Deposit Return Scheme in Scotland

The Scottish Government is introducing a Deposit Return Scheme (DRS) In Scotland from July 2022.

This means that breweries selling beer in small pack in Scotland (either directly or through wholesalers) will be required to carry out the following:

  1. Register with the Scottish Environment Protection Agency (SEPA). This can be done through a Scheme Administrator who will register you on your behalf. Registration will start in January 2022.
  2. Pay a Registration fee of £360 each year. Those with an annual turnover of £85,000 or lower will be exempt from this fee.
  3. Pay a producer fee per container. The amount will be determined by the Scheme Administrator and is designed to cover the costs of collecting and recycling the containers and may vary per container type.
  4. A Scheme Administrator may also require each container to carry an identifying marker, which could include a Scottish only SKU.
  5. Pay a 20 pence deposit for each scheme container.
  6. Maintain records of the number of each type of container sold. It is likely that you will need to provide a breakdown on the number of containers that you intend to sell in Scotland.

Under the Scheme it will be an offence to sell containers without being registered or fail to provide correct information or inform them of material changes in circumstances.

Breweries with taprooms and shops in Scotland:

If you are selling drinks to take way, you will have to accept returned containers. This can be done by either having a Reverse Vending Machine or by accepting manual returns. You will receive a handling fee per container as reimbursement for accepting returns. You may apply to the Scottish Government for an exemption from operating a return point, but will only be considered if there are other options nearby or there is no reasonable way for you to operate one.

Breweries selling beer online to Scotland:

If you sell beer in containers to Scotland online you will be required to provide a takeback service free of charge from the site of delivery to consumers who have purchased these items.

Zero Waste Scotland has prepared a briefing which can be found here.

SIBA’s concerns

SIBA has been making representations on behalf of breweries about the proposals. We believe that the plans will:

– Impose unsustainable costs threatening the future of breweries. As small businesses breweries will struggle to cover registration and producer fees, new labelling requirements and the impact of accepting returned containers.

– Reduce the choice and availability of independent craft beer in Scotland. Global brands can more easily adapt to costs and breweries in the rest of the UK will stop selling in Scotland reducing consumer choice.

– Create more uncertainty for businesses as we do not know if it will be compatible with the scheme proposed for England, Wales and Northern Ireland.

Small brewers would like the scheme to have:

– Proportionate costs for small producers: Registration and producer fees, along with labelling, should take account of size of producer, including de-minimis thresholds for small brewers based on the national Small Breweries’ Relief Scheme.

– Safeguards for small producers: The Scheme Administrator should be required to demonstrate to the Scottish Government how it will give due regard to the requirements of small breweries to stop it being dominated by global producers.

– Fair implementation period: Give small producers enough time to plan ahead and delay implementation so there can be one scheme for the whole of the UK.

– Alternatives to takeback services: Small online retailers should not have to provide a takeback service that few customers will use. Instead they should be able to refer them to their local return point.

SIBA activities

September 2019 – Letter to the Cabinet Secretary for Environment

October 2019 – Article in BusinessGreen

December 2019 – Open letter to the Scottish Government from brewers

January 2020 – Petition handed in from Scottish Brewers

January 2020 – Briefing for MSPs

March 2020 – Briefing for MSPs on Environment Committee

Resources to contact the Scottish Government

Scottish members: If you are a brewer in Scotland, you can write to your MSP or MP sharing your concerns. We have prepared a sample letter that you can use below (in word format). Please let Barry.Watts@siba.co.uk know if you write and get a reply.

letter to MSPs (word format)

Find out who your MSP is at: http://www.parliament.scot/mspfinder/index.html

Find out who your MP is at: https://members.parliament.uk/

Non-Scottish members: If you are a brewer who sells or is considering selling beer to Scotland (including through wholesalers) you will be impacted. You can use this sample letter below (in word format) to write to the Cabinet Secretary sharing your concerns. Please let Barry.Watts@siba.co.uk know if you write and get a reply.

Sample letter to Roseanna Cunningham MSP (word format)

If you have any questions please do not hesitate to contact us.

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