The Scottish Deposit Return Scheme (DRS) will affect all drinks producers AND importers, regardless of size, that markets or offers drinks for sale in Scotland. Any producer and/or importer will need to register either directly with the Scottish Environment Protection Agency (SEPA) or via Circularity Scotland, the Scheme Administrator (SA). If they do not, they will be prohibited to sell any drinks products in the whole of Scotland.
Producers have until Tuesday 28th February 2023 to register.
The scheme will see a 20p deposit placed on all single-use drinks containers made of PET plastic, steel, aluminium, and glass – HDPE plastic is NOT included. All container materials have the same deposit amount and only applies to containers sized between 50ml and 3 litres. Drinks containers that meet these criteria are referred to as ‘scheme articles’.
You are considered a drinks producer if:
- You are a brand owner of a scheme article that is branded in the UK;
- You import scheme articles that are branded by a brand owner outside the UK;
- You fill and seal scheme articles with a drink at the point of sale to a consumer.
The consumer will be able to get the 20p back once the empty container has been returned.
Some retailers will operate returns over the counter, whereas some larger retailers will operate the use of Reverse Vending Machines (RVMs). All retailers who sell drinks are required, under DRS, to operate some form of return point for consumers. There are some exemptions to operating a return point. All exemptions must be applied for via Zero Waste Scotland.
The Scottish DRS will go live for consumers on Wednesday 16th August 2023.
Use the ‘Beverage Test’ to see if your products meet the criteria:
- Must be a drinkable liquid;
- Are taken to increase bodily liquid levels;
- Are taken to relinquish thirst;
- Are consumed to fortify.
The registration for both SEPA and Circularity Scotland is £365 per year. If the producer has a taxable turnover of £85,000 or less in the previous financial year, then no registration fee will apply.
You do not need to register with both organisations. If you register with Circularity Scotland, they will register you with SEPA and will undertake the reporting duties on your behalf. If you register with SEPA, you will have to fulfil take-back and reporting duties yourself.