Circularity Scotland is a new, not for profit, administrator of the Deposit Return Scheme in Scotland.

Circularity Scotland will work with companies throughout the supply chain – from producers through to hospitality, wholesalers and retailers - to deliver a system that is expected to collect at least 90% of drinks containers across Scotland.

This website will be updated as the setup of the scheme progresses, setting out how the scheme will affect you and providing information for consumers, producers, wholesalers and retailers. In the meantime, please see our Frequently Asked Questions section below, or contact us.

To receive information on the implementation of the DRS, Circularity Scotland is encouraging producers, retailers and members of the hospitality industry to subscribe for updates here.

Subscribe for Updates

Frequently Asked Questions

Scotland’s DRS

For background information on the DRS, its objectives, and the obligations for producers, retailers, and consumers, visit: https://depositreturnscheme.zerowastescotland.org.uk/

The Deposit and Return Scheme for Scotland Regulations 2020 can be viewed online: https://www.legislation.gov.uk/ssi/2020/154/contents/made

Further information on the scheme and government policy (including impact assessments and the Full Business Case) can be found here: https://www.gov.scot/policies/managing-waste/deposit-return-scheme

  • Retailers will charge a 20p deposit on bottles and cans and will take back empty drinks containers, either manually (over the counter) or via a ‘reverse vending machine’ (RVM).
  • Hospitality businesses, like restaurants, bars, cafes and hotels, will have different obligations depending on whether they sell drinks to take away or sell drinks to be consumed on-site only.
  • All return points will get a handling fee to cover costs.
  • An independent, private sector not-for-profit known as a scheme administrator - such as Circularity Scotland, if approved - can fulfil the obligations of retailers and producers, or they can do so themselves.

Throughout the supply chain, every time an item is sold the deposit is charged and paid by the buyer of the drinks. Producers, wholesalers and retailers will each charge the 20p onwards for every container sold, and so are reimbursed in turn.

Producers working with a scheme administrator are likely to be requested to report sales and pay the deposits they have received on the sale of drinks to the scheme administrators so that return points (typically retailers) can be reimbursed for any deposits they have paid out to consumers returning drinks containers.

Further information is available from Zero Waste Scotland, including a video guide to the scheme’s cash flow: depositreturnscheme.zerowastescotland.org.uk/cash-flow

The deposit has been set by Scottish Government at 20p within the Deposit and Return Scheme for Scotland Regulations 2020. This applies to all in-scope drinks containers (glass, can or PET plastic container) in scope of the DRS.

The costs of establishing and running the scheme will be covered by three main sources of funding: a producer fee, revenue from the sale of materials, and any deposits that go unredeemed. In this respect, producers are responsible for the net costs of the DRS.

The Scottish Environment Protection Agency (SEPA) will regulate the scheme.

The Environmental Regulation (Enforcement Measures) (Scotland) Amendment Order 2020 gives additional powers to SEPA to enforce the scheme and sets out the offences in relation to DRS. Civil and criminal penalties apply for failure to comply with the Regulations.

Circularity Scotland

Circularity Scotland is Scotland’s Deposit Return Scheme administrator. Circularity Scotland Limited is an independent not-for-profit company, established by a combination of companies and trade associations representing their broader drinks producer and retail members.

Circularity Scotland Limited is an independent not-for-profit company, established by a combination of companies and trade associations representing their broader drinks producer and retail members.

Membership of Circularity Scotland also remains open to others who wish to join in their own right.

The regulations make clear the onus on all parties to establish a fit for purpose Deposit Return Scheme, and to prepare to meet their legal obligations, in the given timeframe.

Scheme Administrator

The DRS Regulations allow for drinks producers and importers to nominate a scheme administrator to act of their behalf to fulfil their DRS obligations – for instance refunding return points and taking away collections of empty containers from their premises. As administrator, Circularity Scotland will manage the financial flows (fees and deposits) and the collection of materials (returned containers), as well as other administrative functions and logistics.

Circularity Scotland will work with companies throughout the supply chain – producers, retailers and wholesalers – to help deliver a scheme ultimately expected to collect more than 90% of drinks containers in Scotland.

Circularity Scotland will take on the responsibility for operational aspects and day-to-day management of the scheme on behalf of producers who appoint it to act on their behalf; return point operators would be service customers of the scheme.

Shoppers and individuals can expect to see a coherent and effective scheme that makes it easy for them to return their empties.

Membership of Circularity Scotland

No. The initial members of Circularity Scotland include trade associations representing dozens of other companies. Membership of Circularity Scotland also remains open to others who wish to join in their own right.

There is no obligation on producers to be a member of Circularity Scotland to appoint it as their scheme administrator. Likewise, return point operators will be offered service contracts by Circularity Scotland irrespective of their membership status.

