The Packaging Recycling Group Scotland (PRGS) today (18 June 2015) submitted evidence rejecting Scottish Government proposals for a DRS, detailing the lack of consultation with retailers, industry and consumers and demonstrating that it will neither boost recycling nor reduce litter.

Issues that have not been fully considered, according to the PRGS, are the growth in online shopping and home deliveries; high support for current local authority kerbside recycling; the carbon impact of additional transportation; loss of trading space to install recycling points and associated costs and the ultimate hit on the consumer wallet the current proposed scheme would create.

Jane Bickerstaffe, PRGS spokesperson, explains: “The cost to the consumer will be significant, while the impact on retailers has been virtually ignored. We want the Scottish Government to understand that we are also intent on promoting reuse and recycling where possible, but this scheme does not promote reuse.

“As it stands it places extra burdens on consumers who will need to factor in extra trips and planning to claim refunds; and extra burdens on retailers to fit machines and operate a system. Yet we are certain that the outcome will not deliver what is required and we ask them to consider our alternative Packaging Resource Commitment before taking on an inherently unworkable scheme.

David Martin, Head of Policy & External Affairs at the Scottish Retail Consortium said: “At a time when household budgets are already under severe pressure and retailers are working incredibly hard to insulate consumers from higher prices, introducing a levy that will fall disproportionately on those on low incomes or with limited personal mobility is regressive and ill-conceived.

“The proposed DRS will place a wide range of costs on business and fails the Scottish Government’s own Better Regulation test, namely that regulations should be proportionate and well-targeted. The environmental progress being made by the retail industry, particularly on driving down carbon emissions from transport, will be severely undermined by a deposit scheme as millions of road miles will be required by retail haulage.

“DRS is a proposition that is bad for consumers, bad for business and bad for achieving our carbon reduction targets.”

Reverse Vending Machines, suggested by the Scottish Government as the main refund mechanism are estimated to cost at least £32,000 each.

Scottish Grocers’ Federation Chief Executive Pete Cheema, said: “We have serious concerns about this entire process – the ZWS feasibility study has not looked at the potential impact on convenience stores.  A typical convenience store will sell around 3,000 units a week of soft drinks alone. Space is always at a premium for convenience store retailers – how could a store be expected to cope with the anticipated high levels of return?”

PRGS fears that a DRS will increase costs for retailers, industry and local authorities, cause inconvenience and create inefficiencies while costing consumers an additional £155 million per year, or £63.50 per household[1].

The industry group is urging retailers to support an alternative Packaging Resource Commitment to help improve recycling and tackle litter in Scotland, which will exceed Government targets by 2025.

Its submission highlights that the cost of setting up and administering the system, including the creation of new Scottish-only labelling for fraud prevention, will lead to stockholding and distribution problems. Product prices could increase while choice could be reduced.  There are also implications for retailers needing to clean, store and return empties.

The PRGS proposals, offered to Government last year, harness the unprecedented communications and marketing reach of its member organisations.  Working in partnership with government, local authorities, Keep Scotland Beautiful, Zero Waste Scotland and others, the partnership would maximise best practice in existing kerbside and on the go recycling schemes while helping to influence and change consumer behaviour.