The UK government has granted temporary exemption under the UK Internal Market Act 2020, allowing the Scottish deposit return scheme (DRS) to launch ahead of the rest of the UK. This recent decision has prompted the Scottish Grocers’ Federation (SGF) to call for further clarity and certainty around the implementation of the scheme. As SGF CEO, Dr Pete Cheema OBE, confirms, “the proposed removal of glass from the DRS will help simplify and streamline operational processes, as will the moves to standardise the deposit charge, bar codes, and labelling across the UK and arrangements around scheme membership.”
However, with the requirement for nationwide UK SKU’s, the producers of scheme articles will need to review their decisions around range reduction for the Scottish convenience market, which will significantly impact the sector in terms of time and resources. Moreover, the changes will require a complete reset of the scheme, requiring replanning, refactoring, and re-costing. Thus, compensation will be necessary for the changes, as businesses have made significant investments and signed up to contracted commitments such as reverse vending machines.
Dr Cheema emphasizes that the Scottish government should have resolved the many outstanding issues with the scheme earlier, such as the arrangements for price-marked-packs, VAT, online takeback, and the required exemption from the IMA. Resolving these issues earlier could have potentially avoided unnecessary expenditures. Given the extensive changes being proposed, the implementation date of 1 March 2024 may need to be reviewed to provide sufficient time for businesses to prepare and adapt to the new requirements.
In conclusion, aligning the Scottish DRS system with Westminster requires the UK government to pass its own regulations, which have not been done to date. SGF, as a member of the Scottish Government’s DRS Ministerial Strategic Assurance Group and the DRS Retailers Sector Specific Working Group, will continue to play its part in ensuring a fit-for-purpose DRS.