Membership of Circularity Scotland is open to producers and return point operators in Scotland, or their trade associations, who meet qualifying thresholds.

Regardless of membership status, companies will be able to appoint Circularity Scotland (if approved as scheme administrator) to act on their behalf to fulfil obligations under the DRS Regulations 2020.

For producers, placing more than 10 million containers into the territory on an annual basis qualifies for membership.

For return point operators, taking back more than 20 million containers on an annual basis and/or responsibility for more than 500 return points in the territory on an annual basis, qualifies for membership.

For trade associations, representing members who collectively place more than 10 million containers qualifies for membership. Alternatively, representing members who collectively are responsible for taking back more than 20 million containers via a return service in the territory on an annual basis and/or who collectively are responsible for more than 500 return points in the territory on an annual basis, qualifies for membership.

Circularity Scotland is constituted as an independent, not-for-profit company. The very nature of an independent Scheme Administrator is to ensure that no party has any advantage over another and that the scheme is inclusive and run as efficiently and effectively as possible.

Circularity Scotland will be led by an independent board of experienced executives and a professional staff. Members will not manage day-to-day running of the company or operational aspects of the DRS.

Producers and return point operators who do not wish to join as members themselves – or who do not meet the qualifying thresholds – can nominate another organisation or member to represent them within the governance of Circularity Scotland. This is through either a trade association or approved nominee member.

Members cannot derive any benefit – financial or otherwise – over those who simply ‘appoint’ it as their scheme administrator. There is no obligation on producers to be a member of Circularity Scotland to appoint it as their scheme administrator. Likewise, return point operators will be offered service contracts by Circularity Scotland irrespective of their membership status.

There is no joining fee for members of Circularity Scotland. As a ‘company limited by guarantee’, the liability of any member of the company is limited to £1.

Return Point Operators

Circularity Scotland will set out more details of how return point operators will be identified and registered with the scheme. This will be published in due course.

Circularity Scotland will set out more details of how return point operators will be identified and registered with the scheme. This will be published in due course.

Yes. Circularity Scotland will work with all return points and those businesses operating take-back services.

Under the DRS regulations, there is no obligation for return point operators to utilise reverse vending machines. It is up to individual retailers and venues hosting return points to decide whether they wish to install a reverse vending machine or accept returns manually. More information and guidance will be set out by Circularity Scotland for return point operators in due course.

Circularity Scotland will set out more information and guidance for return point operators in due course.

It is up to Return Point Operators to select and buy or lease their own RVM, ensuring that it complies with the specs produced by Circularity Scotland.  

Yes. Circularity Scotland will work with all return points and those businesses operating take-back services.

Please visit circularityscotland.com/makecontact and fill in the form – as we progress through the next phase of implementation we’ll keep you informed of progress and anything you need to do.

 

Producers

In Scotland’s DRS, a producer is a drinks brand owner or importer into the market (or the website operator, for online sales).

The Definition of a producer under the Deposit and Return Scheme for Scotland Regulations 2020 can be viewed online: www.legislation.gov.uk/ssi/2020/154/part/3/chapter/1/made

Financial contributions will be through a producer fee, charged on each drinks container placed on the market. The level of the producer fee will be determined at a later date by Circularity Scotland.

Yes. Circularity Scotland will offer its services to all producers (as defined under the DRS Regulations) who wish to appoint it as their agent.

Financial contributions will be through a producer fee, charged on each drinks container placed on the market. The level of the producer fee will be determined at a later date by Circularity Scotland.

Circularity Scotland is constituted as an independent, not-for-profit company. It will run an efficient and effective scheme that achieves the collection targets as prescribed by the DRS Regulations in the most professional and efficient manner possible.

Circularity Scotland will set out more information for producers in due course. 

Under the DRS Regulations, producers are required to register with SEPA from January 2022 onwards. If producers choose to appoint a scheme administrator, this will be carried out on their behalf. Circularity Scotland would expect producers wishing to appoint it as their scheme administrator to register well in advance of the start of the DRS.

Please visit circularityscotland.com/makecontact and fill in the form – as we progress through the next phase of implementation we’ll keep you informed of progress and anything you need to do.

Consumers

At the point of sale, the deposit price (20p) will be displayed separately from the price of products that are in-scope of the DRS. Some containers may also carry markings, logos or text to indicate that they are in the DRS. Circularity Scotland will set out information on identifying products in due course.

Deposits will be refundable and the deposit price (20p) will be displayed separately from the price of products that are in-scope of the DRS at the point of sale. Circularity Scotland is not responsible for the pricing of other parties’ products.

Consumers will get their deposits back when they return empty drinks containers, either over the counter or via a reverse vending machine – or to online seller via a ‘take-back’ service.

Circularity Scotland will set out guidance on redemption methods and donations. It is hoped that a range of causes can be supported should customers choose to donate their deposits.