A return point operator (RPO) is anyone who provides a service that collects the recyclable containers included in Scotland’s Deposit Return Scheme (DRS) and refunds consumers’ deposits. This service can range from accepting returns over the counter and refunding consumers from the till to operating a reverse vending machine which will automatically accept containers and repay deposits.
All retailers and hospitality businesses that sell drinks to take away are legally required to operate a return point. This includes online retailers of drinks.
Many sports venues and clubs, staff canteens and public buildings such as schools and hospitals will also have to operate return points. Visitor attractions and leisure sites such as cinemas and campsites may also need to become return point operators although premises that only operate a vending machine are not required to provide a return point.
This will ensure that all consumers, wherever they live, have access to a local return point, making it easier to return their empty scheme containers helping us to achieve a high recycling rate.
Retailers offering online sales of deposit bearing containers will have to offer a free takeback service allowing the purchaser to return containers and get their deposit back from that retailer.
Businesses can choose to have a reverse vending machine or take back containers manually
Collecting containers from the public
Reverse vending machines
Reverse vending machines (RVM) are sophisticated pieces of equipment that can identify drinks containers inserted and refund consumers’ deposits once the container has been scanned and validated. RVMs can generate vouchers that can be used at retailers to pay for shopping or get a cash refund at the till.
RVMs have been successfully used to support many other deposit return schemes around the world. Return points using RVMs store the returned containers in bags, boxes and bins ready for collection by Circularity Scotland or our nominated logistics partner.
This is when a retailer accepts returned containers over the counter and repays consumers from the till, using accounting and reporting systems to obtain reimbursement from the scheme administrator. They will store returned containers on-site, in bags and boxes provided, ready for collection by the scheme administrator’s nominated logistics partner. Circularity Scotland collects the material and validates each container at a counting centre, and redeems deposits as appropriate.
An app will be created to help you and your staff identify what is included in the scheme and what is not.
What you need to know
Return point operators will receive a handling fee designed to cover the costs of the time, equipment and additional storage space needed to operate the scheme. Information on the Retail Handling Fee is now available, please sign up to access further information.
The level of this fee will be determined annually by Circularity Scotland, based on data and analysis provided by independent consultants to ensure it remains reasonable and current.
Collections will be performed by the CSL logistics partner and will be free of charge which will result in a saving to retailers who currently pay for the removal of disposable drinks containers on their premises. Collection activities will operate seven days a week – depending on the volume of returns the current model is that RVMs could be visited daily while Manual Return Points could be serviced weekly or fortnightly. However, these collection frequencies will be reviewed as part of the registration process and once the scheme is live and adjusted where necessary to ensure an efficient operation as the system beds in.
Each bag and tote box collected will be sealed with a security tag with a unique identifier for the return point operator so they can track its progress through the system. Glass bins will be weighed by the collections driver and reconciled to the uplift location.
We recognise that additional, one-off collections may be necessary at specific return points. This might be triggered when a return point with limited storage capacity experiences a surge following a local event such as a music festival or sports match.
You will be able to request additional collections on our Customer Web Portal or by calling the customer call centre. There will be agreed timeframes for such collections
Repayments of deposits paid out by return point operators will be around 7 days after the collection of their containers. For manual return points, the process is triggered when the containers collected have been processed at the counting centre.
For automatic return points (RVMs), it is when the sacks or totes have been scanned on arrival at the counting centre. We are committed to offering the same level of service to return points at all locations across Scotland - no matter how remote.
There is some flexibility in how you can meet your obligation to accept empty containers. Retailers can apply for an exemption from having to operate their own return point
A typical example is where a small shop could agree an exemption with a larger store nearby. Another type of example is for shops located in a specific location, like a train station or shopping centre, who can agree an exemption with a newly created voluntary return point.
Examples of these might be train stations, shopping centres or food courts where a centralised reverse vending machine could perform the individual retailers’ duties to accept returns.
There are also grounds for exemption on safety or environmental health grounds. If you can demonstrate that operating a return point on your premises would put you in breach of other legislation, such as environmental health and food or fire safety, you can apply for an exemption.
Applications for exemptions should be addressed to Zero Waste Scotland.
Voluntary collection points
These are return points hosted by people who have no legal requirement to provide one. Typically, they will be property owners managing facilities, such as shopping centres and transport hubs, housing multiple retailers or hospitality businesses who want to claim exemptions. They can also be run by community groups wishing to encourage local recycling and generate funding.
You can find out how to apply to set up a voluntary return point at the Zero Waste Scotland Website.
Yes. For the scheme to work seamlessly, we will need to reimburse you from scheme funds for the deposits you pay and monitor what is collected from your return point.
You will be able to register online. You’ll just need to tell us where you are, so we can arrange collections, and whether you are planning to operate a manual return point or an RVM. We’ll also need to know your opening hours, any access restrictions and how you want to be paid.
You can sign up to receive updates and be notified when the formal registration process opens. This will ensure you have ample time to work out the best solutions for your business and for us to help you prepare. Ultimately, there will be over 35,000 return points across Scotland, so don’t leave it to the last minute. Remember, it will be illegal to sell drinks after the launch date unless your business is fully compliant with the DRS Regulations.
The formal registration process will begin in early 2023.
Yes. Circularity Scotland will work with all return points and those businesses operating take-back services.
For any questions about how online takeback will work visit SEPA’s FAQ page
Under the DRS regulations, there is no obligation for return point operators to utilise reverse vending machines. It is up to individual retailers and venues hosting return points to decide whether they wish to install a reverse vending machine or accept returns manually. Generally speaking, a reverse vending machine only makes economic sense if you are handling a high volume of returns. More information and guidance will be set out by Circularity Scotland for return point operators in due course.
The RVM Specification for the Deposit Return Scheme is now available to download from the restricted area.
If you haven’t already, we encourage all producers and return point operators to register for access to these and all previous documents here.
It is up to Return Point Operators to select and buy or lease their own RVM, ensuring that it complies with the specifications produced by Circularity Scotland.
Yes. Every return point has to accept every item that is included in the scheme. This ensures that consumers can return their recyclable bottles and cans and retrieve their deposits wherever they are in Scotland. People buying deposit bearing products from your business will be allowed to return the containers to any other return point in Scotland.
Circularity Scotland are unable to advise businesses on the Deposit Return Scheme regulations and how they apply to their business.
If you are unsure if your business is required to register as a return point please check SEPA’s FAQ page
For questions about exemptions please contact Zero Waste Scotland.
We are not aware of any funding being available to support the Deposit Return Scheme implementation.
The RHF consultant developed a detailed cost model aligned to the requirements of the regulations. Data to populate the model was sourced from the broad range of RPOs that will operate in Scotland, and augmented with and validated by input from other operating schemes around the world (where appropriate), and major independent reference points and indices. The model is designed to reflect the variation in costs across different types and sizes of RPOs and materials