Circularity Scotland is a not-for-profit Company Limited by Guarantee with members drawn from the producer and wholesaler community, based on production volume, and the retailer community (based on collection volume and numbers of return points). 

The company's legal setup requires us to have members. 

It was important for us to have a broad representation of members from across the key sectors affected by the deposit return scheme. This gave us an indication of support for the approach we are taking to fulfil the duties of scheme administrator.  

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

No, producers do not need to be a member of Circularity Scotland to appoint us 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.

For producers, placing more than 10 million containers onto the market in Scotland 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 Scotland on an annual basis, qualifies for membership.

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

Regardless of membership status, companies will be able to appoint us to act on their behalf to fulfil obligations under the DRS Regulations 2020.

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 an advantage over another and that the scheme is inclusive and run as efficiently and effectively as possible.

We will be led by an independent board of experienced directors and a team of professional executive staff. Members will not manage the day-to-day running of the company or operational aspects of the deposit return scheme. 

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 an approved nominee member.

Members cannot derive any benefit – financial or otherwise – over those who simply ‘appoint’ us as their scheme administrator. There is no obligation on producers to be a member of Circularity Scotland to appoint us 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.