Duncan Midwood, CEO of DDRS Alliance, analyses the latest developments around an aligned deposit return scheme across all four UK nations.
The UK Government has committed to launching a deposit return scheme (DRS) in England and Northern Ireland in October 2027, and the Scottish Government are following that lead. The Welsh Government, too, has undertaken to match that timeline to launch its version of a DRS.
So that’s all great – all four UK countries fully aligned. If only that were true! They are aligned on timings (sort of), but not on scope – and that is where the root of all the confusion and frustration lies.
Despite strong public support across all four UK nations for the inclusion of glass bottles in a UK DRS, the UK Government decided to drop glass from the DRS scope in England and Northern Ireland.
The Scottish Government, having had a torrid time trying to stick to their guns by keeping glass in scope and currently being sued for millions by Biffa around the collapse of the Scottish scheme, has relented and agreed to follow the UK Government by excluding glass. As a result, the scope of the DRS for England, N. Ireland and Scotland only covers PET bottles and metal cans.
In Wales, where collection and recycling performance far exceeds that elsewhere in the UK, there is a determination to make more of the recycling revolution that a national DRS launch will bring. The Welsh Government is determined to include glass in its DRS and, as a further goal, plans to launch a re-use framework alongside the DRS launch.
Many stakeholders agree that having different DRS systems and rules within the UK is a recipe for confusion, fraud and, ultimately, failure to create the step-change needed in circularity.
The Welsh Government, for their part, have agreed to align with the rest of the UK on PET bottles and metal cans – in approach and timings. But they are holding tight to their desire to include glass and re-use. They would argue that they have done their bit to support a UK solution, and are expecting (or hoping) that the rest of the UK reciprocates and supports the Welsh ambitions.
And to bring everything right up to date, the UK DMO (deposit management organisation) has been appointed, is building its team and recently moved into its new premises in Milton Keynes. They are busy now putting all the plans in place for an October 2027 DRS launch.
The Welsh Government are currently inviting tenders for the Welsh DMO, which is widely expected to be awarded to UK DMO. They also recently submitted their draft legislation to the WTO – a required step in the establishment of a national DRS.
So, with all this activity and shared determination to launch a DRS across the UK, what could possibly go wrong? Well, in short: politics!
What’s gone wrong?
When the Scottish Government showed equal determination to launch its own scheme (originally in April 2021), the UK Government used the UK Internal Market Act 2020 (IMA) to try to force the Scottish Government to remove glass from scope. In the end, the Scottish Government were forced to cave, and their DRS plans were shelved.
Of course, there now exists a possibility that the UK Government will repeat their sledgehammer tactic on Wales to force the Welsh Government to drop its aspirations to include glass and re-use, using the IMA.
But the Welsh Government is determined and, in December, the Deputy First Minister and Cabinet Secretary for Climate Change and Rural Affairs, Huw Irranca-Davies, declared that, should the UK Government not grant an IMA exemption to enable the inclusion of glass and re-use in the Welsh DRS, then the DRS project will be dropped in Wales.
This means that England, Scotland and Northern Ireland would have to gain an exemption from the IMA in order to introduce their own DRS! Essentially, Wales is threatening to turn the very weapon the UK used to get its way in Scotland back onto the UK Government. This, of course, could result in the whole idea of a DRS for the UK being scrapped – or at least shelved for the foreseeable future!
So, you might think that this whole sorry story couldn’t get any worse. But no – not quite!
In the Welsh draft DRS legislation, although the introduction of glass in its DRS is planned to launch alongside plastic and cans, glass has two key exemptions:
- Glass bottles will not carry any deposit for a planned three years from launch (so not until 2030), and;
- Glass bottles will not require any special labelling until the same 2030 date.
Essentially, what this means is that glass bottles will be part of a DRS in name only. Yes, it is true that retailers will be compelled to take glass bottles back from the public, but they will not be required to pay any deposit back (as none got paid in the first place).
Practically, a retailer can provide a bin in their car park for customers to deposit their bottles for recycling, and the DMO will have to provide a logistics solution to collect the glass. This is what we once knew as a bottle bank!
So, as currently drafted, retailers in Wales will have to provide some form of infrastructure to collect glass bottles, the DMO will have to set up a service to collect the glass, all while the public will have no incentive to do anything different from what they do today – which is put their glass bottles out for the local authorities to collect from the kerbside!
And the glass industry will have to fund this – all while being hit hard by the new EPR fees, which penalise glass for being a heavier packaging format than plastic and aluminium.
Not surprisingly, DDRS Alliance believes that digital DRS can at least alleviate some of this pain, put glass in a much better place (from a consumer perspective), reduce costs and drive increased recycling more effectively. The Alliance believes that glass bottle collections should remain at kerbside – after all, that is what consumers tell us they would prefer!
It believes that retailers should NOT be compelled to take glass back, and that kerbside returns should suffice for any interim period before a deposit is charged on glass bottles. However, this would require a small modification in the current Welsh DRS draft legislation.
Today’s world has become very uncertain, costs are spiralling for the consumer, and there is political debate around the virtues, affordability and necessity of circularity initiatives. Clear thinking is needed, and pragmatism should rule commercial gain.
If glass should be included in a DRS in the UK (and the public strongly believes it should), then it should be done in a way that makes it easy for the consumer and delivers the optimum recycling performance.
Maybe Wales has the track record and ambition to make glass work, even if the rest of the UK is content to lag behind. Maybe Wales should continue to be the pioneer in sustainability, and the rest of the UK should see them as providing this valuable service, instead of trying to tie everyone down to the lowest common denominator.
Clear thinking – that’s what’s needed. Clear as glass! Let’s find the solutions to simplify the situation that is, right now, as clear as mud!
For more details contact DDRS Alliance at info@ddrsalliance.com.
