David Harris Answers the industries Concerns on The DRS

Head of OnTrade Scotland Justin Wingate puts the questions supplied by the industry to Circularity Scotland Chief Executive David Harris

Why has the date of 16th August been so “set in stone” as a go live date for the scheme when not only Lorna Slater MSP but CSL & it’s partners admit they are not yet ready but every venue ,operator & supplier is expected to be ready.

The “go live” date for the Deposit Return Scheme is set by the DRS regulations, which were passed by the Scottish Parliament. We’re fully confident that the scheme will be ready on that date.

We’re already seeing major investment from producers and retailers to prepare for the scheme, with work underway to install reverse vending machines at many sites across

Scotland. Together with our partners we are investing £100m to develop the infrastructure to deliver the cheme and have recently seen confirmation of the first counting centre in Aberdeen, with many more counting and sorting centres on the way. This will create more than 500 jobs.

Circularity Scotland was set up by industry to deliver their obligations under the deposit return scheme regulations as efficiently and cost-effectively as possible and we have always said that we will continue to identify new and innovative ways to mitigate the pressure on business and ensure that the scheme works for Scotland.

We’ve already been able to reduce producer fees by up to 40% while still providing the highest return handling fee (the amount paid to those businesses that act as a return point for containers) anywhere in the world. We’ve also just announced further measures to help smaller producers, who we know have been concerned about the cashflow impacts of the scheme. To address these concerns, we have introduced a £22m package of measures, which will provide two-month credit terms and removing the day one and month one charges for producers.

Of course, we recognise that there are still challenges for businesses, and we’re here to help them work through these - it’s by working together that we will ensure the scheme is a success.

Given the fact that the UKG are looking to start their DRS in 2025, would it not have been beneficial and more sensible, to have a joint scheme, which would have cleared many fraud issues, producer issues, stopped consumer on the borders going across for cheaper DRS free purchases, and also more importantly, to allow an already fragile hospitality sector in Scotland time to heal after the pandemic.

[On background – this is a question for the UK government and the Scottish government. Circularity Scotland’s role is to enable business to meet their obligations under the DRS regulations in Scotland, which

set the scope and timescales for the scheme]

What problems do you see with the scheme in its current form given the time pressures that not only CSL & it’s partners have been put under but also industry to implement the scheme which is more complex than any scheme of its kind anywhere in the world.

We don’t underestimate the scale of the challenge in introducing a scheme of this nature and are working with those involved to help them meet their obligations and address their concerns. But we also know from the experience of other countries that DRS has enormously positive impacts and we can’t lose sight of the opportunity DRS provides, both for society and the environment. By ensuring that the billions of drinks containers imported, produced and sold each year do not end up as waste, the scheme will transform how Scotland recycles and protect our environment for generations to come.

Why was there no consultation from Scottish Government & Lorna Slater MSP or CSL with authorities in the countries who have put in place schemes already to learn from mistakes and challenges they experienced?

This just isn’t accurate. We’ve engaged widely with those running schemes across the world to understand how they overcame challenges and we have been able to learn from them what worked well and what didn’t. Indeed, I am in regular contact with the people who lead successful schemes in other countries, and we will continue to learn the lessons from others as we prepare for the scheme now and when it goes live.

Why do CSL think the best way of engaging the entire industry across Scotland to maximise awareness is Roadshow events with limited numbers invited or attending and webinars?

The workshops we held throughout Scotland and online in February were attended by more than 1,000 people and the two-day conference we held in November was attended by another 600 of Scotland’s drinks producers, retailers and hospitality businesses. These were designed to give businesses an in-person opportunity to ask questions, gather information, better understand their obligations and help them prepare for the scheme.

At the same time, we are also engaging with businesses large and small in every corner of Scotland daily through our dedicated customer services team as well as working closely with trade associations and industry groups –including those working with many of your readers – to give them the information they need to help their members get ready for the scheme.

There is a huge amount of information on our website about how the scheme will work, but we’d also encourage any business that will be impacted by DRS to get in touch with us directly so that we can answer their questions and give them the information they need. If they haven’t already, we would urge businesses to contact us on 0141 401 0899 or via our contact form so that we can support them in getting ready for DRS.

Do you feel enough is being done by Scottish Government, Lorna Slater MSP, & CSL to recognise and address the concerns of the industry as a whole in Scotland given the comments of Fergus Ewing MSP which clearly & publicly voiced displaying what the vast majority of people across the hospitality sector and drinks industry in Scotland feel that it is putting thousands of jobs & hundreds of businesses at risk? How do you as Chief Executive of CSL and the wider CSL organisation propose to address these concerns in a proactive way?

As I said earlier, we’ve been formed by industry – and by that, I mean producers, retailers, and trade associations representing hospitality – in order to meet their obligations under the scheme as efficiently and cost-effectively as possible. At the heart of this is making sure that the scheme works for business, because only then will it be effective. Circularity Scotland is not part of government – we are a private company, and we all come from a business background. That means we fully recognise the challenges that this scheme poses, and that we’re actively working to address these. We’ve already seen this through the reduction in producer fees, the increase in return handling fees, the pragmatic approach to exemptions for businesses that don’t want to act as return points and the indication that online takeback will only apply to the largest supermarkets and won’t be introduced until 2025. And, most recently, we’ve seen it in the cashflow support we’ve announced for smaller producers.

This all demonstrates that we are listening to industry and working with them to identify innovative ways to make the scheme as effective as we can. We’ll continue to do this right up to August and on an ongoing basis once the scheme is in operation, and where we can make improvements, we won’t hesitate to act.

Will there be an extension of the exemptions criteria to allow pubs, bars, restaurants etc. that provide a takeaway or delivery service and also include the occasional bottle of wine or beer with the order, (therefore an off-sales transaction) to remain in the closed loop scheme? As you know many started this during Covid and continue with this service.

Last year the Scottish Government announced a streamlined exemption process, which in practice means that many businesses who don’t believe it is appropriate for them to act as return points will largely be able to secure an exemption. Ultimately, the decision on whether to grant an exemption lies with Zero Waste Scotland, not us, but the principle behind the streamlined exemption process was to allow businesses like pubs, bars and restaurants selling takeaway or delivery drinks to secure an exemption. Circularity Scotland are able to assist these businesses with applying for an exemption.

What would you like to say directly to the hospitality industry and the drinks industry in Scotland who are clearly and understandably confused, frustrated & becoming more angry at present?

I fully understand that many businesses are concerned by the DRS and it’s potential impact on their businesses. Some of these come from misunderstandings about how the scheme will affect them, but many are legitimate concerns. That’s why we’ve introduced a range of measures to address these – and where issues still exist, we’re working hard to identify new solutions. Ultimately, all successful deposit return schemes across the world have improved and become more efficient over time and Scotland’s will be no different.

I would also stress that we’re here to help – where we can answer questions we will, and where we can make improvements, we will take action. We’re absolutely committed to ensuring DRS is a success for Scotland and by continuing to work together we know that we can have an incredible impact in protecting the landscape and environment that makes this country so special. Our customer service team are ready to assist any business needing support with the DRS, please contact us in order that we can provide you with the correct information and assistance.

For more information please contact: circularityscotland@citypress.co.uk