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Publication - Independent report

Deposit return scheme: gateway review report - March 2023

Published
7 July 2023
From
Director-General Net Zero
Directorate
Environment and Forestry Directorate
Topic
Environment and climate change
ISBN
9781835211076

Evidence-based snapshot of the status of the Deposit and Return Scheme (DRS) for Scotland programme carried out by an independent review team in March 2023.

View supporting documents Supporting documents

Annex D

Progress against May 2022 Gateway Review recommendations, assessed by October 2022 Assurance of Action Plan:

Ref No. Recommendation Progress/Status (As Reported by SG Programme Team)
1. The SRO should ensure that sufficient mechanisms and resources are put in-place to capture the value of the Programme learning for the benefit of wider government. Establish a new dedicated Scottish Government DRS unit to lead on DRS oversight, assurance, continuing policy development (e.g. alignment with UK scheme) and evaluation.
  • DRS unit established, with eight full time Scottish Government staff in place, and additional project based support. Unit will be in place until at least December 2023 to ensure that learning from the development, implementation, launch and early running of the scheme is captured.
  • Additional programme management and policy support being provided by Zero Waste Scotland.
  • Unit building strong relationships with other administrations to share learning from SG programme.
  • Discussion with SG analytical services underway on stepsto capture value of the Programme learning.
2. The SRO should urgently review the needs and structure for Programme governance and leadership, to ensure accountability lines and oversight roles are clearly defined and understood. Review governance structures to ensure that they reflect responsibilities for scheme delivery.
  • CSL seen by all partners as responsible for implementing DRS, with board now fully appointed and functional as primary governance and assurance body within scheme administrator. CSL sharing internal governance information (from board) with SG
  • Formalising structures to report readiness, information gaps and emerging risks within the 'system-wide assurance group'. Group providing good mechanism for sharing information and highlighting collective risks, but could do more to provide assurance function. Working with CSL to align its Board's assurance needs (though their business readiness workstream) with assurance needs of Scottish Government.
  • At CSL executive, Scottish Government senior official, and ministerial level, we are reinforcing formal reporting mechanisms to complement regular meetings between officials, Ministers, CSL and SEPA. New governance structures established (e.g. policy board) where new requirements emerge.
  • Executive Oversight Group(SG, ZWS, SEPA, CSL) meeting regularly to focus on assurance of scheme readiness and other key issues
3. The SRO should urgently re- evaluate the 'go- live' schedule and the Scheme 'go- live scope' [Redacted] Review go-live schedule, scope, cut-over (launch) approach, online takeback obligation, operational information, compliance approach, and early launch opportunities
  • [Redacted]
  • [Redacted]
  • CSL adopting a 'cut-over' model that will allow the gradual flow-through of DRS articles from 16 August 2023. Resolved concerns relating to use of UK-wide barcodes. Measures should reduce operational challenges for producers and need for a sudden transition of stock at launch. Slower launch should also help manage logistical challenges due to lower volumes of DRS articles .
  • Several proposed changes to DRS regulations to address concerns with online takeback obligation, including more targeted obligation and potential phase-in / evaluation period are being undertaken.
  • Updated return point exemptions guidance published in December 2022 that make it clearer, quicker and easier for eligible retailers to apply for an exemption, should they wish to do so. [Redacted]
  • [Redacted]
  • SEPA has committed to take a supportive approach to compliance, which they are working to detail exactly what this approach looks like.
  • Orkney Return Initiative launched on 04 November. The project will provide a practical test of scheme logistics (especially on island communities) and help to de-risk elements of the scheme.
4. SRO should re- examine the roles and coordination of communications across the Programme and ensure a significant improvement in communications flows. Review the remit and leadership of the communications group to ensure that (1) responsibilities of the different organisations are clear, with a view to CSL taking lead responsibility (2) more is done to identify and target 'hard to reach' groups, (3) there is greater clarity in 'essential information' on the scheme to support business decision making, and (4) the group is better integrated into wider delivery plans (e.g. infrastructure roll-out).
  • CSL have taken lead on communications from 2023, with Director for Communications now in post.
  • Progress on business communications since the Gateway Review, including production and distribution of tailored communications tools for stakeholders, expansion and regular updates to SEPA's FAQs. SEPA comms campaign launched August 2022, CSL comms campaign launched Sep 2022.
  • Integrated Communication and Marketing plan developed which focuses on all stakeholder groups
5. [Redacted] [Redacted]
  • [Redacted]
  • [Redacted]

Contact

Email: DRSHub@gov.scot

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