Defra has finally published their response to the DRS consultation issued in March 2021. It has obviously been a tortuous process, but given the declared date for implementation is October 2025, there is clearly still much to do.
The response covers the proposed system for England, Wales and Northern Ireland – Scotland will be starting their system in August this year.
Some key points to consider:
- All nations will be including PET drinks bottles up to 3 litres and steel/aluminium drinks cans.
- Wales and Scotland will also include glass bottles.
- Scotland has declared a 20p deposit, but the Defra response did not confirm the same although it alluded to it.
- DRS labelling will be mandatory on DRS packaging on implementation. So in Scotland from 16 August 2023 and in England, Wales and Northern Ireland from October 2025.
- The Defra response implies that Local Authorities will be able to claim deposits on DRS packaging sorted at MRFs although this is not yet clear for Scotland.
- DRS packaging will be excluded from the packaging waste regulations on implementation – so from the PRN system and EPR from August this year in Scotland and then from EPR from October 2025 in the rest of the UK.
- All retailers of drinks in DRS materials will have to provide a deposit payment and take back service once implemented. although there is still further work to be done on exemptions and on-line suppliers.
- VAT arrangements have yet to be finalised, but it could well be that the deposit is subject to VAT on the purchase of the materials, but the deposit repayment to the consumer will be net of VAT.
- The system will be managed through Deposit Management Organisations (DMOs), one for Scotland and one for the rest of the UK.
- Defra will set a 90% collection target within 3 years with interim targets of 70% and 80% for the two years preceding.
- Defra will publish regulations for DRS by the end of 2023.