Deposit return scheme consultation: analysis of responses

4 Materials to be collected in a DRS (Q1–Q6)

4.1 One of the key components in a DRS relates to the materials that the scheme will collect. The consultation paper discussed the options, set out the advantages and disadvantages of including each option, and considered the possible combinations of materials which the scheme could target. It also discussed (i) the possibility of a staged introduction to the scheme, (ii) whether any materials should be excluded from the scheme, and (iii) what the cost implications for local authorities would be.

4.2 The consultation included six questions on these issues:

Question 1: Which of the options do you prefer? Please choose one or more options and explain your reasoning. [PET plastic containers / PET plastic containers and metal cans / PET plastic containers + glass containers + metal cans / PET plastic containers + glass containers + metal cans + HDPE plastic containers / PET plastic containers + glass containers + metal cans + cartons + disposable cups]

Question 2: Do you think the scheme should start with a core set of materials and then be expanded as appropriate? [Yes / No / Don’t know]
Question 2a: If yes, which materials should it start with? [PET plastic / Metal (aluminium and steel) / Glass / HDPE plastic / Cartons / Disposable cups]
Question 2b: If yes, which materials do you think should be added later? [PET plastic / Metal (aluminium and steel) / Glass / HDPE plastic / Cartons / Disposable cups]

Question 3: Are there any materials that you think should not be included? [PET plastic / Metal (aluminium and steel) / Glass / HDPE plastic / Cartons / Disposable cups]

Question 4: Are there any other materials not already listed that should be included?

Question 5: Are you aware of any materials currently in development that should be included?

Question 6: What are your views on the cost implications for local authorities?

Materials in scope (Q1)

4.3 Question 1 invited views about which materials should be collected by a DRS. Respondents were invited to choose one or more options from a list containing various combinations of six different materials.^[6]

4.4 Table 4.1 shows that almost half of respondents overall (45%) thought the DRS should include the widest possible range of materials. A further 44% thought the DRS should include all materials except for HDPE (36%) OR cartons and disposable cups (8%). Organisations were much less likely than individuals to favour a highly inclusive scheme: only 21% of organisations favoured the inclusion of the widest possible range of materials, while over half of the organisations (53%) favoured a restriction to PET plastic containers only (17%), PET plastic containers and metal cans only (27%), or PET plastic containers, metal cans and glass containers (9%). There were substantially different views among different organisational groups. For example, food and drink producers, retailers, and recycling / waste management organisations were more likely to favour a more limited set of materials being included in the DRS. By contrast, public sector organisations, charities, community bodies and environmental consultancies were more likely to favour a wider range of materials. (See Table A4.1 in Annex 4 for further details of the organisational responses to Question 1, broken down by organisation type.)

Table 4.1: Q1 – Which of the options do you prefer?

	Organisations		Individuals		Total
Options	n	%	n	%	n	%
ALL materials listed*	28	21%	928	47%	956	45%
ALL materials listed EXCEPT HDPE containers	28	21%	738	38%	766	36%
ALL materials listed EXCEPT cartons and disposable cups	8	6%	160	8%	168	8%
PET plastic containers, metal cans and glass containers	12	9%	78	4%	90	4%
PET plastic containers and metal cans	37	27%	29	1%	66	3%
PET plastic containers only	23	17%	33	2%	56	3%
Total	136	100%	1,966	100%	2,102	100%

* ‘ALL materials’ refers to: PET plastic containers, metal cans, glass containers, HDPE plastic containers, cartons and disposable cups.

Percentages may not total 100% due to rounding.

4.5 Question 1 was addressed by the postcard campaign which called for all materials to be included in a DRS in Scotland.

4.6 Respondents gave a variety of reasons for preferring each of the six options set out in Table 4.1 above. They explained their preferences not only in terms of the benefits of targeting certain materials, but also in terms of the disadvantages or difficulties of including other materials. The main reasons given by respondents in support of each of the six options listed in Table 4.1 above are discussed below. Arguments against the inclusion of certain materials are discussed later in this chapter (together with views expressed in relation to Question 3).

4.7 Some respondents (mainly organisations, and some respondents who did not indicate a preference for any of the options) made general points which they thought should be considered in the selection of in-scope materials. These points are summarised in paragraphs 4.24 to 4.30 below.

Option 1 (PET plastic containers only) and option 2 (PET plastic containers and metal cans)

4.8 Respondents who selected option 1 (PET plastic containers only) or option 2 (PET plastic containers and metal cans) generally gave the same reasons for their preference. The main difference between them was that those in favour of targeting PET plastic containers only gave arguments for not including metal cans, whereas the latter group discussed the benefits of including metal cans.

4.9 Both groups (and both organisations and individuals within each group) thought that it would be best to keep the DRS ‘simple to start with’. These groups also thought that a focus solely on PET plastic / PET plastic and metal was a ‘good’ or ‘easy’ starting point and would provide the basis for (i) developing the necessary systems, (ii) getting them working effectively, and (iii) building awareness and participation among the general public.

