Deposit return scheme consultation: analysis of responses

16 Cooperation with UK Government (Q49–Q52)

16.1 The consultation paper reported the UK Government’s intention to introduce a deposit return scheme, subject to its own consultation.^[25] The consultation paper noted the potential benefits of a single UK-wide system, or of separate but coordinated systems, and the importance of balancing these different options with maximising the benefits for Scotland of any scheme. Four questions invited respondents to give their views about the advantages and disadvantages of a UK-wide (or UK-compatible) system:

Question 49: Do you think being part of a UK-wide system would be beneficial for deposit return in Scotland? [Yes / No / Don’t know] Please explain your reasons. 

Question 50: Do you think having compatible but separate systems would achieve the same effect as a single system? [Yes / No / Don’t know] Please explain your reasons.

Question 51: Can you identify any risks with being part of a UK system?

Question 52: Can you identify any risks with not being part of a UK system?

16.2 There was a large degree of overlap in the views expressed across these four questions. In particular, the points made in relation to the questions about the risks involved (Question 51 and 52) often restated points made earlier in relation to the (potential) benefits of a UK-wide (or UK-compatible) system (Question 49 and 50). 

16.3 Thus, the qualitative comments have been analysed together and are presented below (after the findings from the closed questions) in three sections, namely (i) the benefits of a UK-wide system, (ii) views in favour of compatible but separate systems, and (iii) risks in relation to a UK-wide / UK-compatible systems.

Views on possible UK-wide DRS and UK-compatible DRS

16.4 Question 49 asked respondents if they thought being part of a UK-wide system would be beneficial for deposit return in Scotland. Question 50 asked respondents about whether having compatible but separate systems in different parts of the UK would achieve the same effect as a single system. Both of these were two-part questions comprising a closed question and space for respondents to explain their reasoning.

16.5 Table 16.1 shows that two-thirds of respondents (66%) thought that being part of a UK-wide system would be beneficial for deposit return in Scotland. While the majority of both organisations and individuals agreed with this view, organisations were particularly likely to do so, with 91% answering ‘yes’ to this question, compared to around 63% of individuals.

Table 16.1: Q49 – Do you think being part of a UK-wide system would be beneficial for deposit return in Scotland?

	Yes		No		Don't know		Total
Respondent type	n	%	n	%	n	%	n	%
Public sector organisations	19	90%	1	5%	1	5%	21	100%
Food and drink producers	19	95%	–	0%	1	5%	20	100%
Charities	18	95%	–	0%	1	5%	19	100%
Retailers	17	100%	–	0%	–	0%	17	100%
Recycling / waste mgmt orgs	15	94%	1	6%	–	0%	16	100%
Packaging manufacturers	12	75%	–	0%	4	25%	16	100%
Community bodies	5	71%	2	29%	–	0%	7	100%
Environmental consultancies	7	100%	–	0%	–	0%	7	100%
Hospitality and restaurant trade	5	100%	–	0%	–	0%	5	100%
DRS companies	3	100%	–	0%	–	0%	3	100%
Other organisations	7	88%	–	0%	1	13%	8	100%
Total organisations	127	91%	4	3%	8	6%	139	100%
Total individuals	820	63%	277	21%	209	16%	1,306	100%
Total (organisations and individuals)	947	66%	281	19%	217	15%	1,445	100%

Percentages may not total 100% due to rounding.

16.6 Table 16.2 shows that there was no clear consensus among respondents about whether having compatible but separate system across the UK would have the same effect as a single system – 41% answered ‘yes’, 30% answered ‘no’ and 29% answered ‘don’t know’. However, compared to individuals, organisations were more likely to answer ‘no’ (54% compared to 27% respectively). And, among organisations, food and drink producers (85%), packaging manufacturers (75%), recycling and waste management organisations (73%) and retailers (71%) were particularly likely to say ‘no’.

Table 16.2: Q50 – Do you think having compatible but separate systems would achieve the same effect as a single system?

