Big Deposit Return mess that will hit the islands

I tend to see the increasingly controversial Deposit Return Scheme through the prism of my excellent, community-owned local shop. If the Scottish Government or one of its off-shoots could explain how it is going to work here, then there might be room for hope.
Community bottle-banks will be largely redundant after DRS.Community bottle-banks will be largely redundant after DRS.
Community bottle-banks will be largely redundant after DRS.

The problem is that they can’t, as I have discovered over the past week by asking some straightforward questions. While the scheme is under fire throughout Scotland for being complex and expensive, island conditions raise a whole additional range of challenges that remain wholly unanswered.

Close to the shop in Uig, there are two large skips, regularly filled to their brims with bottles in one and assorted recyclables in the other. At any time, I guess there must be several thousand recyclable containers at this site alone. In summer, the numbers roughly quadruple.

Most locals and visitors to the area use this and other recycling sites pretty diligently. When the skips look like overflowing, the council comes and replaces them, taking away the contents to be processed for recycling on the mainland. It is a system that has worked pretty well.

In recent weeks, additional bins have reached Uig so that more of this separation of recyclables can take place at home, for roadside collection. But don’t get too used to diligently placing bottles made from any material in the allotted bin. Six months from now, that will be like throwing away money.

By then, all containers – no matter how big or small - will carry a deposit of 20p each. In order to recover that deposit, it will be necessary to take them to a registered participant in the scheme who will have an obligation to pay out, no matter where they have been bought. My shiny new bins will become at least semi-redundant and so too will the skips beside the shop. So where will these thousands of bottles go then?

That is one of the big unanswered questions which have led to pleas from every link in the drinks chain for a pause until the scheme is capable of being delivered. The deadline to complete registration for it is the end of February. Any business which sells drinks, hard or soft, in containers made from glass, plastic or metal, that has not registered risks heavy penalties if, from August, they sell drinks through any channel in Scotland.

Scotland director of the Society of Independent Brewers, Jamie Delap, told BBC Scotland that up the last minute he is undecided about whether to register because there are so many unknowns – including costs. If he doesn’t then he will be unable to sell his products in Scotland, though they are brewed in Argyll. Mr Delap described the scheme as “insanely complex” and said it would lead to a huge rise in costs for small, independent brewers that could put some of them out of business.

So far, the pleas for delay – in line with every other part of the UK – have fallen on deaf ears. Yet the inability of anyone to provide answers to even the most basic practical questions is causing alarm among producers, distributors and retailers.

The producers range from micro businesses like island breweries and distilleries to the major brands behind both soft and alcoholic drinks. All of them unite in warning that the complexities of selling their products on different terms in different parts of the UK will lead to higher costs which will be passed on to the consumer, quite apart from the 20p refundable deposit.

Last week, I sent some pretty basic questions to the Scottish Government. They advised me that most of them were “operational” and should be addressed to Circularity Scotland which is a cross between a quango and a private company, set up to administer the DRS. They in turn passed them onto an Edinburgh public relations firm called Citypress.

They weren’t trick questions – just straightforward, practical ones like:

- The number of containers placed in bottle banks etc quadruples in summer, the vast majority likely to have been bought elsewhere. If these are "returned" to the local shop, what recognition will there be of impact on cash flow?

- If a shop cannot afford a Reverse Vending machine, what are they expected to do with the containers while awaiting collection? Who will have the duty of collecting them, and how often?

- Who will have responsibility for funding storage capacity where none currently exists?

- In the case of islands, who will have responsibility for transporting the bottles/containers collected to the mainland?

In reply, there was no pretence of attempting specific answers. Instead I got a generalised statement which could as easily have gone to someone asking how it is going to operate in the middle of Glasgow. There was not a word of recognition that particular factors that arise in rural or island conditions.

Citypress informed me on behalf of Circularity Scotland: “Scotland’s Deposit Return Scheme (DRS) will go live in August 2023 and will revolutionise how Scotland recycles, preventing billions of drinks bottles and cans each year from ending up as waste and helping protect Scotland’s environment for generations to come”.