4.10 Both groups argued that these materials were the most significant contributors to litter in the environment and thus, targeting them in the DRS would have the biggest impact. Moreover, the focus on a smaller range of materials – at least initially – would:

• Minimise the complexity and cost of the DRS: There were repeated concerns that, if the DRS attempts to be all-encompassing from the start by including materials for which there is currently less established recycling capacity (i.e. disposable cups and cartons, in particular), this would increase the complexity and cost of the scheme, and the risk that it might fail. 
• Make it easy for people to participate: These respondents emphasised the importance of removing potential barriers – for consumers, retailers and producers – so that they can understand and fully participate in the DRS.
• Be less likely to compete with local authority kerbside recycling schemes: Respondents favouring a focus on a more limited set of materials said that it was important for any scheme to complement existing recycling schemes. This could be achieved, especially if the scheme targeted ‘on the go’ plastic and metal drinks containers only. (This latter argument is considered in greater detail in relation to Question 11 in Chapter 5.)

4.11 Both groups argued that it is unnecessary to include glass in the DRS – while those who chose option 1 also said it was unnecessary to include metal – because other recycling schemes are already gathering these materials successfully and there are policies and / or regulations in place to support further increases in recycling of glass and metal.

4.12 Some organisational respondents who chose option 1 (particularly food and drink producers, packaging manufacturers, those in the retail sector, and those in the restaurant and hospitality trade) also suggested that:

• A focus solely on PET plastic would minimise disruption and adverse impacts on small businesses such as independent brewing companies, who would be required to have separate bottling runs for any products sold in glass containers in Scotland.
• It would also have the least adverse effect on other major policy initiatives – particularly, in Scotland, on minimum unit pricing (MUP) for alcohol, since most alcohol products are sold in glass or metal containers. (There is more detailed discussion of this issue in Chapter 5 in relation to Question 8.)
• In an airport retail context, a focus solely on PET plastic would be useful, since current hand luggage restrictions on liquids require that passengers dispose of all bottles containing more than 100ml before going through security. Most of these bottles are made of PET plastic.

4.13 Some of the respondents who chose option 2 pointed out that targeting PET plastic containers and metal cans would allow the Scottish Government to learn from the experiences of schemes in other countries – many of which collect this combination of materials. In addition, some organisational respondents (particularly those in the recycling and waste management sector and those in the retail sector) discussed the cost-benefit of targeting PET plastic and metal cans. These respondents noted that:

• These materials have high value and can be easily recycled, even when collected and transported together – whereas if glass was included, it would have to be collected separately, thus increasing disruption to return points. In addition, there are well-developed markets for PET plastic and metal cans.
• Recycling and reprocessing facilities are available in the UK for these materials.

Option 3 (PET plastic containers, metal cans and glass containers)

4.14 Table 4.1 above suggests that there was very little support for option 3 (PET plastic containers, metal cans and glass containers) – either among organisations or among individuals.

4.15 Among organisations in favour of collecting this combination of materials, the following reasons were given:

• This combination of materials is the combination most widely captured by DRS systems operating in Europe; Scotland can learn from these experiences.
• Targeting this combination of materials would be the most cost-effective option as it concentrates on the recyclable products most used in the licensed trade.
• Including glass may help local authorities that do not provide a kerbside collection for glass.
• All these materials would add value to the scheme; there are good processes in place (including RVMs) for recycling them.

4.16 Individual respondents thought this combination of materials covered most littered items and considered it to be a ‘middle road’ – avoiding the complexity, cost and (possible) complications of trying to collect a wider range of materials.

Option 4 (PET plastic containers, metal cans, glass containers and HDPE plastic containers), option 5 (PET plastic, metal cans, glass, disposable cups and cartons) and ALL materials

4.17 Similar reasons were given by respondents who selected option 4 (PET plastic containers, metal cans, glass containers and HDPE plastic) or option 5 (PET plastic containers, metal cans, glass containers, disposable cups and cartons), or who expressed a preference for all six materials to be collected. Those who selected option 5 often stated in their comments that they wanted all materials (including HDPE plastic) to be included.

4.18 Individual respondents often simply reiterated that they wanted ‘as much as possible’ to be recycled, or that ‘all items’ should be recycled, without offering further explanation for their views. Among those who provided details, there was a recurring view that the DRS should ‘be ambitious’ and ‘far-reaching’. These respondents repeatedly stated that collecting the widest possible range of materials would have the greatest positive impact on litter, landfill and the environment. They saw the main benefits as:

• Increased volume of recycling: Some organisations suggested that capacity already exists in the UK for processing all the materials listed in Question 1. These respondents thought that a DRS would facilitate a significantly higher proportion of these materials being recycled than current household and commercial recycling collections.
• Simplicity: Respondents in these groups often suggested that including a wider range of materials from the start would create a simpler system for the public to understand and engage with, limiting confusion over which containers are in scope and which are not.
• Prompting behaviour change: Targeting a wide range of materials would send out a clear message to the public that all these materials are valuable and that efforts should be taken to dispose of them correctly.
• Efficiency: Some in this group argued that since setting up the system and influencing public and business behaviour is a big undertaking, it makes sense to be as inclusive as possible.
• Preventing market distortion: Some respondents thought that, by including a wider range of materials, there would be less risk of food and drink producers switching to other materials. It would also encourage manufacturers to use the most easily recycled materials if all materials are included.
• An opportunity to support innovation: Some respondents thought a more ambitious scheme would receive more financial and material resources at the start-up stage, and that this in turn would lead to innovation in recycling materials that are currently difficult to recycle (such as disposable cups and cartons).

4.19 Less often, it was suggested that another benefit of targeting a wider combination of materials would be a reduction in household recycling – thus avoiding the problem of ‘bin overflow’ which was perceived as a widespread problem in urban areas.

