Scotland’s Deposit Return Scheme has been delayed until October 2025.  

If you have questions regarding producer registration, please contact SEPA at [email protected].

 

Below is a list of questions your business might have about Scotland’s Deposit Return Scheme.

If you can't find the answer to your question, please contact us.

CSL – Circularity Scotland Limited

RHF – Return Handling Fee

DRS – Deposit Return Scheme

RPO – Return Point Operator

EAN – European Article Number

RVM – Reverse Vending Machine

EPR – Extended Producer Responsibility

SEPA – Scottish Environmental Protection Agency

LSP – Logistics Service Provider

SKU – Stock Keeping Unit

OEAN – Old European Article Numbers

TA – Trade Association

PET – Polyethylene Terephthalate

VRP – Voluntary Return Point

PF – Producer Fee

WTN – Waste Transfer Note

RHF – Return Handling Fee

ZWS  Zero Waste Scotland

Topics

Cashflow     Key Documents     Producers     Resources     Return Point Operators     The Scheme

The Scheme

The deposit return scheme will go live on 1 March 2024.

Scheme articles are single-use drink containers between 100 millilitres and 3 litres in size, made of PET, glass, aluminium or steel, and placed on the market in Scotland.

All the drink containers collected will be recycled. Recycling is an essential part of a circular economy, where nothing is wasted and energy use is minimised.

Collecting the drink containers at return points ensures that they are not contaminated with other waste. This means that they can be recycled in the most efficient way possible and the materials can be used to make more drinks containers.

Find out the latest information for online drink retailers on the SEPA website.

A closed loop hospitality provider is a premise where drinks are sold for on-site consumption only, such as a pub.

Cashflow

The deposit was determined by the Scottish Government in the Deposit and Return Scheme for Scotland Regulations 2020. For simplicity and clarity, it is the same price for drink containers of all sizes, made from all in-scope materials.

The return handling fee is a payment made to all return point operators to cover the costs involved in receiving returns.

The timeframe for payment after the collection of scheme materials depends on your return point.
 
Automatic return points (those with reverse vending machines) will have a monthly payment process, and manual return points will have a weekly payment process.
 
Invoices will be generated by Circularity Scotland.

Return Point Operators

Return points are a place where consumers can return their empty drink containers in order to retrieve their deposits. A cash amount equal to the deposit will be reimbursed for each scheme article that is returned.

Registration for return point operators is now open. Please refer to our registration guide for return point operators for a full list of information you will need in order to complete registration.

Yes. If all these drinks are consumed on-site and you can also collect their containers on-site, then you do not need to operate as a return point – but you do still need to register.

This is so the scheme administrator can collect all your eligible containers and refund you for the deposits you paid the supplier or producer. The closed loop blueprint contains more information for hospitality businesses.

After registration, the information you provided will be used to form a logistics plan, including collection frequency and payment day for return handling fees. You will receive this plan as soon as it becomes available.
 
We will be in touch should we require any further information from you.
All businesses and retailers that sell eligible single-use drink containers must register as a return point operator with Circularity Scotland. If you have been granted an exemption, you should state this in your registration.
 
Failure to register is a matter for SEPA, the regulator of the scheme.

Exemption requests must be made through Zero Waste Scotland.

For details on the current criteria for exemptions, please see the Zero Waste Scotland website.

No. However, all return point operators will receive a return handling fee once they have been established which will compensate for the costs of operating a return point.

No. Under the deposit return scheme regulations, there is no obligation for return point operators to install a reverse vending machine. It is up to individual retailers and venues hosting return points whether they wish to install a reverse vending machine or accept returns manually.

No. It is up to each return point operator to select and buy or lease their own reverse vending machine, ensuring it complies with Circularity Scotland's reverse vending machine specifications.

A list of approved reverse vending machine manufacturers can be found under 'Automatic Return Points' within the section entitled Types of Return Point.

Yes. If your reverse vending machine breaks down, you still have an obligation to take back returned containers. Your return point should be prepared to accept containers manually whilst your reverse vending machine is under repair.

An app will be available to help identify what drink containers are included in the scheme.

By scanning the barcode of the drink container in the app, you will be able to tell if the drink container is a scheme article or not.

This app will be compatible with both Android and iOS operating systems.

Retun point operators can choose whether to accept non-scheme articles or not. These can be returned via the same collections process for recycling but will not qualify for a deposit return to the consumer, nor as part of the return handling fee.

