Deposit return schemes – there’s never a convenient time for a revolution

With the publication of proposed legislation, the Scottish Government has reaffirmed its position to go ahead with a deposit return scheme (DRS) for the recycling of PET plastic and glass bottles and aluminium or steel cans between 50ml and 3L in size.

The scheme, which reimburses 20p to the buyer of every in-scope container returned to any location that sells drinks to take away, either via a reverse-vending machine (RVM) or manually, has been hailed as a crucial step in the right direction by recycling campaigners and activist.  

However, retailers and producers have disputed plans that would heap an avoidable extra cost burden on them and, ultimately, the consumer. In particular, the inclusion of glass in the scheme would place demands on retailers because of the sheer size and weight of the material involved.  

Further complications arise as the Scottish scheme is following an accelerated timeline for delivery, slated to commence by the end of the country’s current parliamentary term in May 2021. If that deadline is met, Scotland will have a DRS years before any similar scheme covering the rest of the UK. Consultation on a solution for England, Wales and Northern Ireland commenced in February 2019.

Ambitions and challenges

While the benefits of DRS are undeniable and public support is overwhelming, the ambitious start date, set against the backdrop of ongoing Brexit complications, provides a number of challenges. 

The preferred option would be for a UK-wide DRS to go live at the same time across the whole Union. That way, product identifiers contained within existing barcodes could be used to track and trace eligible DRS drinks containers without disruption and added cost to the supply chain. 

Barcodes would still need to be updated in this case to prevent fraudulent reimbursement from pre-scheme containers entering system.

The impossibility of a harmonised, UK-wide programme in the given timeframe means that the Scottish Government are out ahead of the pack in terms of scoping out the most efficient and effective measures to run a solo DRS.

The lack of a unified UK DRS also brings the potential for defrauding the scheme to the fore. For example, a lorryload of stock purchased in England where the deposit has not been paid, could be transported into Scotland and deposits redeemed en masse, if no unique identifier is placed on the container.

Labelling is not mandated in the draft regulations, to combat this, Zero Waste Scotland is working with the implementation advisory group and other working groups to assess labelling options. 

In our opinion, this could take two main routes:

  • A Scottish DRS logo to appear on all UK-wide products eligible for the scheme
  • A Scotland-specific product identifier encoded into the existing the barcode, to mark DRS-compliant receptacles 

In the first instance, a UK-wide Scottish DRS logo, introduced in addition to the existing barcode, would allay fears about disruption in the supply chain, as it would negate the need to manage Scottish stock separately. That said, it would greatly increase the opportunity for cross-border fraud. 

In contrast, a Scotland-specific product identifier encoded in the barcode could have a significant impact on the existing supply chain, which has matured over many years to serve the entire UK. 

Producers would have to plan for label design changes and introduce the transformation needed to manage anticipated disruptions to production lines, sales forecasting and logistics management, or to absorb the cost of anticipated fraud.

Standards in the mix

In essence, the adoption of either approach would have its advantages and drawbacks, and standards definitely have a role to play in any forward movement, as does consideration for the future of on-pack labelling. Currently, GS1 is in the strategy phase of a three-year programme in response to member interest in the latter.  

The ambition is to transition to a single 2D barcode that uses the GS1 Digital Link to solve multiple use cases, yielding additional label space, providing each physical object with a link to a digital counterpart and references to sustainability and recycling information. Our first thoughts on the matter will be ready for publication by the end of this year – so watch this space.  

Traceability and transparency have become key enablers for trust and safety in the supply chain, not only between consumers and producers, but also between manufacturers and their suppliers. 

For this to be workable, the sharing of data between multiple partners – who are likely operating different IT systems and using incompatible taxonomies – can most efficiently be solved and future-proofed using a standardised approach. 

The potential for cross-border fraud remains, necessarily, front of mind, and the best solution within the allowed timeframe will be totally dependent on the allocation of new Scotland-specific product codes.

This may impact consumer choice and price in the near term, but will reunite the supply chain using innovation built upon the momentum for product serialisation and GS1 Digital Link.

Despite protestations in industry circles, well-needed change is coming to the way that we consume materials that have harmful consequences for the global environment. 

By their very nature, revolutions are an inconvenient step away from the status quo. For this specific revolution to succeed, it must be standardised.      


Industry news