Member Responses

Call for Evidence

In response to Zero Waste Scotland’s “call for evidence” regarding the feasibility of a Scottish deposit-return scheme, several industry leaders have voiced their reservations of the Eunomia report on the feasibility of implementing a DRS in Scotland. 

Read our members' submissions, and our own, by scrolling through the headlines, or click on the member's name to read their full submission.



A.G. Barr

A.G. Barr has been in the soft drinks business since 1875 manufacturing and selling soft drinks such as Irn-Bru. They have also operated a returnable glass bottle scheme for c.140 years.


The theory of a DRS sounds simple. The reality of putting such a scheme into practice would be much more complex


A.G. Barr was not approached to discuss its returnable glass bottle scheme currently in operation in Scotland. With current return rates of 54%, compared to Eunomia’s DRS projected return rates of 85-95%, this is a glaring omission.




The Alliance for Beverage Cartons and the Environment (ACE) UK represents Tetra Pak, Elopak, and SIG Combibloc, the leading manufacturers of beverage cartons for the UK market. In addition to this is ACE UK runs the packaging industry's recycling programme.


Beverage carton collection in Scotland is a success story, having grown significantly in recent years through voluntary commitment and investment by the beverage carton industry, working together with local authorities - 94% of local authorities in Scotland collect beverage cartons for recycling. 


ACE UK's experience shows that the best way to increase recycling is to make it as easy as possible for the public to access collection systems and to increase awareness through better communication. 




The Aluminium Packaging Recycling Organisation represents members from the full spectrum of the aluminium packaging industry and works towards meeting aluminium recycling targets. 


In countries which have had DRS for over 20 years, overall recycling rates are nowhere near the aspirations of the Scottish Government and indeed below the level currently achieved in Scotland


The recycling levels of non-deposit metal packaging, including food cans, aerosol and foil trays, are adversely affected by the introduction of DRS systems



Ball Packaging Europe

One of the world’s leading packaging producers providing metal packaging on all 5 continents, with 4 plants in the UK. A subsidiary of Ball Corporation, which operates within most of the world’s DRS systems.


This feasibility study is, we feel, insufficient for any form of robust assessment to be made on a DRS’s suitability to address the concerns of the Scottish Government


DRS is an outdated concept as it only targets a relatively small fraction of total waste, such systems are vastly inferior to modern holistic “Kerbside” provision and “MRF” sorting of the type built and operated by the Scottish Local Authorities network that captures all types of HH waste, economically



British Soft Drinks Association

The British Soft Drinks Association represents UK producers of soft drinks, including carbonated drinks, still and dilutable drinks, fruit juices and bottled waters. Membership includes the majority of Britain's soft drinks manufacturers as well as franchisors, importers and suppliers to the UK soft drinks industry.


Whilst we recognise that more needs to be done in Scotland to increase recycling rates and tackle littering, the BSDA believes the simplest, most cost effective and environmentally sound way to do this is through developing and improving existing kerbside recycling and harnessing the communications and marketing expertise of companies such as those within BSDA membership, to influence and change consumer behaviour. 




One of the leading soft drinks companies in Europe, with manufacturing operations in Great Britain, Ireland and France, and leading brands including Robinsons, Fruit Shoot and Tango.


We firmly believe that a Deposit Return System is not the solution to increasing recycling rates and reducing litter



Coca-Cola Enterprises

Manufactures and distributes soft drinks for Coca-Cola and other brands. With over one hundred years of trading in Scotland, Coca-Cola Enterprises (CCE) lessens the impact of its operations while continuing to grow in a responsible and sustainable manner.


Peer-reviewed research found that a DRS in Scotland would cost consumers an extra £155M / £65 per household per year


Consumers don’t want it: 71% were “very convinced” that the extra £65 cost per household was “too high in the current times of austerity”. 50% backed an improved local authority collection scheme, with only 27% saying a DRS




The Confederation of Paper Industires is the leading UK trade association for the paper supply chain, with 65 member companies.


While the proposals for a deposit scheme may not have an immediate or direct impact on secondary pakcaging, we recognise that these moves are the 'thin end of the wedge', and that future developments may well impact upon us.


We are pleased to be part of the Packaging Recycling Group Scotland, and fully support the PRGS response




The Industry Council for research on Packaging and the Environment is a research organisation set up in 1974 to bring together companies from across the supply chain to promote responsible packaging for resource-efficient supply chains.


Deposits are not an efficient way for Scotland or anywhere in the UK to achieve higher recycling rates


A deposit will not prevent drinks containers being littered and will do absolutely nothing to prevent the littering of other items




Lucozade Ribena Suntory work with a range of partners to make a positive contribution to drive change in our environment, including the Wildlife Trust and the Hubbub ‘Neat Streets’ programme.


There is no ‘silver bullet’ to the problem of increasing recycling and reducing litter - the solution lies in a range of activities


LRS stands alongside our colleagues in supporting a more successful and unprecedented alternative to tackle litter and recycling – achieving a beverage recycling rate of 80% by 2025



The Packaging Federation

The over-arching trade association for the UK Packaging Manufacturing Industry.


Our members in Scotland are seriously concerned that the costs of the proposed scheme have been seriously underestimated and will, by the very nature of the supply chain, fall heavily on them




The Packaging Recycling Group Scotland, PRGS, is a group of 33 leading food and drink companies and industry bodies that shares the Scottish Government’s ambitions to tackle littering and increase recycling.


A DRS would increase costs, be inconvenient for consumers and would penalise low income families


Not only does it lack a cost-benefit analysis, but, of even more significance, it did not consult any retailers, local authorities or waste management companies. There is little evidence for many of its assumptions.




The Scottish Food and Drink Federation is a devolved division of FDF, the trade association for food and drink manufacturing.


We have serious concerns about the lack of evidence to support the position that the advantages of a deposit vending scheme, in terms of increased recycling or reduced littering, outweigh the costs of such a scheme on business, local authorities and consumers


Experience in other countries has shown that fraud can be a serious problem




The Scottish Grocers’ Federation and the Association of Convenience Stores represent the interests of convenience retailers across Scotland.


We are concerned that the Zero Waste Scotland feasibility study has failed to consult with any retail organisations or representative bodies in Scotland about the Deposit Returns Scheme (DRS)


Consultation with our members about the proposed DRS has resulted in significant concerns about their ability to participate in the scheme without incurring significant set up costs, additional staffing hours and ongoing operational disruption in their stores




The Scottish Retail Consortium is the lead trade association for retailers operating in Scotland and has been representing the interests of the retail industry since the Scottish Parliament’s inception in 1999.


We believe that a DRS would place a significant burden on vulnerable consumers at a time when household budgets are already under severe pressure


If just 2% of customers make a special journey to claim back deposits this would have a significant additional carbon impact of around 6000 tonnes of CO2 (enough to power 1475 homes for one year)



Tennent Caledonian Breweries

Producers of iconic Tennent’s Lager, based at Duke Street in Glasgow where beer has been produced for nearly 500 years.


We are one of Scotland's largest producers of drinks and were not consulted by ZWS in the compilation of this report.


By not consulting with organisations such as ourselves, and the others listed above, some of the fundamental facts relating to the operation of the drinks industry were ignored.




The Wine and Spirit Trade Association is the UK body that represents the wine and spirit industry representing over 340 companies producing, importing, exporting, transporting and selling wines and spirits.


A full Business Regulatory Impact Assessment should be undertaken on the proposal for a Deposit Return Scheme in Scotland before further discussion takes place.


The introduction of DRS runs entirely contrary to the drive to reverse the decline in small retail businesses