Deposit Return Legislation laid before Scottish Parliament: What's next?
The Cabinet Secretary for the Environment, Climate Change and Land Reform has laid Regulations before the Scottish Parliament that will create the legal framework for the Scottish Government’s Deposit Return Scheme (DRS). These Regulations also contain a scheme go-live date of July 2022.
The Scottish Government and all concerned should be commended for their hard work and efforts to get the legislation to this point, considering the journey they have had, as well as a string of significant disruptions including EU Exit, general elections, and now COVID-19.
Valpak recognises the positive effect a DRS system can have on the resource management sector but wish to have a thorough understanding of possible impacts and alternative options before committing to a final system.
Ensure it is the best system for Scotland
Now that Scottish DRS legislation has been laid, the key objective must be to ensure that it is the best system for Scotland and that it will lead the way in terms of tackling quality, accessibility, functionality, increasing participation, reducing litter, and exploiting the use of end materials to best effect. We need to monitor and manage the system to ensure the greatest environmental benefit and minimise any negative impacts, which will become more apparent as the system goes live.
Revised timeline benefits
It makes sense to take more time to get the system up and running, as the initial timeline seemed at best challenging and at worst posed a risk to the live launch date. A revised timeline allows for extra planning, issues being thought through more thoroughly, and more options for the service to be more clearly managed and understood. There is no doubt that change to the new system will impact everyone’s lives in Scotland. This brings me neatly to another point. Planning for the new system and getting the infrastructure in place will need time, which will undoubtedly be impacted by business disruptions caused by containment measures for COVID-19.
Questions and answers
Many stores and other locations will be required to fully understand the “customer experience” when taking part in the new system. Questions will need to be answered, such as “How will I pay my deposit and when will this be done?”, “Will it be shown on a receipt, so I have a record?”, “When I come to the store what will I see and where will I see it?”, “Will the machine have easy-to-read and access information on how to use it?”, “Will there be a help number?”, “Will it be inside the store or outside the store?”, “What if it’s not working, where’s the next nearest machine?”, “How will my pub deal with managing deposited goods within our day-to-day operations?”, “What will we need to do?”, “How much space do we need to give up for managing this?”, “What security measures do we need to take?”, “ How do we manage the cash flow of paying our deposits but not getting it back for a while?” I could go on.
Zero Waste Scotland (ZWS), the Scottish Government, producers, and retailers have proactively considered many of these points and have produced and maintained an FAQs page on the website, which can be accessed here
It is highly likely that proposals for a Scheme Administrator (the approved organisation to run the scheme) will come forward. The scheme will need to deliver a reliable, functioning, Scotland-wide service from day one and will need significant support from producers and retailers (including wholesalers, smaller grocery, independent grocery, and obligated hospitality) for it to have the best chance of success.
Robust operational plan
Both the Scheme Administrator (and producers if they register individually) will also need to have thorough and robust operational plans in place. This means that several people will be working hard on the next steps over the coming weeks and months in order to put themselves in the best position for running the scheme, as well as delivering it.
It is likely that previous dates suggested for producer registration, data provision, application for exemption from in-store take back and Voluntary Take Back Centre applications will be adjusted to fit the new proposed timeline, which will take into consideration the disruption caused by COVID-19.