Online retailers

You are an online retailer or distance seller if you: 

  • sell drinks to consumers from your own website, regardless of whether you have a physical store or not; 
  • operate an online marketplace selling drinks that are supplied by a third party. 

If you are unsure if you are an online retailer or not, please get in touch with us by emailing

What does this mean for me?

Online retailers, or other distance sellers, that sell drinks (in scheme containers) to consumers in Scotland will have to comply with the scheme, regardless of where they are situated.

This means that even if your business is based outside Scotland, if you sell drinks to consumers in Scotland, the Regulations will apply to you. You will have legal responsibilities that you must comply with. These are called obligations.

Online retailer obligations

As an online retailer you must: 

  • only sell drinks on the Scottish market 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 on the Scottish market;
  • 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. This should be clear to a consumer before they put the drink in their virtual basket or decide to purchase;
  • clearly display information on how the customer can redeem the deposit;
  • operate a takeback service for the return of empty scheme containers;
  • store returned empty containers in a safe way, following the Duty of Care code of practice.

What is a takeback service?

Online retailers or distance sellers do not need to operate return points but must offer a takeback service to consumers in Scotland for the return of drink containers they have purchased.

A takeback service must: 

  • be offered without needing to make a further purchase;
  • be made available from the point of delivery; 
  • be free of charge to the consumer;
  • take scheme packaging back to either the retailer’s premises, return point or location for storage pending collection by a producer (or scheme administrator). 

The takeback service must be offered from the point of delivery. For example, if a customer had an order delivered to their home address, the takeback collection for return of empty containers would be from that same address. This is to ensure the scheme is accessible for all, including those who rely on home deliveries or who may not be able to return scheme containers to a physical location. The retailer can provide this service, or it can be carried out by someone else on behalf of the retailer.

Customers buying drinks through online sales do not have to use the takeback service provided and can return their empty containers to any return point.

Can I charge the consumer for a takeback service?

An online retailer or distance seller must provide a takeback service free of charge to the consumer.

The retailer can apply a temporary charge to cover the cost of materials or packaging used for collection and takeback. This charge must not be more than the value of the materials used. Once the empty scheme containers are returned, the customer must be refunded for any charge applied.

The retailer must also pay back the 20p deposit for each scheme container returned by the consumer.

Can I refuse to accept empty containers/pay back the deposit?

Online sellers only have to accept returns of scheme containers they have sold directly to the customer. As a takeback service operator, you can refuse to accept a return of empty containers disproportionately greater than the average number of drinks normally sold in a single transaction.

A takeback service operator does not have to provide a refund if the returned packaging is:  

  • not identifiable as being part of the scheme; 
  • soiled;
  • broken or damaged;
  • not empty.

Further information on takeback services is available on our Frequently asked questions page.

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 see who has registered to be part of Scotland’s Deposit Return Scheme.

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


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