4th September 2026
The Scottish Government has another chance to make its Deposit Return Scheme work.
Whether it will take that opportunity is another matter.
After years of delays, political arguments and growing frustration among retailers, the new scheme is scheduled to begin in October 2027, operating alongside schemes in England and Northern Ireland. This time the design has been changed considerably. Glass bottles have been removed, the minimum container size has increased to 150ml, and the system is intended to operate across the three nations in a broadly consistent way.
But there is a question which is just as important as whether the scheme works technically.
Will it work for ordinary people?
Because telling shoppers that they will pay a 20p deposit on every eligible bottle or can sounds straightforward.
Getting that 20p back may be rather less straightforward.
And that could become particularly important in rural Scotland.
The principle is simple
The basic idea behind DRS is easy enough.
Buy a drink in an eligible single-use plastic or metal container and an additional 20p deposit is charged.
Return the empty container to an approved return point and the deposit is refunded.
The deposit is not supposed to be another tax. It is effectively the customer's money being held temporarily to encourage the container to be returned.
That is the theory.
The success of the system therefore depends upon one simple proposition:
It must be easier to get the 20p back than it is to throw the container away.
If returning a bottle means making a special journey, finding a machine that is full or out of order, waiting in a queue or discovering that a particular return point does not accept the container, the economic incentive starts to weaken.
The Scottish Government itself recognises that accessibility will be important. Its impact assessment says some consumers will find returning containers more difficult and specifically identifies rural and island communities as requiring further consideration when return points are distributed.
That is not a minor detail.
It could determine whether the scheme is regarded by the public as a useful recycling system or simply another charge added to the weekly shopping bill.
What exactly will be included?
The new scheme is considerably narrower than the original Scottish proposal.
It will cover single-use PET plastic bottles and aluminium and steel cans, between 150ml and 3 litres.
Glass is no longer included.
Milk containers made from HDPE are also outside the scheme.
That should make the system easier for retailers and consumers to understand than the original proposals.
There is, however, still going to be a learning curve.
Imagine a family sorting through the recycling after a weekend barbecue.
Some bottles will have a 20p deposit attached.
Others will not.
A glass bottle will not necessarily be part of the scheme.
A milk container will not necessarily be part of it.
A plastic drinks bottle will be.
A can will be.
The consumer therefore needs to recognise which packaging carries the deposit.
The labelling will be crucial.
But where do you get your money back?
This is where the scheme becomes much more interesting.
A consumer needs a convenient return point.
The Scottish regulations require grocery retailers to operate return points unless they qualify for an exemption. There are exemptions where, for example, an alternative return point is reasonably close or the premises cannot reasonably accommodate a return point because of its size, layout or construction.
That sounds sensible.
But what is “reasonably close” in Caithness?
Five minutes?
Ten minutes?
Ten miles?
Twenty miles?
A definition that works perfectly well in an urban environment may look rather different in a rural area.
If somebody lives in a village where the local shop does not have a return point and the nearest participating retailer is several miles away, that 20p deposit starts to behave rather differently.
For somebody who shops there anyway, it may not matter.
For somebody who has to make a separate journey, it could be another cost and inconvenience.
The Government already knows some deposits won't be reclaimed
This is perhaps one of the most revealing parts of the official documentation.
The Government expects the scheme to achieve a 90% return rate by its third year.
That sounds impressive.
But it also means that, by definition, around one in ten containers could still not be returned through the system.
The Government's own assessment explicitly recognises that a percentage of deposits will remain unredeemed and says this represents a cost to consumers as well as a source of funding for the scheme administrator.
That deserves more public attention.
Suppose a household buys 500 eligible drinks in a year.
At 20p each, it will have paid £100 in deposits.
If 10% of those containers are never returned, that household could effectively lose £10.
Of course, not every household will buy 500 eligible containers, and many people will return almost everything.
But the example demonstrates something important.
The 20p is only “refundable” if the consumer actually has a practical way of reclaiming it.
And what happens to people who cannot easily get to a shop?
This is particularly important for elderly people, disabled people and those without access to a car.
The original Scottish proposals included a much more explicit requirement around online retailers taking containers back.
That mandatory online takeback requirement has now been removed from the revised scheme. However, retailers and community organisations interested in providing takeback services can apply to participate.
That potentially leaves a gap.
The Government says it wants the system to be accessible.
But accessibility is not simply about whether there is technically a return point somewhere.
It is about whether an individual consumer can reasonably use it.
A return point five miles away may be perfectly accessible to somebody with a car.
It is not necessarily accessible to someone without one.
That is why rural Scotland needs to be considered differently from central Glasgow or Edinburgh.
The small-shop problem
Then we come to the retailers.
A small shop may already be operating with tight margins, limited staff and very little spare floor space.
