In calculating the impact of our Deposit Return Scheme (DRS) on local authorities, the economic model in the final Business and Regulatory Impact Assessment (BRIA) uses compositional data on the tonnage (‘dirty’ weights) that Local Authorities actually manage, both recycled and in the residual waste stream, rather than the number of containers placed on the market. This aligns with the (weight-related) costs local authorities actually incur.

Hence the benefit to local authorities set out in table 3 of the amended final BRIA does not change in the sensitivity analysis presented in Annex F. The amended final BRIA can be reviewed here: A Deposit Return Scheme for Scotland: Final Business and Regulatory Impact Assessment (BRIA) (www.gov.scot) .

The benefits of a Deposit Return Scheme to businesses are not only a function of container numbers. As well as reimbursement to retailers through the handling fee, the benefit to businesses includes: savings from waste uplift costs for hospitality return points, reduced operational costs for private waste management companies (relating to uplifts from hospitality customers, albeit offset by reduced income from these activities), avoided compliance costs for producers, and income to the reverse vending machine service industry, as well as potential advertising revenue.

The economic model underpinning the figures in the amended final Business and Regulatory Impact Assessment takes account of a number of factors, and costs and benefits do not necessarily increase in proportion to the change in input. In this case, the addition of 0.5bn containers increases costs through greater potential for fraudulently redeemed containers, but also increases the benefits both from more income from sale of materials and from unredeemed deposits.

The cost to the regulator is estimated based on the number of businesses to be regulated; it is therefore unaffected by any increase in the number of containers.

As Cabinet Secretary for Rural Affairs and the Islands, I made the decision not to suspend the greening rules on Ecological Focus Areas relating to fallow land and field margins following the request from the NFUS. I remain clear in my commitment to supporting farmers and crofters to produce more of our food more sustainably, nevertheless we must continue to acknowledge to ensure agriculture continues to play its part in cutting emissions, mitigating climate change and restoring and enhancing nature and biodiversity.

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.

The information presented in the version of the Business and Regulatory Impact Assessment (BRIA) published in July 2019 has been superseded.

Please refer to the amended Final BRIA published in December 2021 which can be accessed here: https://www.gov.scot/publications/deposit-return-scheme-scotland-final-business-regulatory-impact-assessment/ .

The economic modelling in the amended Business and Regulatory Impact Assessment for Scotland’s Deposit Return Scheme does not account for any VAT being levied on deposits. That is in line with best practice as set out in HM Treasury’s Green Book ( https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/938046/The_Green_Book_2020.pdf ) because VAT is considered to be a transfer payment that does not affect the output or consumption of resources.

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.