Chamber and committees

The position taken by Circularity Scotland Ltd (CSL) in respect of container and return point numbers, as I understand it, is set out at Annex F of the amended Business and Regulatory Impact Assessment (BRIA) for our Deposit Return Scheme (DRS) published in December 2021.

CSL’s position in respect of number of reverse vending machines is that they expect roughly 3,000 of these as set out in the Full Business Case for DRS.

CSL had no sight of the content of the amended BRIA in advance of publication.

The information presented in the version of the Business and Regulatory Impact Assessment (BRIA) published in July 2019 has been superseded.

Please refer to the amended Final BRIA published in December 2021 which can be accessed here: https://www.gov.scot/publications/deposit-return-scheme-scotland-final-business-regulatory-impact-assessment/ .

The economic model underlying the analysis in the amended Business and Regulatory Impact Assessment (BRIA) for Scotland's Deposit Return Scheme was developed in line with best practice by Zero Waste Scotland on behalf of the Scottish Government. The key inputs to the model are set out at table 2 of the amended Final BRIA.

As set out in Annex F to the amended Business and Regulatory Impact Assessment (BRIA) for our Deposit Return Scheme (DRS), published on 15 December 2021, we consider that there is a degree of uncertainty attached to the figures proposed by Circularity Scotland Ltd (CSL) for the number of scheme articles and return points under DRS. For that reason our final and best estimate remains that set out on p19 of the amended BRIA.

Nevertheless, as Annex F shows, even if we were to adopt these two figures there would continue to be a strong economic case for DRS.

We have seen no evidence for higher numbers of RVMs than the roughly 3,000 assumed in the Full Business Case Addendum and I understand that CSL is continuing to work from this figure. That is therefore the figure modelled in the updated Final BRIA that was published in December last year.

Audit Scotland provides advice and support to ensure that public money is spent properly, efficiently, and effectively. Scotland’s Deposit Return Scheme (DRS) is financed and administered by industry under the principles of producer responsibility, therefore Audit Scotland is not involved.

The centralised BRIA quality assurance services provided by the Better Regulation team has ceased, their last meeting was in February 2018.

Stock keeping arrangements related to Scotland’s Deposit Return Scheme (DRS) are a matter for industry to determine; our Regulations do not mandate a separate Scottish label or barcode for in-scope containers.

Since July 2021 SEPA has advised that the same vehicle that is used for delivery can be used for the backhaul of scheme packaging provided that:

• the haulier is a registered waste carrier ;
• where backhaul is carried out in a vehicle used to transport fresh food, there is sufficient separation and a barrier to prevent contamination of waste materials with organic matter.

This advice was published as part of a series of DRS Frequently Asked Questions on SEPA’s website on 8 March 2022.

We are analysing the text of the Act to understand how it could interact with Scotland’s Deposit Return Scheme (DRS), but in order to assess impact fully we need to understand the UK Government’s intentions for its own DRS. We have not yet seen their response to their recent consultation.

Section 34 of the Environmental Protection Act 1990 requires those handling waste to ensure that it is handled in a fashion that promotes high-value recycling.

Return points, producers and Circularity Scotland, when handling returned scheme packaging, including glass, will therefore have an obligation to promote high-value recycling regardless of whether the glass is collected manually or by the use of reverse vending machines.