Scotland’s Deposit Return Scheme
Producer Registration Briefing
Circularity Scotland, the Scheme Administrator for Scotland’s Deposit Return Scheme was formed to enable drinks producers to meet their obligations under the Deposit and Return Scheme for Scotland Regulations 2020 (DRS Regulations). The journey to registering as a producer under the DRS Regulations, with Circularity Scotland starts now.
Based on your feedback we now plan to release the final version of the Producer Agreement, including fees and cashflows, on Monday 12th December 2022. At that point we will open our Registration Portal to allow you to complete the registration process. We are encouraging you to get ready for registration by reading this guide and gathering all the information you require to allow for an easy and smooth registration process.
Preparing for Registration
Read the regulations
Please read the regulations to ensure you understand your legal obligations under them. Producers can choose whether to register directly with SEPA or via the Scheme Administrator. The benefit of registering with the Scheme Administrator is that they take on some of the obligations defined in the regulations for producers, such as collecting returned scheme packaging and reporting returns data to SEPA as well as registering your company with SEPA. All registrations must be received by SEPA before 1 March 2023.
Make sure your products are DRS ready
For products to be identifiable as scheme articles, they need to have unique markings, which must be a GS1 compliant barcode. This allows consumers and retailers to recognise DRS products, and Reverse Vending Machines and return points to identify scheme packaging. This must be at container level, so products within multipacks must have a barcode. When you register with Circularity Scotland you will need the GS1 barcode information as part of the data upload.
Gather product data
For most producers, the biggest part of the producer registration process will be preparing the product information, so it is recommended that you start this as soon as possible. You will need to provide information such as the packaging size, attributes and material type, confirm which of your products have scheme marking and identify you as the producer, the type of drink as well as the type of EAN. There is a lot of information to gather, you will find details contained in the CSL Product File Upload Spec and Product File Upload Template. We would recommend that you use the product upload template so that you will not have to enter each item manually.
Work out an annual forecast
An annual forecast will be required for each product. While this is a forecast, and may not be exactly precise, it needs to be as accurate as possible.
Decide who will complete the registration
Decide the roles for the registration process within your organisation – you must have a main contact and an approver.
You must also accept the terms of our Producer Agreement as part of registration. We have received feedback on a number of areas of the agreement we made available on 7th November 2022. We are working to address the concerns of producers based on that feedback. In the meantime, we have produced a key facts document on the Producer Agreement.
Based on feedback received at our Conference, we appreciate producers will require the full agreement before finalising the Registration Process. As we have indicated, the cashflow timings of the scheme are being reviewed. The Scottish Government’s recently announced revision to the exemptions process for return point operators has allowed us to further remodel our cost base and review forecast producer fees.
In the meantime, our customer service centre is open from 9am-5pm Monday to Friday and our team is available to answer any questions that you may have either on registration or on the DRS itself. You can call them on 0141 401 0899 or contact them via the form on the website. Circularity Scotland’s website will be offline from 7th to 11th December for essential upgrades as part of the registration process. During that period, please continue to contact our customer service centre.