Now it may have to decide whether to become a return point.
There are two basic approaches.
Containers can be accepted manually over the counter, or a retailer can install a reverse vending machine.
The latter is obviously more attractive for a large supermarket with plenty of space.
A machine can automatically identify eligible containers, record the deposits and produce the refund.
But a machine needs somewhere to go.
And every square metre of a small shop has a value.
A retailer could potentially use that space to sell food, newspapers, household goods or other products.
There is therefore a genuine commercial calculation involved.
The Government and scheme administrator have tried to address that
There is financial support available.
A £60 million support package has been developed to help smaller retailers with reverse vending machines, alongside payments to retailers for handling returned containers.
That is important because it acknowledges that retailers cannot simply be expected to provide the infrastructure for nothing.
But the question is whether the support is sufficient.
A small shopkeeper will not be asking how much the Government is spending nationally.
They will be asking:
What will this cost my business?
How much floor space will it take?
How much staff time will it consume?
Who deals with overflowing storage?
Who cleans the machine?
What happens when it breaks?
How frequently are containers collected?
What happens if customers bring back containers bought somewhere else?
And perhaps most importantly:
Will the income generated by the scheme cover the real cost?
Those are commercial questions, not environmental ones.
There could actually be a benefit for shops
It would be wrong to assume that every retailer will lose out.
A return point could bring customers through the door.
Someone arriving with 15 bottles to return is standing inside the shop.
They might buy bread, milk, cigarettes, newspapers, snacks or something for dinner.
The 20p deposits could therefore become a form of customer loyalty mechanism.
A shop that handles a large number of returns could potentially benefit from additional footfall.
The problem is that this benefit will not necessarily be evenly distributed.
A busy urban convenience store may receive hundreds of returns.
A tiny rural shop may receive comparatively few.
Yet the rural shop could still have to devote a disproportionately large amount of space and staff time to providing the service.
This is where Scotland's geography matters
The new DRS has been designed to operate across Scotland, England and Northern Ireland.
That is sensible.
A consumer should not have to understand three completely different systems when travelling around the UK.
The three governments have specifically committed to making their schemes interoperable and as simple as possible for consumers and businesses.
But a single national system does not mean identical local circumstances.
A return point network that works in Manchester may not work in Caithness.
A supermarket in Inverness can potentially handle large volumes.
A small shop in a Highland village may have only a few aisles.
This is why the success of DRS should ultimately be judged not by how it performs in the largest supermarkets but by whether it works at the edges of the network.
What if the machine doesn't recognise the bottle?
There is another practical issue consumers will quickly discover.
Reverse vending machines are not simply recycling bins.
They have to identify whether the container is eligible and whether it belongs within the scheme.
The consumer will therefore need to bring back the correct container, and in an acceptable condition.
That raises questions about crushed cans, damaged labels, foreign containers and bottles purchased outside the UK.
A sophisticated machine can deal with many of these issues.
But the more complicated the rules become, the more likely it is that somebody eventually stands in front of a machine with a bag of bottles wondering why they cannot get their money back.
And that is when public confidence can disappear very quickly.
The 20p could also change shopping behaviour
There is an interesting psychological aspect to the scheme.
Twenty pence does not sound like much.
But if somebody buys ten bottles, that is £2.
Twenty bottles is £4.
Fifty bottles is £10.
For a family buying large quantities of soft drinks or bottled water, the deposits could become noticeable.
It may encourage people to return everything.
But it could also have an unintended effect.
Some consumers may simply regard the 20p as another unavoidable addition to the price of a drink.
If returning the container is inconvenient, they may never bother reclaiming it.
The Government's own assessment acknowledges that unredeemed deposits will occur.
The challenge is therefore to make the percentage as small as possible.
There is a lesson from Scotland's first attempt
The previous Scottish DRS became a symbol of what happens when a policy becomes entangled in political disagreements, regulatory complications and uncertainty for business.
The new scheme is supposed to be different.
The launch has been moved to October 2027.
The scheme has been aligned with England and Northern Ireland.
Glass has been removed.
The minimum size has changed.
The obligations on retailers have been reduced.
A scheme administrator has been appointed.
There is financial support for smaller retailers.
In other words, there has been a considerable attempt to learn from what went wrong.
But the ultimate test will not be whether the regulations look better on paper.
It will be what happens on a wet Saturday afternoon when a customer walks into a small Highland shop carrying a sack of empty cans.
Will Scottish shops embrace it?
I suspect the answer will be some will and some certainly won't.
Large supermarkets and retailers with plenty of space are likely to see the advantages.
Some independent shops may also decide that a return point is an opportunity to bring customers through the door.
Others will look at their limited space and staff resources and conclude that it is simply not worth the trouble.