Yes, all return points have to accept every drink container included in the scheme, unless otherwise agreed.

This ensures that consumers can return their recyclable bottles and cans, and retrieve their deposits wherever they are in Scotland. Those buying eligible products from your business will be able to return the containers to any return point in Scotland.

Yes, you will need to charge a deposit on all the drinks sold within the scheme and operate as a return point to accept any eligible drink containers, unless exempt. 

Any consumers paying deposits and consuming your product on-site can simply redeem their 20p by taking the empty container to your registered return point. The closed loop blueprint contains more information for hospitality businesses.

No. Only stores that are linked to a particular reverse vending machine will have to accept the vouchers given out by that machine.

A voluntary return point is where an organisation or business has no legal obligation to operate a return point but still chooses to do so. Anyone can apply to operate a voluntary return point provided that they can prove they have sufficient operational and financial plans in place to run the return point for at least one year.

You can apply to be a voluntary return point operator through Zero Waste Scotland.

If successful, you must then register your voluntary return point with Circularity Scotland.

Yes. We recognise that some events, such as music festivals or sports matches, may result in the need for extra collections due to return points being overwhelmed. In this case, we can arrange for additional collections as needed.

Return point operators will be able to request additional collections through the app, the Circularity Scotland website or by contacting our customer support team.

If it becomes clear that your collection volumes are low or unpredictable, you may find an ad-hoc collection is preferable rather than a regular cycle. There will be agreed timeframes for such collections.

No, please do not crush returned drink cans before bagging them. Items from all manual return points will be scanned at the collection depot so barcodes need to be readable.

If you have any queries about the collection and counting process, please contact our customer support team who can deal with a dispute on your behalf.

Producers

According to the deposit return scheme regulations, a producer is:

  • a drinks brand owner or importer into the UK market
  • the website operator for online sales
  • companies that fill and seal drinks into single-use scheme containers at the point of sale for customers to take away

Registration for producers through Circularity Scotland is now open.

Please refer to our guide to producer registration for a full list of information you will need in order to complete registration.

Not necessarily.

All drinks producers and importers must be registered with SEPA. However, if you register as a producer through Circularity Scotland, we will list your business with SEPA on your behalf and complete any reporting duties for you.

Producers will pay an annual registration fee of £365 to be part of the deposit return scheme. No VAT is charged on this fee.

Please note, there is no registration fee for:

  • producers with an annual turnover of £85,000 or less
  • producers that only fill and seal single-use drink containers at point of sale (e.g. crowlers)

Based on other similar systems operating in Europe, it could take up to six weeks for producer registrations to be processed.

If a producer fails to register as such before the 1 March 2024 launch date of the Deposit Return Scheme, they will no longer be able to sell their products in Scotland.

Failure to register is a matter for SEPA, the regulator of the scheme.

No, you do not have to have a scheme administrator and can choose to administer the scheme yourself.

However, the costs and complexity of doing this are likely to prove onerous. This is why the industry has come together to create a single scheme administrator in the form of Circularity Scotland.

Circularity Scotland will work with companies throughout the supply chain to create the best possible systems. By pooling everyone's resources in a single scheme administrator, we can develop the most efficient and economical solutions. 

This will ensure that consumers are presented with a clear and consistent identity so they know exactly what to do with their empty drinks containers. This coherent approach is more likely to meet the Scottish Government’s aspiration of collecting more than 90% of Scotland’s drinks containers.

Payment for the scheme administrator will take the form of producer fees.

Yes. Any business producing drinks for sale on the Scottish market in PET plastic, glass or metal containers between 100ml and 3 litres in size is legally required to take part in the scheme.

See the full list of drink containers included in the scheme.

No, as you do not qualify as a producer under the deposit return scheme legislation. Here, a producer is defined as being “the brand owner” or, where the brand owner is outside the UK, “the importer”.

It is the responsibility of each producer to accurately and regularly report the number of drink containers they place on the market in Scotland.

If you appoint Circularity Scotland as your scheme administrator, we will lay out what is required in full in the contract. You may wish to engage with your trade association to find out how similar organisations are dealing with this legal obligation.

Yes. All producers will be treated equally and have the same producer agreement.

No. Simply Supply Chain has no authority to act as the representative of Circularity Scotland in an official capacity or otherwise, nor has Circularity Scotland provided any backing or endorsement for Simply Supply Chain generally.