Deposit return scheme consultation: analysis of responses

3 Overview 

3.1 This chapter presents a brief characterisation of the responses to the consultation, describes the overall views and key messages, and summarises the ‘cross-cutting’ themes which were raised repeatedly by respondents.

Characteristics of responses

3.2 Organisational responses generally engaged with the technical aspects of the consultation. They were often lengthy and detailed, and many included, or cited, supplementary evidence. This was particularly the case for food and drink producers, public sector organisations, retailers, packaging manufacturers, and recycling and waste management organisations. Furthermore, a substantial number of organisations either (i) challenged the evidence presented in the consultation paper in relation to a wide range of issues and / or (ii) said that many of the consultation questions could not be answered until the scheme was specified in more detail.

3.3 In contrast, responses from individuals were generally short, and many were based on the Have You Got The Bottle campaign response (discussed in Chapter 2). It was common for individuals to say that they did not know how to answer many of the questions in the consultation paper, which they considered to be quite ‘technical’. However, the views articulated by individuals were similar in many ways to those expressed by environmental charities and community bodies in calling for everything which can be recycled to be recycled.

Overall views and key messages

3.4 There was widespread agreement amongst both organisational and individual respondents that a well-run and appropriately targeted DRS could provide opportunities in relation to improving the environment, changing people’s attitudes to recycling and littering, and building the circular economy. Respondents identified potential benefits at all levels of the Scottish economy, for example: (i) at a national level, in terms of employment opportunities especially in relation to enhancing Scotland’s recycling infrastructure and in developing new and innovative materials, (ii) for retailers in terms of increased footfall, (iii) for charities if there is an option for consumers to donate their deposits, and (iv) for individuals who would be able to pick up discarded items in order to redeem the deposits.

3.5 In relation to the design and operation of the scheme, there was a range of areas in which respondents (both organisations and individuals) expressed a large degree of consensus. However, it is important to note that, on certain issues, there was disagreement between organisations and individuals, and between different kinds of organisations. Areas where there was widespread agreement included:

• The materials – and products – to be included in the scheme: Overall, there was support for a scheme that included the widest range of materials possible. However, organisations (and especially food and drink producers, retailers, and recycling and waste management organisations) were much more likely than individuals to favour a scheme which targeted a more limited set of materials – PET plastic, metal cans and, to a lesser extent, glass. Few respondents identified any specific products for exclusion from the scheme, although organisations were more likely than individuals to do so – particularly in relation to dairy / fresh milk, alcoholic drinks and, less often, fruit and vegetable juice. In addition, the overall balance of opinion was strongly opposed to a scheme limited to ‘on the go’ products. However, certain organisations – particularly those in the public sector, recycling and waste management organisations and the hospitality trade – were supportive of an ‘on the go’ DRS.
• A staged introduction of the scheme: Respondents generally supported a staged introduction of a DRS in Scotland – i.e. starting with a more limited set of materials and then expanding in the future. Such an approach was seen as helpful for ensuring the successful introduction of the scheme and in building support for future development.
• The return model and take-back logistics: There was widespread agreement that the scheme should use either a model based on take-back to a place that sells drinks, or a mixture of take-back and designated drop-off. (There was very little support for a scheme that involved solely take-back to a place that sells drinks.) In addition, there was a general consensus that online retailers should be included in the scheme. In terms of the return method used, both organisations and individuals favoured using a combination of manual take-back and reverse vending machines in any scheme that involves take-back to retailer.
• Financing the scheme: There was strong support for the view that deposit return should be seen as a form of ‘producer responsibility’, although organisations emphasised the importance of managing this in a ‘holistic way’ alongside other producer responsibility requirements. There was also general support (particularly among organisations) for an arrangement whereby the DRS administrator maintains ownership and income from the sale of materials collected in the scheme, and agreement that any excess funding and unredeemed deposits should be ringfenced for the continued maintenance or improvement of the DRS. Regarding the deposit level, more than half of all respondents favoured an amount between 15p and 20p.
• Consumer communication: Both organisations and individuals agreed that (i) producers should be required to put DRS-related information on each container, (ii) those putting small amounts of material onto the market in Scotland should not be exempt from this labelling requirement, and (iii) small importers could be allowed to meet this requirement by putting a DRS-related label onto their existing packaging.
• Aspects of scheme ownership: There was widespread agreement that the scheme should not be privately-owned and commercially operated.
• Regulatory aspects of the scheme: There was general support for an existing body, such as Trading Standards or SEPA to have the responsibility for regulating (i) producers and (ii) return sites, and there was strong support (both among organisations and individuals) for the Scottish Government to have responsibility for regulating the scheme administrator.

3.6 However, respondents also identified a range of risks, particularly economic risks, for a DRS in Scotland. These were both general in nature (relevant to any / all schemes) and specific (linked to particular scheme design options). 

3.7 General risks included limited public engagement; the potential for confusion; the cost of implementation; reduced sales and consumer expenditure; fraud and vandalism. There were also concerns about the possible adverse impacts on local authority kerbside recycling schemes, which were perceived to be highly successful. 

3.8 Specific risks were identified in relation to (i) running a scheme based only in Scotland (rather than in the UK as a whole), (ii) including cartons and cups (because of the lack of a suitable infrastructure to process these and the limited market for the recycled products), and (iii) including materials or products which could have adverse impacts on hygiene, health and safety, financial viability, or other policies (e.g. HDPE, glass, alcohol). Moreover, a wide range of respondents identified potential risks for small retailers whose inclusion in the scheme as deposit return-points might compromise their financial viability.

3.9 Respondents thought that maximising opportunities and mitigating risks would require: (i) securing public ‘buy in’ through awareness raising, education and effective communication, (ii) ensuring a properly resourced and well-run scheme with sufficient time available for its introduction, and (iii) maintaining ongoing dialogue with industry and local communities throughout the development and implementation period to ensure an appropriate, fair, and coherent approach. 

Cross-cutting themes

3.10 Three particular themes were raised repeatedly – by both individuals and organisations – in relation to a wide range of consultation questions. These ‘cross-cutting themes’ are discussed briefly below.

Deposit return in Scotland should not be seen in isolation

3.11 Respondents argued that a DRS should be part of a comprehensive approach to waste management, recycling and reuse. They reiterated that a DRS in Scotland should complement, rather than compete with, existing local authority kerbside schemes, and that it should also take account of other relevant policies and initiatives both in Scotland and elsewhere in the UK, such as Minimum Unit Pricing (MUP) for alcohol, anticipated reforms to Extended Producer Responsibility (EPR) and a proposed tax on single-use plastics. Furthermore, they also favoured a UK-wide (rather than Scotland-only) DRS – which they thought would offer benefits in terms of consistency, regulatory coherence, reduced complexity for all parties, and reduced scope for fraud.

Deposit return in Scotland should be accessible and convenient

3.12 Respondents repeatedly emphasised that, to achieve the large-scale behaviour change required, the DRS needed to be: (i) easy to use for consumers and other key stakeholders (producers, retailers, manufacturers); (ii) ‘accessible’ and ‘convenient’ for all consumers (including those with disabilities, those without private transport, and those living in rural areas); and (iii) ‘simple in design’ so that people can understand the scheme and use it appropriately. 

The scheme should be evidence-based

3.13 Respondents thought there was a need for further analysis on a wide range of issues. For example, they called for more (and more detailed) impact analysis and cost-benefit analysis for each of the materials proposed for inclusion in the scheme, assessment of the impacts of different schemes on consumer behaviour, an analysis of the economic impacts on consumers, etc. There were also calls for lessons to be learned from schemes elsewhere.