FAQs: Deposit Return Scheme Regulations and Compliance

If you sell single use beverage containers in Scotland, yes, unless you meet very specific exemption criteria.

Compliance with DRS regulations

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Yes, you will need to register to act as part of the scheme. Details will be provided by SEPA/the Scheme Administrator in due course.

Compliance with DRS regulations

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SEPA has powers under The Environmental Regulation (Enforcement Measures) (Scotland) Order 2015, including the power to impose fixed or variable criminal penalties for noncompliance (on summary conviction, a fine not exceeding the statutory maximum of £10,000, or on indictment and conviction an unlimited fine).

Compliance with DRS regulations

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SEPA will be the overall regulator of the scheme and will enforce compliance with DRS. It will have enforcement powers including the ability to enter your premises, carry out investigations, make purchase tests and returns, question owners and staff, see copies of relevant documentation etc.

Compliance with DRS regulations

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Yes. If a consumer buys a Pepsi 500ml from an independent convenience store in John O’Groats, the consumer must be able to return it and redeem the deposit in a hypermarket in Gretna Green if they want to.

Equally, if a small store only sells Pepsi PET bottles and cans, it will be required to take back Pepsi glass scheme containers too.

Remember, the intent is that it is as easy to return a container as it is to buy the product. This is deliberately designed to encourage the highest possible level of redemptions, collections, and recycling.

Compliance with DRS regulations

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You can sell these products as normal, however, it must be clearly shown at point of purchase that these are not part of the scheme.

The practicalities of this are clearly more complex in the supply chain, and as such please expect further guidance in due course.

Compliance with DRS regulations

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Yes. The retailer is only required to accept the return of scheme containers. You will have access to a register of these for the avoidance of doubt.

SEPA guidance will inform retailers and wholesalers of their obligations to charge the deposit and how they can evidence discharging this obligation, which could involve the keeping of records.

Compliance with DRS regulations

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Yes. Anyone, including voluntary or public organisations, can apply to operate a return scheme from a non-retail premises. We would expect several organisations to do this, on either a permanent or ad-hoc basis, including schools, community centres, recycling centres, charity shops etc.

Such organisations will need to apply to Scottish Ministers to register as what will be known as a “voluntary return point operator.”

We expect this to be a straightforward application process, which will include basic requirements (name, address, location, access to a return point, hours of operation, volume expectations etc.).

Compliance with DRS regulations

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