4.20 While all three of these groups wanted the widest possible range of materials to be recycled, those who selected option 4 voiced concerns about the complexity and practical difficulties of including disposable cups and cartons (option 5). Occasionally, respondents who chose option 4 indicated that they wanted HDPE plastic to be included in the scheme, but they thought fresh milk HDPE containers should not be included. This latter view is discussed further in Chapter 5.

4.21 Some respondents in these groups acknowledged that one of the potential difficulties of including a wide range of materials was that more space would be required at return points to collect different materials separately. This could be difficult for small stores, particularly when the scheme first begins. Related to this point, there was also recognition that targeting a wider range of materials might put more of a burden on members of the public (for example, to recycle their materials into different collection bins). The view among those who raised this point, however, was that it ‘is not hard’ for people to separate different materials and recycle them appropriately.

Other combinations of materials preferred

4.22 Occasionally, respondents expressed a preference for some other combination of materials – rather than those offered in the consultation paper. Suggestions included: (i) PET plastic containers, metal cans and disposable cups; (ii) PET plastic containers, metal cans, cartons and disposable cups; (iii) PET plastic containers and disposable cups; (iv) PET plastic containers, metal cans and HDPE plastic containers (v) PET plastic containers, metal cans, HDPE plastic containers, disposable cups and cartons.

4.23 Those who suggested these types of combinations generally gave specific reasons for excluding the remaining types of material.

General points made in relation to the materials collected by the scheme

4.24 A range of organisations made more general points or identified general principles which should inform the selection of in-scope materials. (Some of these respondents chose not to indicate a preference for any of the options listed.) This group also highlighted wider considerations about the materials to be included in the scheme.

4.25 These views have been summarised below.

Decisions about in-scope materials should be based on cost-benefit analysis and robust option appraisal

4.26 These respondents emphasised that the decision about materials, sizes, formats and products to include in a DRS should be based on the best available data about where the greatest benefit can be achieved in a cost-effective way. Impact assessments should be undertaken in relation to each option, and consideration should be given to whether there is a market for the items collected. These kinds of response are discussed in greater detail in Chapter 15.

A DRS should be just one part of a comprehensive strategy for waste management, recycling and reuse

4.27 Some organisations (particularly those in the public sector) commented that a DRS should be part of a comprehensive and integrated system of resource and waste management.

4.28 This group argued that the introduction of a DRS should not be at the expense of existing (and in their view, effective) kerbside schemes. A more detailed discussion of the relationship between the DRS and local authority kerbside recycling is provided below in relation to Question 6 (paragraphs 4.71 to 4.80.) 

4.29 Finally, there was a recurring view that the choice of materials for a DRS in Scotland should take into account wider policy initiatives – not only those relating to recycling and waste management, but also those relating to public health and reducing equalities. Such initiatives would include: (i) plans by the UK Government to tax disposable cups, (ii) reform of Extended Producer Responsibility (EPR), (iii) minimum unit pricing for alcohol and (iv) wider policies aimed at tackling social and health inequalities. Some respondents highlighted possible unintended consequences – for older people, disabled people, rural and remote areas, and low-income households – both in terms of the additional cost of purchasing certain products (e.g. milk), and in terms of the environmental cost of consumers having to travel to return materials that could previously be collected at kerbside. (Note that the issues identified at points (i) and (ii) above are discussed in more detail in relation to Question 17 (Chapter 7) which reports on views of producer responsibility. Further discussion of possible impacts on equalities groups is in Chapter 17.)

The scheme will need to be flexible to account for specific contexts

4.30 Some respondents queried – or made suggestions about – how the scheme could work in very specific contexts, for example, an airport, a hospital, a small rural convenience store, or an island community. It was suggested that it may be possible to collect a comprehensive set of materials in some contexts or areas of Scotland, but it may be more appropriate to collect a scaled-down set of materials in others.

Possible staged introduction to the DRS (Q2)

4.31 Question 2 asked for views about a possible staged introduction to the DRS – i.e. starting with a core set of materials and expanding as appropriate. Table 4.2 shows that   around two-thirds (65%) of respondents overall were in favour of the scheme starting with a core set of materials and then expanding later. Whilst most types of organisation were also broadly in favour of a staged approach, retailers were fairly evenly divided in their views (37% said ‘yes’ and 47% said ‘no’), and food and drink producers and packaging manufacturers disagreed with a staged approach (64% and 75% respectively said ‘no’).

Table 4.2: Q2 – Do you think the scheme should start with a core set of materials and then be expanded as appropriate?

	Yes		No		Don't know		Total
Respondent type	n	%	n	%	n	%	n	%
Public sector organisations	17	81%	3	14%	1	5%	21	100%
Food and drink producers	7	32%	14	64%	1	5%	22	100%
Charities	13	76%	2	12%	2	12%	17	100%
Retailers	7	37%	9	47%	3	16%	19	100%
Recycling / waste mgmt. orgs	11	73%	4	27%	–	0%	15	100%
Packaging manufacturers	1	6%	12	75%	3	19%	16	100%
Community bodies	8	89%	–	0%	1	11%	9	100%
Environmental consultancies	5	71%	2	29%	–	0%	7	100%
Hospitality and restaurant trade	4	67%	1	17%	1	17%	6	100%
DRS companies	3	75%	1	25%	–	0%	4	100%
Other organisations	7	78%	2	22%	–	0%	9	100%
Total organisations	83	57%	50	34%	12	8%	145	100%
Total individuals	1,159	66%	480	27%	120	7%	1,759	100%
Total (organisations and individuals)	1,242	65%	530	28%	132	7%	1,904	100%

Percentages may not total 100% due to rounding.

