The UK must learn the lessons of Ireland’s successful Deposit Return Scheme launch, if it is to avoid the mistakes of Scotland
The UK is at serious risk of falling even further behind, with the deadline all but certain to slip. Politicians from all parties must work together to give the industry the level of certainty needed to unlock investment and to encourage consumers to support this nationwide environmental intervention
Ireland today launches its Deposit Return Scheme (DRS), Re-Turn, marking the culmination of four years of work by government, drinks manufacturers, retailers and the recycling industry.
DRS has the potential to transform recycling rates and reduce littering. Since Sweden introduced Europe’s first DRS in 1984, evidence shows that consumers adapted swiftly to paying a deposit on their drinks bottles and cans, which is refunded when they return the container for recycling. Countries like Germany and Lithuania now enjoy recycling rates well over 90% — and Suntory Beverage and Food GB&I’s (SBF GB&I) research shows there’s no reason the UK can’t see similar success.
SBF GB&I, proud owner of Lucozade and Ribena, therefore strongly supports the introduction of DRS. Driving up recycling rates is critical to our target of producing only 100% sustainable plastic bottles from recycled or bio-based material, and of reducing our value chain emissions by 30%, all by 2030.
Yet, while the UK announced its intention to create a DRS in 2018, two years before Ireland, we are not due to launch our scheme until late 2025 — almost two years later. In reality, we are at serious risk of falling even further behind, with this deadline all but certain to slip.
It is, therefore, essential that the UK urgently learns the lessons from our neighbour’s successful approach. We have already seen in Scotland the consequences of failure — which has been costly for businesses, the public purse and the environment.
As a business with a strong presence in every part of the UK and in Ireland, that is also part of a wider network operating alongside many DRS schemes throughout Europe, SBF GB&I has seen first-hand what works and what doesn’t.
Government needs to be engaging much more closely with industry on the design of the scheme, working to ensure that there are clear regulations, that realistic deadlines are set and held to, and that there is full alignment between the different parts of the UK.
Implementation of a DRS is a complex business challenge that comes with significant up-front costs. Moving into a general election year, politicians from all parties must work together to give the industry the level of certainty needed to unlock investment and to encourage consumers to support this nationwide environmental intervention. To that end, we urge action on the below learnings.
Working closely with Industry
SBF GB&I, as part of a wider industry coalition, worked in collaboration with the Irish government from the very earliest stages to shape the development of an industry-led scheme — chairing and sitting on several industry working groups. From the beginning, this coalition involved all the relevant parts of the industry sharing their expertise, including retailers who will be required to host return points. This contrasted with Scotland, where retailers were brought into the process at far too late a stage.
Of critical importance in Ireland was the early creation of an industry-wide working group, which went on to ensure a timely appointment of a scheme administrator responsible for the implementation of the scheme and for determining key aspects of it, including the return handling fee and management of its contracts with suppliers. The Irish government was able to award a licence to a scheme administrator, knowing that the right organisation was already in place.
Many of the problems experienced in Scotland were a result of Circularity Scotland not being given enough time between their appointment as scheme administrator and the proposed go-live date of the scheme.
For the UK, the collapse of Circularity Scotland has meant the loss of significant industry experience and institutional knowledge — making it all the more important that the UK Government acts to appoint an administrator as soon as feasibly possible.
Clear and specific regulations
Experience from Ireland demonstrates DRS regulations must be detailed and prescriptive, so there is no ambiguity for each part of the system as to what their obligations are. In particular, clear and detailed descriptions are required for “producer”, “retailer”, “wholesaler”, and other key terms. This would be a key role for a Defra-industry working group that should be set up as a key first priority.
The scheme in Scotland left far too many of the obligations on manufacturers and retailers open to interpretation — creating a very difficult situation for the scheme administrator and adding unnecessary risks to the investment case for businesses.
A clear example of this was around product labelling and whether drinks containers should carry some form of symbol to denote they were included in the scheme. Labelling changes are a costly and time-consuming process; however, the scheme regulations did not mandate them, and Scottish Ministers gave conflicting messages on whether labels were 'recommended', 'advised', 'required', or 'unnecessary'.
As a business, we accept meeting our environmental obligations will come at some cost. Knowing clearly what those costs are is always preferable to ambiguity. The clear drafting of regulations is vital in providing certainty.
Timing is essential
Timing is everything when preparing for large-scale business changes. Experience from the Scottish and Irish DRS has taught us that we need sufficient time between the drafting of legislation, its passage, the appointment of a regulator and the ultimate go-live date to give us the time needed for the significant transformation of our business and supply chain.
Of particular importance — and complexity — will be the creation of new IT and digital infrastructure that will link products together from production to consumption and return. Experience shows this will take an absolute minimum of 18 months from the appointment of the scheme administrator.
Industry also needs confidence that these timescales will be kept — something that has been undermined by delays in the UK and by the experience in Scotland.
If, as seems likely, the UK scheme has to be delayed further beyond October 2025, this needs to be confirmed with urgency. An announcement must be accompanied by a detailed and practical timeline setting out all the stages building to the new go-live date, so that there is clear accountability to keep government and industry on track.
A single set of rules for a single market
As a business that operates across the world, we are all too aware of the importance of the interoperability of regulations that impact jurisdictions differently.
This is why we firmly support the rollout of a single UK-wide DRS scheme with a single set of materials, deposit levels and administrator. Divergence creates significant difficulties for our ability to sell across the UK single market. It will compel companies to consider whether UK nations that do diverge are large enough markets in which to offer separate SKUs for their full range of products. Divergence also risks harming the consumer experience, creating confusion and undermining the ability to offer UK-wide communications campaigns.
The future of DRS
DRS has the potential to transform the UK’s approach to recycling and to significantly reduce littering. We should be taking very positive encouragement from the successful launch of the scheme in Ireland. If we take forward learnings from their experience, there is no reason we cannot have similar success in the UK.
Now is the time for the UK government to be taking the decisive action needed to plot a way forward to delivering DRS in a realistic timeframe.
SBF GB&I will continue in its support for the scheme and will work closely with Government to offer workable solutions to the challenges it currently faces.
We all have a responsibility and opportunity to ensure future generations inherit and enjoy a healthy planet — it’s vital that we get this right.
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