Yes, retailers can apply for a DRS exemption to act as a return point. However, the scheme will only work well if it is implemented as an “all in” scheme. Exemption possibilities are therefore designed to be limited to only where essential.
We would also expect most retailers to want to be involved in the scheme as much as possible, as offering a good DRS return experience to consumers as it becomes part of the shopping cycle will become an important part of the retail experience in the same way as ease of payment or parking is.
There are two different routes for granting a Deposit Return Scheme exemption:
Applications must be made directly to Scottish Ministers (rather than to, or through, a producer or Scheme Administrator.) Applications for exemptions will open in due course. The Scottish Government is working with key stakeholders to develop final guidelines and support to assist businesses who need to apply for an exemption.
It is expected exemption applications will be able to take place from 2021.
If you make an application and Scottish Ministers decide to grant an exemption, they must within 7 days of the date of that decision give you:
In turn, they will also publish and maintain a list of retailers who have been granted an exemption.
You are also obliged in future to notify Scottish Ministers if any of the conditions which led you your exemption change, which may lead to a review of your exemption.
Once the exemption is live, you must clearly display information in your outlet conveying that you do not, because of an exemption, operate a return point and provide details of the nearest alternative return point(s).