ACS welcomes exemption guidance for Scottish retailers ahead of DRS

ACS has strongly welcomed new guidance published by the Scottish Government which takes an important step toward the introduction of a workable and cost effective Deposit Return Scheme in Scotland.

The new guidance, published today (4 November) makes the process of applying for an exemption from the regulations much less complex. While this does not change the eligibility criteria for an exemption itself, it does provide the following important features:

1. A new Return Point Mapping & Exemption Support service to help retailers identify an alternative return point, and to remove the requirement to share commercially sensitive information with other retailers.
2. Confirmation that the Scottish Government will take the size of a premises into account in determining the risk of breaching obligations relating to environmental health. A retailer is likely to be approved for an environmental health exemption if the footprint of their premises is 100m2 or less, or if they are a food-to-go retailer and the footprint of their premises is 280m2 or less.
3. Streamlined evidence and assessment processes that better take into account the challenges facing specialist, food service, and hospitality retailers. This should also speed up the decision making process for Scottish Ministers, and provide clarity to retailers on the outcome of their application.

“This is a welcome step forward towards a workable Deposit Return Scheme in Scotland,” said ACS chief executive James Lowman. “We will work with our members to help them consider whether to seek an exemption or to make their store a return point. This will be a site-by-site decision and this new guidance makes it more likely that the right shops will act as return points in the scheme.

“The UK, Welsh and Northern Ireland governments should note the challenges that Scotland is experiencing in using an exemptions system to define a workable and economically viable network of return points. We need solutions now on how to map the right network of return points to meet our common objective of an effective Deposit Return Scheme operating throughout the UK.”

Scotland’s Deposit Return Scheme is set to go live on 16 August 2023, and will include a range of materials within the scheme including PET plastic, aluminium, steel and glass. Scotland aims to achieve a 90 per cent collection rate for materials in scope by 2025.

The guidance is available to view here.