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.

As set out in Annex F to the amended Business and Regulatory Impact Assessment (BRIA) for our Deposit Return Scheme (DRS), published on 15 December 2021, we consider that there is a degree of uncertainty attached to the figures proposed by Circularity Scotland Ltd (CSL) for the number of scheme articles and return points under DRS. For that reason our final and best estimate remains that set out on p19 of the amended BRIA.

Nevertheless, as Annex F shows, even if we were to adopt these two figures there would continue to be a strong economic case for DRS.

We have seen no evidence for higher numbers of RVMs than the roughly 3,000 assumed in the Full Business Case Addendum and I understand that CSL is continuing to work from this figure. That is therefore the figure modelled in the updated Final BRIA that was published in December last year.

As Table 2 of the amended final Business and Regulatory Impact Assessment (BRIA) for our Deposit Return Scheme (DRS) makes clear, the economic modelling in the BRIA assumes that there will be 3,021 reverse vending machines (RVMs) in operation.

Annex F of the amended final BRIA shows that the economic case for DRS remains strong if higher numbers of containers and return points, suggested by industry, are adopted. As we have seen no evidence for higher numbers of RVMs than 3,021, this is also the figure modelled in Annex F.

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.

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 registered waste carrier ;
• 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 DRS Frequently Asked Questions on SEPA’s website on 8 March 2022.

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

Return Point operators are responsible for ensuring that the Reverse Vending Machines (RVM) that they use meet the specifications supplied by the Scheme Administrator, Circularity Scotland Ltd (CSL).

The costs of operating a Return Point, including the RVM, is offset by the Retail Handling Fee paid by CSL to Return Point operators per in-scope container they process.