The cohort of producers for the England DRS will depend on whether an ‘all in’ approach is taken that will include drinks containers of any size, or if an ‘on the go’ approach is favoured for containers that are under 750ml and sold as single items.
Within the latest consultation, government seeks views as to whether unredeemed deposits should part-fund the DMO, or whether funding should also come from annual producer fees. It’s also suggested that all retailers of in-scope materials will be obliged to host return points, with some exceptions based on proximity to other points and breaching of safety regulations.
The Scottish Government have confirmed that all drinks contained in polyethylene terephthalate (PET) bottles, metal and glass will be included, from 50ml to 3l. Mixed material pouches, cartons, HDPE and cups are excluded.
Online retailers will be included in the scheme but will not act as a return point, but they will have to offer a takeback service. Retailers meanwhile can choose to install reverse vending machines (RVMs) to collect the bottles and cans and return deposits. Alternatively, they will have the option to return deposits over the counter and collect the containers manually.
Scotland meanwhile has already confirmed a deposit cost of 20p with retailers expected to collect a target percentage of DRS containers. The Scottish Government will confirm details soon.
Producer fees will be set to cover costs associated with the logistical, administrative and recycling activities surrounding the DRS. The second DRS consultation seeks views as to how broad these payments should be.
In-scope containers will likely have to be earmarked for the deposit mechanism, for instance via their SKU codes. This will be especially important given the four devolved administrations may have different DRS structures.
If the deposit is set at 20p, this will have to be traceable to the scheme administrator or Deposit Management Organisation (DMO). It will also be necessary to organise a system whereby consumers are reimbursed for returned packaging, if you have retail premises.
If you have a retail site that sells in-scope material, you will likely have to host consumer take back. This may involve installing a reverse vending machine or having a back of store area to keep empty containers. If you are a producer without physical retail sites, you may be obliged to collect scheme packaging from return points.
The DMO, if implemented, would be responsible for managing financial flows, including producer fees, logistics, and potentially infrastructural activities such as maintaining reverse vending machines. If this were the case, the logistical and administrative responsibilities above may be alleviated.
We are developing further services to support our members with the future requirements of the DRS and are working with government and industry to seek further clarification on the mechanics and requirements of the system. We will continue to offer guidance as legislation is updated and we will let our members know what further support we will provide in the future.