Deposit return scheme for Scotland: equality impact assessment

Stage 1: Framing & background

Undertaking an equality impact assessment is an iterative process which has been conducted throughout the planning of Scotland's Deposit Return Scheme (DRS). This final equality impact assessment is the third one to have been published as part of this process and builds on the previously published interim and full assessments.

An interim equality impact assessment (EQIA) was published^[2] as part of the Scottish Government's public consultation on the design of a DRS for single-use drinks containers which took place between 27 June and 25 September 2018. The interim EQIA provided preliminary and indicative insight into the risk of unintended equality impacts as a result of introducing DRS.

A full EQIA was published^[3] in July 2019 as part of the launch of the preferred design for DRS. The full EQIA focussed on some of the potential issues identified in the interim EQIA and considered what mitigations could be put in place to reduce these.

This final EQIA is published alongside the final DRS Regulations, which will be laid in the Scottish Parliament for 54 days before a plenary vote. This final EQIA does not identify additional equality impacts, but rather serves to provide information on the mitigating actions adopted and planned in order to address the potential equality impacts identified in the interim and full EQIA. This document should therefore be read in conjunction with the interim and full EQIA, as together all documents constitute the complete EQIA for DRS in Scotland.

Policy aim

Scottish Ministers are introducing a Deposit Return Scheme for single-use drinks containers. This new policy forms part of the Scottish Government's wider ambition to develop a more circular economy which keeps products and materials circulating in a high-value state of use for as long as possible – maximising resources to benefit the economy and the environment.

Deposit Return Scheme for Scotland Regulations

The Scottish Government announced the design of DRS on 8 May 2019 and published draft Regulations on 10 September 2019. The scheme design and Regulations have been informed by extensive public consultation, international best practice and engagement with a broad range of stakeholders.

The scheme design will mean that consumers are charged a 20p deposit when they purchase a drink in a single-use container made from PET plastic, aluminium, steel, or glass; they can redeem the deposit by returning the container to any retailer selling drinks covered by the scheme for consumption off the premises.

Retailers can choose to install reverse vending machines (RVMs) to collect the bottles and cans and return deposits. Alternatively, they will have the option to return deposits over the counter, collecting the containers manually.

A take-back service for retailers selling by way of distance sales will be included in the scheme to support those customers who are dependent on distance sales for any reason, and non-retail spaces such as recycling centres, schools or other community hubs will also be able to apply to Ministers for permission to act as voluntary return points.

Who will DRS affect?

DRS will impact upon everybody in Scotland who buys drinks in the specified containers. The interim and full EQIAs explore the likely impact of DRS on different groups in Scottish society.

It is important to note that the protected characteristics covered through an EQIA are often not independent of each other and some people may have to deal with complex and interconnected issues related to experiencing disadvantage at any one time.

What might prevent the policy aim being achieved?

Achieving the policy aim will be dependent on businesses and consumers adopting new behaviours to deliver DRS effectively. Ensuring high consumer participation will be key to the scheme's success. As a result, the scheme has been designed to ensure that all individuals, regardless of any protected characteristics, have fair access to return their drinks containers. There are a number of existing and planned mitigations that will be fundamental to ensuring that everyone can equally participate in the scheme. This is fully explained in this final EQIA.