Independent retailers looking to opt out of the deposit return scheme (DRS) in Scotland have welcomed a widening of its exemption criteria, but warned that urgent questions are still not being addressed by the scheme’s administrator. 

The comments follow new guidance from the Scottish government earlier this month that allows smaller retailers to apply for exemptions. 

Under the guidance, a retailer is likely to be approved for exemption if the footprint of their store is 100m2 or smaller. 

If the retailer is a food-to-go retailer, that criteria extends to 280m2. 

OPINION: I’m applying for a DRS exemption – Natalie Lightfoot, Londis Solo Convenience, Baillieston, Glasgow

A spokesperson from Zero Waste Scotland, which manages the exemptions process, said: “Retailers must demonstrate that operating a return point would mean a breach of other legislation, such as environmental health, food or fire safety.” 

Retailers can also apply for a proximity-based exemption if there is an alternative return point nearby with which it has an agreement. 

According to the new guidance, this would typically be within 400 metres from a store, and would open at roughly similar times. 

A return-point mapping service has been set up to help retailers identify points. 

Fed member and owner of Londis Solo Convenience in Glasgow Natalie Lightfoot confirmed she would be applying for a DRS exemption. 

However, she said further answers were needed to help her manage a transition to DRS. 

“I am a tiny store. I cannot physically house a DRS, and a manual return would be very difficult, but even if I got an exemption, there are still questions over implementation, which will affect everyone. 

“I buy drinks from a wholesaler in England, where there is no scheme. I need to know if there will be separate barcodes for each country, and how that will work? It throws up questions about availability,” she said. 

Biffa lodges application to build bulking station for Scottish DRS

According to the administrator of DRS, Circularity Scotland, current regulations do not require producers to create separate barcodes. However, doing so “will improve the security of the scheme”. 

It warns that producers who retain UK-wide barcode systems will pay more to be part of DRS. 

Circularity Scotland said: “We are working closely with the industry and stakeholders to address these challenges and gathering information as we move towards the scheme going live. 

“We’ll continue to provide updates in due course.” 

Scotland’s DRS is set to go live on 16 August 2023. It will cover PET, plastic, aluminium, steel and glass. No date has been set for a similar scheme in England. 

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