They told me: “We’re working with government, industry and our official logistics provider Biffa to ensure there is a network of return points across Scotland so that consumers will be able to easily return containers … with collection schedules developed in a way that takes regional and seasonal variations into account”.

“While we don’t underestimate the scale of the challenges in introducing a scheme of this scale, we can’t lose sight of the opportunity DRS provides”.

David Macleod, municipal services manager for Comhairle nan Eilean Siar, is in a curious position. He is responsible for a system that works pretty well but says he knows “very little” about one which in six months time will replace large parts of it, under a different organisation and operator. I repeat that because it is so remarkable – the local authority knows “very little”.

“We are not directly involved”, says Mr Macleod “though we are working with other island authorities to try to get our heads round it. We are still waiting to see what their plan of action is for the islands”.

Mr Macleod recalled that he too used the example of Uig shop to illustrate some of the island issues when someone from the Scottish Government visited. He says: “The answer they provided wasn’t very convincing, that they had thought it through”.

As the bland statement on behalf of Circularity Scotland mentioned, their “logistics partner” is Biffa, the biggest waste management company in the UK, based in High Wycombe. However, as David Macleod points out: “Biffa have no presence here at all”. So who is going to collect from the scores of outlets around the islands that will be legally obliged to act as collection points?

In the absence of an answer, it seems at least possible that Biffa will sub-contract the work to another company, perhaps locally based. This would mean huge duplication of effort with the Comhairle still responsible for collecting from half-empty bins and skips while the private recycling contractor tours the collection points.

Around Scotland, it is intended there will be a network of Reverse Vending Machines which refund deposits with either cash or tokens. However it is expected that only a very few supermarkets in the islands will have these units. For everywhere else it will be a manual process.

The Scottish government did tell me that “retailers will be able to refuse to accept a return if a single proposed return by a consumer is disproportionate to the number of containers sold in an average single transaction”.

While offering modest relief, even that concession is so vague as to beg more questions than answers. Would two or three poly bags filled with bottles and cans be “disproportionate” and whose job would it be to tell disgruntled customers they can’t have their money back? Then where do they go with their “disproportionate” load – the nearest Reverse Lending Machine 35 miles away, or the nearest lay-by?

But surely, I hear you ask, any scheme like this was supposed to be “island-proofed”. When I asked the Scottish Government about that, they pointed to an Islands Impact Assessment in February 2020, before Circularity Scotland existed, which cheerfully concluded that for islands, “the overall impact will be significantly positive, supporting the development of a circular economy, acting to address the climate crisis, and preventing litter and plastic pollution escaping into our natural environment”.

Box ticked and who can be against any of that? But three years on, they cannot say who will collect the recyclates or take them to the mainland. Neither have financial implications for small, dispersed retailers been clarified. There is still no “islands action plan” while high quality drinks producers “face a huge rise in costs that could put them out of business”.

Amidst debate about whether the scheme can be made to work, there is one huge elephant in the room that just seems to be ignored – the cost of living impact at a time every penny counts for so many families in the Western Isles as elsewhere.

I looked at the shelves this week and found eight cans of Cola for £3.20. That will become £4.80 plus whatever admin charges go on top. A pack of ten small bottles of own brand water was £2. That will become £4 plus. A £4.80 six-pack goes to £6 plus.

Of course, once contents have been consumed, the deposit will be reimbursed for those – including the elderly, the housebound and folk who just aren’t very well organised or don’t have transport – who can find a place that will take them.

The other costs will not be recoverable and the alternative for those to whom multiples of 20 pence matter will be to strike yet another item off their shopping lists. That is unlikely to be a personal concern for those most intent on pushing this scheme through regardless.

There is an overwhelming case for delay to get it right and ready, which it self-evidently is not; for removing glass from the initial scheme and proceeding on a UK-wide basis to avoid the costs and complexities which different regimes will create.

And when Ms Lorna Slater descends from a green cloud to tell us where the tens of thousands of bottles and cans in Uig’s summer skips are supposed to go, maybe it will be time to take her seriously.