Following feedback Circularity Scotland has updated a number of provisions within the Policy Papers which form part of the Producer Agreement.

Policy papers are designed to be able to flex as the DRS develops and evolves to ensure we maintain the most cost effective and efficient DRS.

The changes are summarised below:


Policy Paper 1 - Product Coding and Marking & Policy Paper 4 - Producer Fee Charges & Other Charges – Both Regarding UK wide SKU use

Policy Paper 1 Section

1 Coding Nomenclature- 1.9 UK wide SKU-

 Policy Paper 4 Section

4.The risks and requirements relating to the use of UK wide EAN codes (defined as Scheme Articles in Scotland and non-Scottish in the rest of the UK)


Circularity Scotland has removed the requirement  for the risk assessment and mitigation plan to be submitted to Circularity Scotland by 1st March 2023. Producers are still required to assess the risk associated with the use of UK wide SKUs and implement a risk assessment and associated mitigation plan. Circularity Scotland may at any time ask for the risk assessment and mitigation plan to be submitted in due course.


Policy Paper 4 - Producer Fee Charges & Other Charges


Month 1 Invoice


We have added clarity to the wording to confirm the basis on which the Month 1 payment will be reviewed and rebated to producers.


For visibility, the updated Producer Agreement reflecting the changes based on the above updates, is available here.

The updated version of the Producer Agreement will be uploaded to the Producer Registration Portal. We will also be uploading an updated Guide to Accompany the Producer Agreement shortly to reflect the above changes.

Producers who have already accepted the terms of the Producer Agreement should treat this communication as a variation to the terms which were accepted on registering. All other terms will continue in full force and effect.