4.32 The consultation did not ask for comments at Question 2. However, some organisational respondents who submitted their responses by email included comments on this question. In addition, respondents often discussed the option of a staged introduction to the DRS in their comments at Question 1, and these views are also covered below. 

Views supporting a staged introduction to the DRS

4.33 It was fairly common for organisations and individuals to suggest that the DRS should start with a relatively simple mix of materials to allow the processes and impacts of the DRS to be assessed before increasing the range of materials in scope. This view was expressed both by those who chose a wide range of materials at Question 1 and by those who chose a more limited set of materials. These respondents were concerned that, if the scheme tries to be all-encompassing from the start, it may fail. Moreover, if it fails, the public may become disillusioned with the value of ‘correct’ recycling, which could also have an adverse impact not only on the future of a DRS in Scotland, but also on the viability of local authority recycling schemes. On the other hand, if the scheme can be introduced in a small way, successfully, giving the public time to get used to it, it will be easier to expand its scope to include other materials at a later stage – subject to further cost-benefit and environmental analysis for each material.

4.34 Occasionally, respondents in this group made suggestions about how a staged DRS could be designed, so that broadening its scope in the future can be achieved easily, cost-effectively and fairly. For example, it was suggested that:

• The initial infrastructure should take account of possible future expansion to avoid businesses having to pay twice or incurring significant increased investment at a future point, to accommodate the new scope. (There was, however, also a concern about businesses having to invest in more expensive infrastructure at the outset which may not then be used in the future).
• All companies whose packaging is included in an expanded scheme should be required to participate and to pay an allocation of the original capital and revenue set-up costs, so that newcomers do not benefit unfairly from any existing infrastructure.

4.35 Some public sector respondents suggested that that the DRS should initially target only ‘on the go’ products and then expand to other types of products later. (These views are discussed further in Chapter 5 in relation to Question 11.)

Views opposed to a staged introduction to the DRS

4.36 Respondents opposed to a staged introduction to the DRS included both those who chose a wide range of materials at Question 1 and those who preferred a more limited set of in-scope materials. The former wanted the DRS to ‘be ambitious’ from the start, and the latter wanted the scheme to start small and stay small.

4.37 These respondents gave three main reasons for NOT introducing a DRS in a staged way. These related to:

• Costs: Respondents thought there would be additional costs for adapting or upgrading RVMs and other scheme infrastructure (such as return locations and reprocessing facilities) and responding to any new labelling requirements. There could also be costs to local authorities, as incremental changes to the scheme would have an impact on waste and recycling services (and infrastructure) provided by councils.
• Confusion among public: A scheme that changes over time would require incremental behaviour shifts by the public. Respondents raising this issue thought it would be preferable to aim for maximum public participation from the start, with clear and consistent communication about the scheme. 
• The possibility that producers will switch to materials not in scope: Respondents who wanted the widest possible range of materials to be targeted thought that a staged approach would provide greater opportunity – at least initially – for producers to switch to materials not in scope.

Initial (‘core’) set of materials

4.38 For those who said ‘yes’ at this question, two follow-up questions were asked about which materials the DRS should start with (Q2a) and which should follow later (Q2b). 

4.39 Question 2a was a multi-code question, with respondents invited to select as many materials from a list (of six) as they wished. The proportion of respondents mentioning each material as part of the ‘core set’ of materials is shown in Table 4.3 below.^[7] The table shows that, among those who thought a staged introduction to the DRS was appropriate: (i) PET plastic was almost universally selected as belonging to the ‘core set’ (92%), (ii) a large majority of respondents also selected metal (68%) and glass (61%), and (iii) the least popular material for inclusion in the ‘core set’ was HDPE plastic which was selected by 30% of respondents.

Table 4.3: Q2a – Number of respondents selecting each material as part of ‘core set’

Options	n	%
PET plastic	1,133	92%
Metal (aluminium and steel)	841	68%
Glass	750	61%
HDPE plastic	368	30%
Cartons	424	34%
Disposable cups	498	40%
Total*	1,232

 Percentages do not total 100% because respondents could tick more than one option.
*  Includes only those who answered ‘yes’ at Question 2.

4.40 Between them, respondents offered 49 different combinations of materials which the DRS should include in the first instance. Forty of these combinations were offered by a small number of respondents only (30 or fewer). The most popular nine combinations, which covered around two-thirds (67%) of responses, are set out in Table 4.4 below. (Note that, on average, respondents selected three materials for their ‘core set’.)

Table 4.4: Q2a – Materials included in the ‘core set’ 

	Total
Options	n	%
ALL materials (PET plastic, metal, glass, HDPE plastic, cartons, disposable cups)	274	23%
PET plastic only	154	13%
PET plastic, metal, glass and HDPE plastic	99	8%
PET plastic and HDPE plastic	56	5%
PET plastic, HDPE plastic, cartons and disposable cups	52	4%
PET plastic, HDPE plastic and disposable cups	48	4%
PET plastic, metal and glass	47	4%
PET plastic and metal	39	3%
PET plastic and glass	32	3%
Other combination	401	33%
Total	1,202	100%

4.41 As can be seen from the table, the most popular ‘core set’ selected by respondents is the entire list of possible materials. (Note, the HYGTB campaign advised their supporters to respond in this way.) Other popular combinations were:

• PET plastic only (13%)
• PET plastic, metal, glass, and HDPE plastic (8%)
• PET plastic and HDPE plastic (5%).

