Retailers - what you must do

It was announced on 7 June 2023 that the launch of Scotland’s Deposit Return Scheme will be delayed until at least October 2025. The full statement is available to view on the Scottish Government website: www.gov.scot/news/deposit-return/

Who is a retailer?

A retailer is:

  • someone who markets, offers for sale or sells the types of drinks in containers covered by the Regulations to someone in Scotland.

This includes:

  • face-to-face retail
  • online or distance sales
  • wholesalers
  • sales in a hospitality setting
  • sales through a vending machine.

This includes retailers who are based outside of Scotland so long as the product is sold to someone in Scotland.

What a retailer must do

For all drinks in single-use containers made from PET plastic, glass, steel or aluminium, sized between 100ml* and 3 litres, sold after the scheme launch date, you must:

Have clear signage

  • If a retail outlet, then you must have clear signage stating that the deposit of 20p will be applied.
  • If you are an online retailer then your website must state that the 20p deposit applies.
  • If you sell through a vending machine, then the information about the deposit must be visible on the vending machine.

Stock that you had purchased before the scheme launch date is exempt from the deposit, you must have signage that tells the consumer that no deposit will be charged, and no deposit will be redeemed if that particular container is returned.

Charge and redeem the deposit

Stock purchased on or after the date the scheme launches will be covered by the scheme.

As a retailer, you will pay the 20p deposit on each drink in a scheme container (scheme article) you buy from a producer or wholesaler . When you sell these drinks, you charge the customer the 20p deposit.

If a customer returns empty drink containers (scheme packaging) to you, you must pay the 20p deposit to them. You must then store the scheme packaging for collection by the producer or scheme administrator acting on their behalf. When they are collected, the producer, or scheme administrator acting on their behalf, will pay you the 20p deposit for each container collected.

Operate a return point

If you sell drinks in scheme packaging, you must operate a return point (unless exempt). This can be manual (e.g. a customer hands containers over the counter and receives their 20p back) or through a machine such as a reverse vending machine (RVM).

The operator of a return point must:

  • accept the containers being returned
  • pay the customer the 20p deposit amount per container
  • store all the containers that are returned for collection by the producer, or the scheme administrator acting on their behalf
  • provide information for customers with details of a complaints procedure for any consumer complaints, and also list SEPA contact details.

The return point operator can refuse to accept drinks containers:

  • that are not identified as belonging to Scotland’s Deposit Return Scheme
  • that are soiled
  • that are broken (or not intact)
  • that still contain liquid
  • if the return point is full and is waiting for collection or uplift
  • if a customer tries to return more empty scheme containers than the number of drinks normally sold in a single transaction.

Return points can also be operated by someone who doesn’t sell drinks. These are voluntary return points and are set up to collect scheme packaging by an organisation or business that has no obligation under the Regulations but has chosen to do so (e.g. schools, shopping centres, community groups).

You can apply to operate a voluntary return point (not based in a retail outlet that sells drinks in containers covered by the scheme) if you have plans that show you will be able to run the point for at least one year. You can find out more information about voluntary return points, and get an application form from: Zero Waste Scotland: Voluntary Return Point

Exemptions for return points

You can apply for an exemption from running a return point. There are two types of exemption.

  • Proximity exemption: if there is an alternative return point close enough, which the customers have access to, and the operator has agreed to accept containers on your behalf.
  • Environmental health exemption: if your premises are not suitable for operating a return point without breaching other legislation. This could be because of lack of space that could cause problems relating to:
    • health and safety;
    • food safety;
    • fire safety;
    • environmental protection;
    • public health.

Zero Waste Scotland is responsible for the exemption service. Please visit the Zero Waste Scotland website for further information or to apply for an exemption:

If you are granted an exemption, you must make it clear to customers, with signage:

  • that you are not a return point;
  • where to take containers for the deposit refund.

Charge a reasonable handling fee

If you operate a return point, takeback service or are a hospitality business collecting and storing scheme packaging, you can expect a reasonable handling fee to be paid to you by the producer or the scheme administrator. This will cover the costs associated with collecting and storing scheme packaging such as:

  • materials used for collection and storage;
  • staff time;
  • floor space rental;
  • vehicles used for collection or delivery of containers, if applicable.

The handling fee will be determined annually. Further information about handling fees is available on the Circularity Scotland website.

* A proposed change to the size of container in-scope of Scotland’s Deposit Return Scheme (50ml changing to 100ml) was announced by the Minister for Green Skills, Circular Economy and Biodiversity on 20 April 2023. This change to the scheme is subject to regulations to amend the Deposit Return Scheme for Scotland Regulations 2020 being laid in, and approved by, the Scottish Parliament.

Further information

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