³ÉÈË¿ìÊÖ

The position taken by Circularity Scotland Ltd (CSL) in respect of container and return point numbers, as I understand it, is set out at Annex F of the amended Business and Regulatory Impact Assessment (BRIA) for our Deposit Return Scheme (DRS) published in December 2021.

CSL’s position in respect of number of reverse vending machines is that they expect roughly 3,000 of these as set out in the Full Business Case for DRS.

CSL had no sight of the content of the amended BRIA in advance of publication.

The economic model underlying the analysis in the amended Business and Regulatory Impact Assessment (BRIA) for Scotland's Deposit Return Scheme was developed in line with best practice by Zero Waste Scotland on behalf of the Scottish Government. The key inputs to the model are set out at table 2 of the amended Final BRIA.

Audit Scotland provides advice and support to ensure that public money is spent properly, efficiently, and effectively. Scotland’s Deposit Return Scheme (DRS) is financed and administered by industry under the principles of producer responsibility, therefore Audit Scotland is not involved.

The centralised BRIA quality assurance services provided by the Better Regulation team has ceased, their last meeting was in February 2018.

Since July 2021 SEPA has advised that the same vehicle that is used for delivery can be used for the backhaul of scheme packaging provided that:

• the haulier is a ;
• where backhaul is carried out in a vehicle used to transport fresh food, there is sufficient separation and a barrier to prevent contamination of waste materials with organic matter.

This advice was published as part of a series of on SEPA’s website on 8 March 2022.

Stock keeping arrangements related to Scotland’s Deposit Return Scheme (DRS) are a matter for industry to determine; our Regulations do not mandate a separate Scottish label or barcode for in-scope containers.

We are analysing the text of the Act to understand how it could interact with Scotland’s Deposit Return Scheme (DRS), but in order to assess impact fully we need to understand the UK Government’s intentions for its own DRS. We have not yet seen their response to their recent consultation.

The figure is based on Circularity Scotland Ltd’s assessment of its expected annual turnover as scheme administrator once it is in steady state.

We anticipate that implementation and operation of DRS will generate a range of business and employment opportunities in the extensive infrastructure and logistics required for the scheme, for example in the construction and operating of sorting and bulking centres.

Section 34 of the Environmental Protection Act 1990 requires those handling waste to ensure that it is handled in a fashion that promotes high-value recycling.

Return points, producers and Circularity Scotland, when handling returned scheme packaging, including glass, will therefore have an obligation to promote high-value recycling regardless of whether the glass is collected manually or by the use of reverse vending machines.

Participation of small producers is vital to the success of the scheme and we believe we have taken their needs into consideration in designing DRS.

We have consulted extensively with businesses of all sizes that will be affected by the implementation of Scotland’s Deposit Return Scheme. We are not aware that any producers have decided to cease doing business in Scotland, although we are aware that some have expressed concerns about whether they will continue to sell their products in Scotland.

This is one of the reasons why we have applied a de minimis for the SEPA registration fee. This will remove a cost for businesses operating below the current VAT threshold, benefiting around 1,600 of the more than 4,000 anticipated producers selling into the Scottish market