Retailers have an important role to play in Scotland’s Deposit Return Scheme. They will have a legal requirement to accept returns of empty drink containers for collection for recycling. They will also be responsible for paying the deposit on the drinks they buy and charging the deposit on drinks they sell.

A retailer is someone who markets, offers for sale or sells drinks on the Scottish market. This includes face-to-face retail, online retail, sales in a hospitality setting, sales from vending machines, and wholesalers.

What does this mean for me?

All drinks that are sold in single-use containers made from PET plastic, glass, steel or aluminium, sized between 50ml and 3 litres are included in Scotland’s Deposit Return Scheme. These are called scheme articles. You may also see them being referred to as scheme containers or, once empty, scheme packaging.

If you are a retailer selling scheme articles in Scotland, you will have legal responsibilities that you must comply with under The Deposit and Return Scheme for Scotland Regulations 2020. These are called retailer obligations.

Retailer obligations

As a retailer you must: 

  • only sell drinks from registered producers;
  • only sell drinks on the Scottish market that a producer has made available for sale in Scotland;
  • charge the 20p deposit when selling a drink that is part of the scheme;
  • make it clear to the customer that the drink is part of the scheme and a deposit applies;
  • clearly display the price of the deposit (20p) separate to the product price in any place that a drink is displayed for sale;
  • clearly display information on how the customer can redeem the deposit;
  • operate a return point (unless exempt) or takeback service;
  • store returned empty containers in a safe way, following the Duty of Care code of practice 

Your obligations might vary slightly depending on how you sell drinks to consumers. Please look at our information for online retailers, hospitality retailers and wholesalers to find out what this means for you.

From 16 August 2023, if you sell any drinks that were placed on the market for sale before the scheme went live, then you must communicate to the customer that the drink is not part of the scheme and the empty container cannot be returned for a deposit. 

We will work with retailers to help you understand what your obligations are and what you need to do to comply with the Regulations.

What is a return point?

Return points are where consumers can return their empty scheme containers and get their deposit back.

It should be as easy to return an empty scheme container as it is to buy a drink. This means all retailers and hospitality business that sell drinks to take away are legally required to operate a return point. This includes online retailers, who must offer a takeback service for the collection of empty scheme containers. To find out more about takeback services, visit our online retailer web page.

A return point can be operated manually (scheme containers handed over the counter and the deposit refunded from the till), or a retailer can install a reverse vending machine (RVM) on their premises (automatically accepts empty containers and refunds deposits).

Return point operators must:

  • accept scheme packaging from consumers;
  • pay back the deposit for each scheme container returned;
  • keep the scheme packaging for collection by a producer (or scheme administrator);
  • clearly display information at the return point about how to make a complaint to the person responsible for operating the return point;
  • display SEPA’s contact details.

Vending machine sales only

If the only drinks you sell on your premises are from a vending machine you do not need to operate a return point. You will have to meet all other retailer obligations, including:

  • charging the 20p deposit when selling a drink that is part of the scheme;
  • making it clear to the customer that the drink is part of the scheme and the deposit applies;
  • displaying information on how the customer can redeem the deposit.

For vending machines, the retailer is defined as either a) the owner of the vending machine (marked by name and address on the machine) or b) the business that manages and controls the premises where the vending machine stands (if there is no owner name or address on the machine).

More information on retailer obligations is available under What does this mean for me? section above.

Accepting scheme packaging/empty scheme containers

A return point operator has a legal responsibility to accept scheme packaging that is returned from a consumer. However, the operator can refuse to accept scheme packaging if:

  • the container is soiled, broken, not empty or not identifiable as being part of the scheme.
  • the return point is full and waiting for collection or uplift.
  • a consumer attempts to return more empty scheme containers than the number of drinks normally sold in a single transaction.

Refunding deposits

A return point operator must pay back the 20p deposit for each scheme container returned by the consumer. The return point operator can offer the consumer options for how the deposit is returned. For example, by way of charitable donation, store points or in-store vouchers, or wireless transfer. However, the deposit must equal 20p per container returned and there must be an option for the deposit to be available as a cash redemption.

Can I be exempt from operating a return point?

Retailers can apply for an exemption from acting as a return point. There are two types of exemption:

Proximity exemption - if there is an alternative return point located within reasonable distance to your premises, and the operator of that return point has agreed to accept the returns on your behalf.

Environmental health - if there is no reasonable way for you to operate a return point on your premises without risking being in breach of other legislation, such as environmental health, food or fire safety. 

The exemptions service for Scotland’s Deposit Return Scheme is run by Zero Waste Scotland on behalf of Scottish Ministers. Please visit the Zero Waste Scotland website for further information on exemptions.

How can I check who is registered?

We will publish and maintain a register of all producers who are registered to market and sell scheme articles on the Scottish market. You will be able to check this to make sure you are only selling drinks from producers that are registered to be part of Scotland’s Deposit Return Scheme.

The register will be available after the producer registration window closes in March 2023.

Further information