Excluded materials (Q3)

4.42 Question 3 asked for views about whether any of the six materials listed above should not be included in a DRS in Scotland.^[8,9] The main findings were that:

• Around 1 in 7 respondents to the consultation (331 respondents out of a total of 2,167) selected one or more materials in response to this question. Eleven (11) respondents (all individuals) selected them all.
• Organisations were more likely than individuals to suggest that one or more materials should not be included. Specifically, around a third of all organisations thought that disposable cups and HDPE plastic should not be included in the scheme, and over a quarter thought that glass containers should not be included. Organisations were much less likely than individuals to say that metal cans should not be included. Those who did comprised a subset of (i) packaging manufacturers, (ii) organisations in the hospitality and restaurant trade and, less often, (iii) food and drink producers and (iv) public sector organisations.
• By contrast, the materials most likely to be identified by individual respondents for exclusion were disposable cups (around 1 in 10 suggested this) and cartons (around 1 in 20 suggested this). Very few individuals overall wanted PET plastic, metal cans, glass or HDPE plastic to be excluded. 
• No organisation suggested that PET plastic should not be included. By contrast, among individuals,19 thought PET plastic should not be included. The latter group were either opposed the introduction of a DRS scheme entirely, or they believed the scheme should target materials which are currently harder to recycle.

4.43 The main points made by those who wished to exclude one or more of the materials listed in the consultation paper are summarised here. Arguments against inclusion often echoed points set out in the consultation paper.

Arguments against including metal cans and glass

4.44 There were some similarities in the arguments of organisations who advocated the exclusion of metal cans and / or glass. In particular, this group thought it was unnecessary for a DRS in Scotland to target these two materials since both already had very high rates of recycling, and these rates are projected to rise under a reformed EPR system. These respondents cited evidence for this and argued that a DRS could provide only a modest improvement over what will, in any case, be achieved through current arrangements.

4.45 This type of argument was echoed by individual respondents who repeatedly stated that there were already good facilities available for recycling metal and glass. These respondents often suggested that the DRS should focus on materials that are ‘less well catered for’ at present.

4.46 Some organisations highlighted the potential for a scheme which included metal cans and glass to undermine the policy objectives of minimum unit pricing for alcohol. These respondents argued that, if metal cans and glass are included in the scheme, then alcohol products should be exempted. This point has been discussed already in relation to Question 1 and will be considered further in relation to Question 8 in Chapter 5.

4.47 Some respondents in the hospitality sector highlighted the potential for the scheme to have an adverse impact on small independent brewers. These respondents argued that the scheme should either include both metal and glass, or it should exclude both these materials. Including one but not the other would disadvantage some brewers (depending on whether products are canned or bottled).

4.48 With regards to metal cans, there were also concerns about the way multipacks may be handled within a DRS. Specifically, some organisations thought that if there was a deposit on every can in a multipack, consumers were likely to switch to large format single use plastic bottles instead. They argued the impacts could include (i) a substantial reduction in the sale of cans, (ii) job losses in the aluminium / steel manufacturing industry, and (iii) plant closures. It was also suggested that, if metal cans were diverted from kerbside schemes into a DRS, local authorities would derive significantly less value from the other forms of metal they collected and, therefore, may stop collecting other metal items – particularly those that are more difficult to recycle (aerosol cans, foil). 

4.49 With regards to glass, those who were opposed to its inclusion in a DRS set out a wide range of additional arguments. These related to:

• Cost: There would be (additional) costs for equipment (i.e. separate or larger RVMs) and transportation. Such costs would not be recouped within the system due to the low-value of the material.
• Lack of litter: Glass bottles were perceived to make a relatively small contribution to littered waste.
• Contamination: There were concerns about the contamination associated with used glass bottles – not only in shops, but also in healthcare settings. In addition, the collection of mixed-colour glass through RVMs – as opposed to separation by colour at bring back sites – will create lower quality recyclate and potentially contaminate other high-value materials (such as PET plastic and cans).
• Health and safety: Respondents raised concerns about the possibility of breakages during the collection and sorting of glass by staff in retail shops.
• Weight and bulk: Because of its bulk and the need for separate and larger RVMs, returned glass would take up greater floor space in collection areas. There would also be implications for consumers having to carry / transport glass bottles – particularly in areas where glass is currently collected as part of a kerbside scheme. Evidence was noted from schemes in other countries (and one former scheme in Scotland) suggesting that glass typically has one of the lower collection rates when included in a DRS because many consumers prefer not to carry glass items back to return points.
• Consumer confusion: If the scheme targets only glass beverage bottles rather than all glass containers, this could cause confusion among consumers.

4.50 Instead of including glass in a DRS, these respondents thought efforts should focus on (i) supporting and, where possible, improving existing kerbside and drop-off collection, (ii) taking action through industry and local authority partnerships, supplemented by EPR reform and (iii) investing in improved sorting technology for glass bottles.

4.51 Alternatively, if glass is included, then the DRS should ensure no cross-contamination with other materials. In addition, tailored arrangements will be required for specific contexts (including hospitals and retail premises, and bars and restaurants which handle large quantities of glass packaging).

