point Mapping & Exemption Support service for retailers to list themselves as a return point, identify alternative return points, and to remove the requirement to share commercially sensitive information with other retailers. As the data increases, retailers will start to get matches with Alternate Return Points (ARP) which they can use when making a proximity exemption application.

2. Based on retailers’ feedback, the environmental health exemption application now focuses on a premise’s internal footprint. A retailer is likely to be approved for an environmental health exemption if the footprint of their premises is 100m2 or less, or if they are a food-to-go retailer and the footprint of their premises is 280m2 or less and operating as a return point would put them in breach of their environmental health obligations. 

3. A streamlined evidence and assessment process that better takes into account the challenges facing specialist, food service, and hospitality retailers. This should also speed up the decision-making process for Scottish Ministers and provide clarity to retailers on the outcome of their application.

The exemptions service launched in January 2021 and is administered by Zero Waste Scotland which facilitates applications and provides guidance on the exemptions process to Scottish Government.

Zero Waste Scotland has supported the Scottish Government on the design of the deposit return scheme, provides ongoing support in the delivery of the scheme and manages the application process for return point exemptions and voluntary return points.