New rules ring alarm bells for Uist drinks producers and retailers

Scottish Government appears to be pushing ahead with its controversial new Deposit Return Scheme (DRS), despite warnings that the Scheme will not be ready by the August launch date.

The new DRS will require all drinks producers and importers to introduce a 20p surcharge on every single-use drinks container sold in Scotland. The charge is passed on through the supply chain, through wholesalers, retailers and hospitality outlets, with consumers finally paying the 20p as a deposit, to be refunded when the drink is returned. This loop is designed to ensure that nobody is out of pocket.

The new rules apply whether or not the drink was manufactured in Scotland, and cover all containers made from PET plastic, glass, steel and aluminium.

With only five months before the scheme’s launch, producers, retailers and hospitality outlets have echoed the findings of the Scottish Government’s own Gateway Review, published in December last year, which stated in the strongest possible terms that the Scheme should be delayed: “The Review Team finds that a fully functioning and compliant DRS cannot be in operation for the revised August 2023 schedule.”

The DRS was subject to an Islands Impact Assessment in March 2020, which highlighted a number of island-specific impacts that would result form the new regulations.

The Assessment recognises the logistical difficulties in transporting waste/recyclables off the islands, but states: “Most islands are net importers of goods and therefore vehicles leaving the islands should have available capacity to back-haul materials to the mainland.” Concerns have been raised regarding ferry capacity, especially in the busy summer months.

The Assessment also noted a potential issue with ‘distance sales take-back’ and the requirement for producers, importers and wholesalers to be responsible for collecting returned containers, regardless of where they are sold. In practice, this means that those drinks sold in Uist are going to cost a lot more to return than those sold in Glasgow. The additional costs associated with distance sellers operating a take-back service, could result in a number of businesses choosing not to deliver to the islands.

With a resident population of less than 27,000 and annual visitor numbers well in excess of 200,000, the Assessment also recognised that ‘the number of containers likely to be returned to retailers would significantly exceed the volumes being sold, creating challenges around both storage of returned containers and cash-flow related to the paying out of deposits.’

The Assessment concludes: “We are confident that the policy does not only look to accommodate islands communities but is optimised for them. The overall impact will be significantly positive, supporting the development of a circular economy, acting to address the climate crisis, and preventing litter and plastic pollution escaping into our natural environment.”

The Scheme was developed by Zero Waste Scotland, is to be administered by Circulatory Scotland and will be regulated by SEPA.

Circularity Scotland is a membership organisation set up by industry stakeholders to manage the operation of the Scheme on their behalf. Its role is to take on producer responsibilities for the collection and recycling of returned materials and effectively ‘administer’ the Scheme. Under pressure from industry, Circulatory Scotland last month announced £22 million of cashflow support measures to help Scotland’s manufacturers prepare for the introduction of the Scheme.

SEPA is the regulator for the DRS, carrying out audits, inspections and enforcement activity.
Scottish Government says that 90% of containers included in the Scheme will be captured for recycling, resulting in 34,000 fewer plastic bottles littered every day, with 76,000 additional tonnes of containers recycled each year.

A spokesperson for the Comhairle said:

“Once the DRS system is fully up and running in the Western Isles, it should help our recycling rates and reduce what we have to collect, bale and pay to be shipped to the mainland.

“The Comhairle has been in contact with Biffa and have offered to assist where we can in making this scheme a success.

“Recycling plastic containers in an Island location is costly due to the haulage costs, so this scheme is welcomed.

“We would hope that all consumers of drinks included in DRS will return containers and get their deposit back.  It will still be counted towards the household recycling figures in the Western Isles and there is an expectation of a much higher capture rate which can only be a good thing for the environment.  We expect to have to review how we collect the remaining recyclable materials but will still provide kerbside collection services.”

Highlands & Islands MSP Ariane Burgess has welcomed the new Scheme, telling Am Pàipear: “I am very excited about the Deposit Return Scheme, which will be a major part of Scotland’s efforts to reduce litter, cut emissions and build a more sustainable economy.

“I understand that implementing DRS is a big change for small businesses to manage, which is why a range of measures have been put in place to support them. For example, there will be no registration fee for producers with an annual turnover of £85,000 or lower. A producer will be charged for each individual container placed upon the Scottish market, so their charges will be proportionate to the size of the business meaning a small producer like a small distiller will pay less than a larger producer.

“This will be the first scheme of its kind in the UK and one of the most environmentally ambitious and accessible in Europe. It will be good for people and planet and it will help us to improve recycling rates – even in areas like Na h-Eileanan an Iar already well known for their efficiency – as well as helping to tackle climate change.

“I am proud that the scheme is being led by Green minister Lorna Slater, who has taken a pragmatic and ambitious approach, supported by industry through Circularity Scotland, and am confident it will be launched in August.”

A spokesperson for the Co-op, said: “We are facing into a climate and environmental crisis and Co-op is committed to making it easier for our members, customers and colleagues to take action that makes a positive difference to our natural environment. As a business we are working hard so we will be ready for the introduction of the Scottish Government’s Deposit Return Scheme.” 

As Am Pàipear went to print, it was still unclear if the Scheme would launch as scheduled.

Uist recycling:
Household and commercial waste in Uist and Barra is collected at the premises and taken to the Market Stance Waste Transfer Station, in Benbecula.

Materials for recycling are compacted to reduce volume and loaded onto lorries for transportation direct to mainland recycling facilities.

Market Stance processes around five loads of glass each year, each weighing around 20 to 25 tonnes, and a similar volume of plastic and cans, each weighing around 20 tonnes.

Around 100 tonnes of non recyclable waste is compacted and taken to Stornoway for landfill, where it is subject to a £98 per tonne Landfill Tax charge.

All in all, more than 740 tonnes of materials were recycled through Market Stance last year.

Despite the islands’ logistical disadvantage, Comhairle nan Eilean Siar’s recycling rates for 2021 were 34.6%, placing us slightly below the Scottish average and well ahead of some bigger Authorities such as Glasgow City Council.