Arguments against collecting HDPE plastic

4.52 Respondents opposed to the inclusion of HDPE plastic generally focused on its use in packaging dairy products, and made the following points:

• Milk is a staple food; placing an additional cost (in the form of the deposit) on milk would have a negative impact on public health and on reducing health inequalities.
• Products in HDPE containers are usually consumed in the home, and thus do not contribute substantially to litter.
• There would be hygiene risks if HDPE plastic was included in the scheme. 
• The processes for recycling HDPE plastic are well-established and already achieve a very high recycling rate (some said higher than that quoted in the consultation paper) and a high recycled material content.

4.53 These points are discussed further in Chapter 5 in relation to Questions 8, 12 and 13.

Arguments against collecting cartons and disposable cups

4.54 There was a widespread view that there would be significant challenges to overcome if a DRS was to collect cartons and disposable cups. Even among respondents who were in favour of collecting the widest possible range of materials, some thought that the inclusion of disposable cups, in particular, was problematic, and that a different type of approach to recycling them may be required. There was a recurring view that adding cartons or disposable cups to the scheme would increase the cost and complexity of collection without generating any financial benefit. In addition, some respondents emphasised that, for the DRS to be viable, high-value materials should not cross-subsidise low-value materials.

4.55 Regarding cartons, respondents additionally commented that:

• Cartons are difficult to empty entirely and to rinse, thus increasing the potential for contamination and odours at collection points which could attract vermin.
• If RVMs are used as a take-back option, the technology required for this to be possible would increase the cost of the scheme substantially. (Some respondents quoted a four-fold increase in the cost of a machine.) Other suggested it might be impossible to use RVMs for taking back cartons since liquids leaking from the cartons can cause the machines to malfunction.

4.56 With regards to disposable cups, respondents additionally highlighted that:

• Disposable cups are very inexpensive; there would be difficulties in preventing fraud if they were included in a DRS.
• The likelihood of contamination of other materials, if collected together, would be high.
• At present, disposable cups cannot be easily recycled.

4.57 Rather than including disposable cups and cartons in a DRS, respondents who wanted to exclude them from the scheme suggested alternatives – including collecting them through a similar but separate system or introducing recycling of cartons and disposable cups at a later stage when the technology for recycling them had advanced further.

4.58 With regards to cups specifically, some respondents thought that the aim should be to reduce their use (rather than recycling them) and there were calls to phase them out entirely. This view was particularly common among individual respondents and some charities. Related to this, there were suggestions to introduce a non-refundable charge for disposable cups paid for by the consumer, similar to that for single use carrier bags; and to incorporate a ‘cradle-to-grave’ cost for producers via a reformed EPR. Other suggestions focused on collecting disposable cups, but not for recycling. For example, there was a suggestion that they could be used to fuel waste-to-energy plants.

Views that no materials should be excluded

4.59 More than 400 respondents, including 39 organisations, did not select any materials for exclusion from the scheme but nevertheless went on to make comments at Question 3. In general, these respondents stated that (i) they wanted all these materials to be included in the scheme and (ii) if any were excluded, producers might switch to materials which are not in scope. Less often, respondents in this group raised similar points to those discussed above in relation to glass, HDPE plastic, cartons and cups, and suggested that different arrangements (outside of a DRS) may be needed to recycle certain materials in a cost-effective way.

Possible inclusion of other materials (Q4)

4.60 Question 4 asked for views about whether any other materials – i.e. other than the six listed in the consultation paper – should be included in a DRS for Scotland.

4.61 Individual respondents identified a wide variety of other materials which they thought should be included. By contrast, organisations were much less likely to suggest specific materials but were more likely to offer general comments. The main points made in both these types of responses are discussed below.

Other materials which should be included

4.62 As noted above, individuals mentioned a wide variety of other materials in response to Question 4. The priority for individuals was to improve the recycling of materials which are not easily recycled (at least in some areas of Scotland), and to reduce litter. This group repeatedly made the point that ‘all recyclable materials’, ‘all single use plastics’ or ‘all synthetic materials’ should be able to be recycled. However, it was not usually clear from people’s comments how certain materials could be collected as part of a DRS. Moreover, for many of the materials / items identified by individuals, recycling facilities are already widely available across Scotland.

4.63 Among both organisations and individuals, the following materials / items were frequently mentioned for potential inclusion in the scheme:

• Other plastic items such as detergent and shampoo bottles, plastic cutlery, plastic straws (i.e. not just PET plastic drinks containers)
• Polystyrene
• Textiles (including clothing, shoes and bags)
• Tetrapack and other forms of composite packaging (including multi-laminate pouches)
• Batteries.

4.64 Individuals frequently identified food packaging (e.g. plastic food trays, black plastic and plastic film) as a category of materials that could be included in the scheme, while organisations were less likely to mention this.

4.65 Other materials / objects frequently identified by individuals were plastic carrier bags / bags for life, paper, cardboard, electronics and crisp packets. Less often, individuals suggested that building materials (e.g. wood, chipboard, pallets, crates, PVC windows and doors) and metals (copper, iron, mild steel, lead, etc.) should be included in a DRS. A wide range of other materials were identified infrequently (usually by fewer than five individuals). Examples ranged from light bulbs, medicines and ink cartridges, to plant pots, cigarette ends and wet wipes. Some organisations also supported the inclusion of bioplastics. (These views are discussed further in relation to Question 5 below.)

