Deposit Return Scheme in England Wales and Northern Ireland, closed 13 May 2019.

Defra consulted on the merits of a deposit return scheme in England, Wales and Northern Ireland. (Scotland consulted in late summer 2018).  Subsequent announcements made in March overtook the initial aim of the consultation.

British Destination has submitted a brief response.  In view of the changed and changing circumstances the following briefing note may be of use to British Destination members:

Deposit Return Schemes

The text of the briefing note reads:

UK wide Deposit Return Schemes

Potentially something and nothing for the moment but I am sufficiently nervous to want to alert you.

In March 2019 UK Government announced its intention to “introduce a Deposit Return Scheme [DRS] in England for single use drinks containers (whether plastic, glass or metal), subject to consultation late this year”.  The Scottish Government made similar announcement and launched its consultation in September 2018.  Although a devolved issue, a UK wide solution is thought desirable so Defra is working with Wales and Northern Ireland on joint consultations (and proposals?) and talking with Scotland about theirs.  Parallel consultations on associated measures to tackle single use plastic related issues, for example, via taxation on the supply or production chains are also underway and will feed into a wider Government strategy and may inform the direction of any DRS. See the announcement at:

https://www.gov.uk/government/news/deposit-return-scheme-in-fight-against-plastic

In February 2019 Defra launched a public consultation in England, Wales and Northern Ireland.  Closing on 13 May its stated aim was to: “help us to consider the merits of introducing a DRS”.  The subsequent announcement in March clearly preempted that consideration but the consultation will still inform thinking around the nature of the proposed scheme, yet to be formally consulted upon, “later this year”.  The March announcement also stated: “Following the passage of DRS-related legislation, there will be a short period of formal consultation on specific regulatory measures in early 2020”.  The assumption must be that nothing can come into effect, before late-2020 at the very earliest and more likely 2021 or later, if indeed a DRS is introduced at all. See the consultation outline at:

https://consult.defra.gov.uk/environment/introducing-a-deposit-return-scheme/

I didn’t circulate the February consultation to you. At the time it seemed too speculative and, until the March announcement, way too far off to bother busy tourism practitioners with. Having responded at a relatively superficial level on your behalf, essentially supporting the principle of the introduction of a widely based DRS to reduce, capture and recycle more single use drinks containers, I have reassessed my stance on whether destination mangers need to start engaging in the thought processes around DRS developments.

There is probably nothing that needs to be done immediately, but I would urge destination managers not to ignore the developing plans for DRS. It is worth consideration over the summer and it may be worth canvassing business views as and when they become more aware of the potential developments, as I am sure they will. If nothing else you and business partners might benefit from them knowing it is already on your local and, through us, your national radar. I will of course let you know as soon I know more about any further, formal consultations.

Why might I be worried?  The consultation documents sought views on so many options and variations on themes, across so many potentially important areas, all of which could then easily be mixed and matched, that I am left concerned that in achieving the laudable aims of a DRS we could end up gifted with an overly complex scheme; a scheme that could positively or negatively impact on consumers and consumption, on business and businesses, on the nature of places and on waste and litter management. I.E. on much that is central to destination management and the maintenance of a vibrant visitor economy.

I am sure local authorities will have engaged in the initial consultation, at the very least, paying close attention to the waste management and litter aspects.  I am not so certain that local destination management interests will have looked at the complexities of the DRS as a whole or considered every potential impact.  For example, how it might impact on individual small businesses should the scheme dictate that anyone selling drinks in single use containers must charge and refund deposits and therefore in all likelihood end up storing and return the used items for recycling?  The “system” certainly doesn’t have to be designed to work that way but it is one of many options that could be adopted.

Equally, rather than putting the onus on individual businesses we could end up with a scheme that relies on widely available public or private provision of reverse vending machines (RVM) and associated storage, or any one or a mix of a multitude of solutions in between.  How might the use of street based RVM impact on place making and maintaining quality public space? Or should the refunding be done in larger central points like supermarkets or recycling centres? But does that approach really act to discourage disposal into the public waste stream or influence casual littering?  There are no easy answers. DRS could be a monster waiting in the wings or more likely our savour from a tide of single use “drinks containers”; only time will tell.

To further illustrate why I might be nervous, the initial consultation makes it clear that what constitutes a “container” could be very narrowly defined (possibly less than 750mm plastic, glass or metal drinks containers) or extremely broad, to the extent of it potentially encompassing paper cartons and plastic pouches and/or paper and plastic cups; whilst what constitutes the drink that goes in them is also still open to definition and debate.  Should or shouldn’t it include: “milk or milk-based drinks”? Should milk substitute-based drinks be exempt on medical/health grounds? Getting these things and a myriad of others right or accidentally wrong from: what the level of deposit is, in what form it is taken or refunded (cash voucher or electronic credit), by whom, who runs the scheme nationally, regionally or locally, for what principle aims or purpose, for whose direct or indirect financial benefit, avoiding opportunities for multiple low level public, to large scale corporate fraud etc. are all extraordinarily important; especially if the DRS is to be effective and, thus, worth the vast effort and significant cost of implementing.

Instinct tells me that as an initial consultation every possible angle needed to be covered off in it, so perhaps I shouldn’t be too concerned?  Equally, experience tells me that the resulting proposal or range of proposals derived from past consultations, initial or otherwise, aren’t always informed by what’s practically achievable or necessary to make a good idea work in the ways it was intended to.  I am also conscious that at the destination level there is going to be conflicts between wanting to reduce waste and improving place and protecting business and businesses.   I am also very aware that businesses and, in particular, big business with big voices, from manufactures, producers, suppliers to the vendors and those on the waste management and recycling side will be understandably keen to limit any RDS’s negative impacts and, wherever possible, avoid or soften any proposed legislative based solutions.

I will consult with colleagues in private sector trade bodies over the coming weeks to try and get a much better understand of their positions and let you know what overarching national picture might be starting to look like.

Meanwhile any local views or intelligence on developments would be appreciate

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