	Yes		No		Don't know		Total
Respondent type	n	%	n	%	n	%	n	%
Public sector organisations	7	33%	5	24%	9	43%	21	100%
Food and drink producers	1	5%	17	85%	2	10%	20	100%
Charities	1	13%	–	0%	7	88%	8	100%
Retailers	1	7%	10	71%	3	21%	14	100%
Recycling / waste mgmt orgs	3	20%	11	73%	1	7%	15	100%
Packaging manufacturers	–	0%	12	75%	4	25%	16	100%
Community bodies	2	40%	1	20%	2	40%	5	100%
Environmental consultancies	3	43%	3	43%	1	14%	7	100%
Hospitality and restaurant trade	2	40%	3	60%	–	0%	5	100%
DRS companies	1	50%		0%	1	50%	2	100%
Other organisations	3	60%	2	40%	–	0%	5	100%
Total organisations	24	20%	64	54%	30	25%	118	100%
Total individuals	495	43%	315	27%	345	30%	1,155	100%
Total (organisations and individuals)	519	41%	379	30%	375	29%	1,273	100%

Percentages may not total 100% due to rounding.

Benefits of a UK-wide DRS system 

16.7 In general, both organisations and individuals highlighted three main reasons why the DRS system should be UK-wide – these reasons were broadly similar to the reasons set out in the consultation document and focused on:

• Cost efficiency: A UK-wide system would be more financially viable, would create economies of scale, and would reduce the costs to producers (from separate labelling and packaging). Respondents often went on to say that these savings would be passed onto the consumer.  
• Consistency and uniformity: Reponses focused on the benefits for both the public and industry of adopting a unified scheme. It was suggested that consistency and uniformity across the UK would (i) make it easier for consumers to understand and use the scheme and (ii) be beneficial in terms of the efficiency and effectiveness of the administration of the scheme as manufacturers and producers would adhere to a single set of DRS criteria. These benefits were particularly emphasised by food and drink producers and by packaging manufacturers.
• Reduction of fraud: Having a UK-wide system would prevent cross-border fraud.

16.8 Less often, respondents identified the following benefits of a unified, UK-wide system: 

• Environmental: A single system would be better from an environmental perspective, as it would reduce waste in supply chains and help maximise recycling rates.
• Policy and regulatory coherence: A single system would improve the potential for policy and regulatory coherence across a range of relevant environmental policies and regulation (for example PRN, EPR, taxes on plastics, etc.).
• Knowledge sharing: A unified system would encourage knowledge sharing in respect of best practice, mitigating risks and undertaking impact assessments. 

16.9 Respondents often identified the risks of not being in a UK-wide DRS system in terms of the failure to achieve these benefits.

Views in favour of compatible but separate systems

16.10 Individuals were more likely than organisations to favour separate but compatible systems and they gave three main reasons for this view.

• Leading by example: Given that Scotland is closer to implementing a DRS than other parts of the UK, there was an opportunity for Scotland to lead by example. These respondents thought that the Scottish Government had presented a more comprehensive DRS package than their UK counterparts (broader scope, ambition and targets, etc.) and, in their view, had generally stronger environmental credentials. Thus, a scheme implemented in Scotland first had the potential to benefit the whole of the UK. 
• Compatible schemes would not incur additional costs: Compatible systems would mean that producers did not incur additional costs in terms of packaging, labelling, etc. 
• Management and control of the DRS: The profits, benefits, management, and administration of a Scottish system would be controlled by Scotland. This would mean decisions about how to develop and administer the scheme would not need to be agreed with other jurisdictions.

16.11 The relatively small number of organisations who supported this option usually qualified their support. These organisations emphasised that for this arrangement to work, systems must be ‘fully’ or ‘truly’ compatible. This would require a significant degree of coordination across a wide range of areas – returns, packaging, administration, tax arrangements, etc.  Some thought that this may be difficult to achieve given the current political context. 

Risks of a UK-wide / UK-compatible system

16.12 In general, organisational respondents did not think there were any risks to being part of a UK-wide system. Individuals, however, were more likely to identify risks of being part of a UK-wide system as follows: 

• Delay: There was concern that waiting for the UK to implement a DRS would delay introduction in Scotland. Respondents highlighted that Scotland is further on in its consultation process than the UK Government. In addition, some individual respondents thought that the current political climate surrounding Brexit, and the divisions between the different parliaments, meant that delays would be inevitable. 
• Watering down of the system: Some individual respondents were concerned that a UK-wide approach would result in a watering down of the system proposed by the Scottish Government. Concerns raised by these respondents focused on potentially different environmental legislation and the different ambitions of the various UK governments.
• Loss of control: Loss of control over the administration of the scheme, the setting of deposit levels and tariffs, financial benefits, processing facilities, potential job losses, and local considerations such as rural impact, were noted by respondents as undesirable features of a UK-wide system.

16.13 Finally, respondents occasionally said that a UK-wide system should be limited to Great Britain, with a separate arrangement needed for Northern Ireland, given their proximity and day-to-day interactions with the Republic of Ireland.