New materials under development (Q5)

4.66 Question 5 asked whether there were ‘any materials currently in development’ which should be included in the DRS. The consultation paper did not discuss such materials, but the question referred specifically to ‘bioplastics’, and stated that ‘whilst these can look and behave like plastic, it is often important to ensure they are kept separate from plastic in the waste stream as they are recycled differently’. Thus, in their responses to this question, respondents generally focused on the extent to which bioplastics were appropriate for inclusion in a DRS.

4.67 There were differences in the way organisations and individuals responded to this question. A recurring view among individuals was that ‘anything that doesn’t break down naturally (or which is causing a problem in the environment), and which can be recycled should be recycled’.

4.68 By contrast, responses from some organisations included detailed technical information and references to published research. These responses discussed the distinctions between and, in some cases, the chemical properties of, ‘bio-based’, ‘biodegradable’, ‘oxo-degradable’ and ‘compostable’ plastics. Respondents commented that there was confusion among members of the public in relation to these different kinds of materials.^[10] The key points made were that:

• This term ‘bioplastics’ is used to refer to a variety of materials which have very different chemical properties.
• Bioplastics are plant-based (or bio-based); however, some are chemically identical to conventional fossil fuel-based plastics (such as PET) and some are not.
• Those which have the same chemical properties as conventional plastics can be recycled together with conventional plastics. Those which are chemically different (this would include ‘compostable’ or ‘oxo-degradable’ bioplastics) must be dealt with separately to avoid contamination of high-quality plastic recyclate.

4.69 While respondents often expressed support for investing in the development of new, environmentally friendly packaging, there was disagreement about whether bioplastics could be classed as ‘environmentally friendly’. Some (mainly individual) respondents thought such materials could be recycled in a domestic compost bin – and therefore there was no need to include them in a DRS. Others thought that these materials would only degrade in conditions provided by industrial composting; therefore, they should be collected in local authority green waste bins, not through a DRS. A third view was that these materials were neither degradable nor easily recyclable (a related view was that they took a very long time to degrade), and thus, they do not address the problem of plastic pollution. Moreover, (i) since the public often mistakenly believes that these materials will break down naturally in the environment, they are more likely to be littered, (ii) their manufacture results in diverting productive farmland from growing food crops, and (iii) the necessary sorting technology is not (yet) available to recycle these materials. As a result, some organisations (and environmental charities in particular) argued that, bioplastics should be avoided altogether. 

4.70 Finally, both organisations and individuals repeatedly emphasised the importance of clear labelling (some wanted to see statutory labelling requirements) to avoid confusion among members of the public, and the mixing up of materials which should be recycled separately.

Cost implications for local authorities (Q6)

4.71 Respondents were asked to comment on the cost implications of a DRS for local authorities. Their responses are discussed below under the following headings: (i) general comments relating to costs, (ii) overall views of cost implications for local authorities, (iii) concerns about cost implications for local authorities, (iv) positive views about the cost implications for local authorities, and (v) other comments.

General comments relating to costs

4.72 A wide range of respondents, particularly individuals, did not address the question in relation to cost implications for local authorities, but rather made general comments about the costs and financing of recycling and litter reduction initiatives. The main points made in these contributions were that:

• Cost is not the defining issue: Respondents emphasised that improving the environment through recycling and litter reduction was an absolute requirement, and that this should be done regardless of the cost. It was common for respondents to say that the ‘benefits outweighed the costs’, and that this needed to be thought of as a long-term commitment to ‘future generations’. 
• The costs are not known: Some respondents said they were unable to provide a view on this question given the lack of clarity about the particular type of DRS that would be implemented. In particular, the cost implications of an ‘on the go’ scheme would be very different to those of a scheme with comprehensive coverage.
• The scheme should be ‘cost neutral’: Respondents thought that whatever scheme was adopted, this should be ‘cost neutral’ or ‘self-financing’. Respondents thought that the costs associated with a DRS (collection, processing, etc.) should be able to be balanced by the income generated (through selling recycled material, charging deposits, etc.) as long as the scheme was ‘well run’.

4.73 In addition, it was common for respondents’ comments to include general views on who should fund the cost of recycling and litter reduction. Most commonly, respondents emphasised the importance of upholding the ‘polluter pays’ principle, and to affirm that producers (and manufacturers) should bear any costs associated with recycling and litter reduction. However, some respondents said that this was a ‘shared responsibility’ and that ‘everyone’ (including central government, local government, and consumers) needed to contribute, while others emphasised that, since this was a ‘national policy’, it should be financed centrally.

Overall views of cost implications for local authorities

4.74 Respondents were divided in their views about the cost implications for local authorities. These divisions were present within, as well as between, subgroups of organisational respondents. There were five main perspectives offered as follows:

• Those who were concerned that local authorities would be disadvantaged as a consequence of introducing a DRS both directly (e.g. through loss of revenue streams) and indirectly (e.g. through financial penalties relating to long-term waste management contracts). These respondents did not think the potential benefits would compensate for these losses. 
• Those who thought that there might be costs for the local authorities in the start-up phase (relating to, for example, the purchase of additional machinery), but that these would reduce as the scheme was established and embedded, and became more efficient. These respondents often suggested that any initial costs should be funded by central government.
• Those who thought that the costs to local authorities (through, for example, losing valuable recyclate) would be balanced by the benefits (such as, being able to rationalise collections, reduce landfill costs, and reduce the costs relating to street cleaning). Moreover, some respondents said that the requirement set out in the EU’s Circular Economy strategy to ‘capture 100% of the net economic cost of dealing with packaging waste’ meant that local authority costs in relation to kerbside recycling / collections would need to be met by producers; so, by definition, there will be no cost implications for local authorities.
• Those who thought that local authorities would benefit financially from the introduction of a DRS. These respondents thought that the benefits (as set out in the bullet point above) would outweigh the costs.
• Those who thought that (i) there was not enough information available to determine what the cost implications for local authorities would be and / or (ii) that potential costs / savings were hard to quantify. These respondents thought that (i) full specification of the DRS, together with (ii) additional modelling – at a local level – of the likely financial impacts across a wide range of variables were required in order to take a view on this. The modelling would need to cover not only physical aspects relating to collection, processing and disposal, but also aspects relating to the public’s (behavioural) response to the introduction of a DRS.

