Drink producers lie at the heart of the deposit return scheme. Their drink containers are the subject of the legislation and producers are ultimately responsible for what happens to these containers.

The scheme has been designed to ensure that producers are legally fulfilling their environmental responsibilities, and Circularity Scotland has been created to help them do this.

The Scottish Government's deposit return scheme legislation defines a producer as "the Brand owner" or, where the brand owner is outside the UK, "the importer". Therefore, if you make drinks in the UK, retail drinks under your own label or import drinks into the UK, you are viewed as a producer and have certain legal obligations under the scheme's regulations. 

These obligations include registration with SEPA and the responsibility to take back packaging, repay deposits and pay handling fees. However, responsibilities like these are more easily enacted by appointing the scheme administrator, Circularity Scotland, to perform them on your behalf.

In Scotland's deposit return scheme, a producer is defined as being a drinks brand owner or importer into the Scottish market, or the website operator for online sales.

What you need to know  

Producer agreement

The producer agreement allows the scheme administrator, Circularity Scotland, to meet the deposit return scheme regulations on your behalf.

Producer registration

Producers need to register with Circularity Scotland by 12 January 2024 to enable Circularity Scotland to fulfil their duties as outlined in the scheme's regulations. 

Producer fee

The producer fee is the financial contribution that producers will make to ensure that the scheme runs smoothly. The overall fee will be based on the number of containers you put on the market. The rate will vary for different materials, but that rate will be the same per container for every producer.

Packaging requirements 

As a producer, you are not required to add new labelling to packaging sold in Scotland for the deposit return scheme.

However, creating a new label and barcode will improve the security of the scheme. It will also enable you to add a consumer-facing logo to your label, highlighting that your product is in the scheme. For this reason, the producer fee will be higher for those products that stick with the existing UK-wide label and barcode systems.