And in rural Scotland, exemptions may become particularly important.
That could create another question.
If a small shop obtains an exemption because it cannot accommodate a return point, where does its customer go to get their 20p back?
The exemption may solve the retailer's problem while creating a problem for the consumer.
That is why the Government's promise to ensure an appropriate and accessible network of return points in rural and island communities will be so important.
The scheme will succeed or fail at the point of refund
There is a temptation to judge DRS by its environmental objective.
If the Government eventually gets 90% of containers returned, it will regard that as a major success.
And environmentally, it may well be.
But there is another measure of success.
Ask the person who has just bought a drink:
“Was getting your 20p back easy?”
If the answer is yes, the system will probably become part of everyday life surprisingly quickly.
If the answer is no, the 20p deposit will start to feel like another charge imposed by government.
That is why the next year is going to be crucial.
The Government needs to explain exactly where people will be able to return containers, particularly in rural Scotland.
Retailers need to know exactly what their obligations and payments will be.
Consumers need to know which containers are included.
And everybody needs confidence that when they hand back an empty bottle or can, their 20p really is coming back without a battle.
The environmental argument for DRS may be strong.
But for the scheme to work, it also has to pass a much simpler test.
It must be convenient enough that people actually want to use it.
And in a country as geographically diverse as Scotland, that means designing a system that works not only in the big cities, but in the small shops, villages and communities at the far end of the road.
That may ultimately be the real test of whether Scotland has finally got its Deposit Return Scheme right.
Or will many of us just drink more tap water to avoid the hassle.
Scotland's First DRS Left Behind More Than Bad Memories
There is one final piece of the Scottish DRS story that should not be forgotten when we consider whether the new scheme will work.
The first attempt did not simply disappear when it was postponed.
Businesses had already spent money preparing for it, and one of those businesses eventually took the Scottish Government to court.
Biffa Waste Services had been appointed as the logistics provider for the proposed scheme and had invested heavily in preparation. When the scheme collapsed in 2023, Biffa argued that it had relied on assurances from Scottish ministers that the scheme would proceed.
The company eventually brought a claim against the Scottish Ministers which, by the time the case reached court, was worth around £166 million. That included approximately £51 million relating to costs and losses and a much larger sum for profits Biffa said it would have made under the planned ten-year contract.
For the Scottish taxpayer, this was potentially a very serious liability.
The Court of Session, however, rejected Biffa's claim in January 2026. Lord Sandison concluded that the Scottish Government had not breached the duty alleged by Biffa and that the communications relied upon by the company could not reasonably be interpreted as guaranteeing that the legislation would ultimately be sufficient to deliver the scheme.
So the Scottish Government avoided what could have been a bill of more than £160 million.
But that does not mean the first DRS cost nothing.
The Scottish Government also incurred substantial legal costs defending the case. An official information release records a further £160,434 of costs between November 2024 and October 2025, on top of costs incurred before that period.
And there is another uncomfortable part of the story.
The organisation created to run the original Scottish scheme, Circularity Scotland, subsequently went into administration. A £9 million loan facility connected with the organisation has not been fully recovered, with administrators reporting that only around £1.2 million had been returned.
This is important because it demonstrates why small businesses may look at the new scheme with some scepticism.
They are not looking at DRS as an entirely new idea.
They have watched the Scottish Government announce a scheme, businesses invest in it, regulations become increasingly complicated, the launch date change, the scheme collapse and a major legal dispute follow.
Now they are being asked to prepare again.
The Government's response is that this time it is different.
And there is considerable truth in that.
The new scheme is being introduced jointly with England and Northern Ireland. Glass has been removed, the range of containers has been narrowed, the launch date has been moved to October 2027 and financial support is being offered to smaller retailers.
Those changes should make the system much more practical.
But governments should not underestimate the effect of policy uncertainty on business confidence.
A small shopkeeper considering whether to spend money on equipment or give up valuable shop space to a reverse vending machine is entitled to ask what happens if the regulations change again.
A large company can spread the cost of a failed investment across a substantial business.
A small independent retailer cannot.
That is why the success of the new DRS will depend on more than getting the technology right.
It will depend on rebuilding trust.
Retailers need confidence that the rules will remain stable.
Consumers need confidence that their 20p deposit really can be recovered without unreasonable inconvenience.
And rural communities need confidence that the Government will not regard a return point several miles away as equivalent to one sitting outside a supermarket in a city.
The first Scottish DRS became a lesson in what can happen when policy, politics, legislation and business investment collide.
The second attempt has been redesigned to avoid many of those problems.
But the Government now has to prove that it has learned the most important lesson of all.
If you are going to ask businesses and consumers to invest in a national scheme, you need to make absolutely certain that the system will still be there when they have done so.