4.75 Note that respondents sometimes offered more than one of these perspectives.

4.76 Respondents often cited evidence to support their perspectives, although some explicitly noted the lack of consensus in the available evidence. 

Concerns about cost implications for local authorities

4.77 A range of concerns was expressed by those who thought there would be negative cost implications for local authorities. These concerns were identified not only by local authorities and other public sector organisations, but also by a range of other organisations (including food and drink producers, waste recycling and management organisations, packaging manufacturers and retailers) as well as some individual respondents. The main concerns were that:

• Local authorities have invested in developing their kerbside recycling activities over a long period. The introduction of a DRS needs to be seen in that context and must be designed from the outset to complement (not compete with) existing services. Respondents contrasted this with the situation in other countries which either (i) did not already have kerbside recycling arrangements in place and / or (ii) had discontinued their kerbside recycling after a scheme was introduced, and argued that the evidence from these other places was not necessarily transferable to the Scottish context.
• Local authority budgets are under a great deal of financial pressure. It would be highly detrimental if local authorities were worse off as a consequence of the DRS and needed to reduce other services to fund their recycling activities. 
• It was the responsibility of the local authority to carry out kerbside recycling. This was enshrined in the Waste (Scotland) Regulations 2012 and had been further articulated within the Scottish Household Waste Charter. These requirements would have to be reviewed in the light of any new arrangements. The current recycling targets would also have to be reviewed.
• Local authorities should not be expected to separately identify in-scope containers which are collected through kerbside recycling; this would be complex and expensive to organise.
• Local authorities would lose the most ‘valuable’ materials from their waste collection. Thus, the amount of income (per tonne) that they would generate from their recyclate would be substantially reduced. The removal of glass from the income stream was thought to be particularly problematic.
• Local authorities would be required to pay ‘contamination penalty charges’ and / or increased ‘gate fees’.^[11] There would also be financial penalties for withdrawing from existing long-term contractual arrangements with private sector waste management services. In addition, local authorities might incur costs relating to the modification of existing recycling facilities.
• Whilst a DRS would be likely to reduce the volume of material to be collected in kerbside recycling, these reductions would not necessarily ‘translate’ into efficiency gains. Local authorities would still be required to undertake collections, and these would not be any quicker or easier with the removal of DRS items. If service redesign was required, this would incur a cost.

4.78 While some respondents agreed that there would be financial benefits to local authorities of a DRS (for example in terms of reductions in the requirement for street cleaning, reduced landfill and waste management costs) these would not be sufficient to offset the costs. (Note that some local authorities provided details of modelling which they had carried out to quantify the losses associated with introducing a DRS.) Thus, there were concerns that jobs would be lost as a consequence.

Positive views about the cost implications for local authorities

4.79 Some respondents thought that, even if there were negative cost implications for local authorities in the short term, there would be (net) revenue benefits to local authorities resulting from a DRS. Respondents with this view included DRS companies as well as (some) community bodies, environmental consultancies, charities, food and drink producers, and other organisational respondents. These respondents highlighted that:

• Local authorities would benefit financially from lower landfill / residual waste disposal costs, lower costs in relation to dealing with littering (e.g. street cleaning), and lower collection costs (given the reduced volume of material processed through kerbside recycling).
• Long-term contracts for waste management can be renegotiated (using the ‘force majeure’ clause) if a DRS is introduced; this will mean that financial penalties will not be implemented. 
• Local authorities could develop a new income stream through separating out the in-scope DRS containers that were put out for kerbside recycling.
• Local authorities would have the opportunity to develop new collection points / recycling facilities which could be profitable if well managed.

Other comments

4.80 There was a range of other comments made in relation to this question including that:

• Local authorities should be compensated for any losses incurred following the introduction of a DRS. Respondents who suggested this said that the compensation should be provided either through the EPR mechanism, by the scheme administrator, or by central government. (Note that some of these respondents specifically referred to compensation during the ‘transition phase’.)
• There may be negative unintended consequences for consumers. In particular (i) people may ‘devalue’ non-DRS containers and stop recycling these and / or (ii) those who are already committed to recycling may object to having to pay an upfront deposit. 
• The effects will not be uniform across authorities. In particular, some respondents argued that rural authorities would benefit, others that rural authorities would lose out, and a third group thought that those authorities which currently separate their waste into different streams may be disadvantaged. 
• More information is required in relation to the practicalities and costs of (local authorities) sorting and collecting unredeemed deposits from their kerbside recycling activities. It was suggested that this had been done successfully in New Zealand. Others suggested this was undesirable as it would put local authorities in competition with the private sector, and could increase the likelihood of fraud.