ADEPT cautiously welcomed the publication of Defra’s response to the Deposit Return Scheme (DRS) consultation, as a positive sign that the Government is proceeding with its planned reform of the waste system. We are keen that the implementation of this strategy is accelerated. Despite this, however, we do have a number of concerns about the deposit return scheme proposals.

Our key concern is that the DRS is just one small part of the overarching waste system ‘jigsaw’ for which key stakeholders including councils still need to see the overall picture. While we recognise that the Government sees DRS can play a significant role in changing consumers’ behaviour, it is limited to beverage containers. Meanwhile, we are still waiting to hear the plans and requirements for the vast majority of the waste that communities generate: without this, it means that local authorities and the waste sector are unable to make decisions about new investment and reforming services.

New requirements around consistency in recycling collections will have a far more fundamental impact on residents, public finances and environmental outcomes but these are yet to be revealed. A revised Waste Prevention Plan is another vital missing piece of the jigsaw, necessary to ensure that the overall waste system reforms support reduced consumption and one world living.

In addition, we have grave concerns about a clear loophole in Defra’s policy: the planned exclusion of DRS materials from the Extended Producer Responsibility (EPR) regime. In the short term this approach could lead to ‘free riders’ – packaging producers shifting from glass to plastic or cans to avoid contributing to recycling costs, as until the DRS is launched, producers would not be under an obligation to deal or pay for packaging in the DRS scope. There is also the longer term problem of the estimated 10% of DRS material (over 2 billion bottles and cans each year) which will remain in litter, street bins and refuse which, again, producers will have no incentive to address as the costs will be borne by the public purse.

One of the shared ambitions of these packaging reforms is to make recycling easier, but in this regard surely a ‘digital DRS’, providing consumers with the opportunity to redeem their deposits online when an item is placed in the kerbside recycling box is the most convenient option. However, the Government’s response indicates a lukewarm ambition towards providing digital options, which ADEPT considers to be a massive, missed opportunity. A digital DRS system would maximise convenience for residents and avoid the huge unnecessary additional expense of providing reverse vending systems at retail premises, as well as avoiding duplication of waste transport and processing infrastructure.

In the response to DRS, the Government does not explore this option sufficiently, instead talking about requiring every beverage retailer to install a deposit redemption point. It is clear that they are seeing it as a physical process, relying on consumers to visit retail premises, rather than a digital process.

The original resource waste strategy was published in 2018, pre-pandemic – since then, we have seen a massive shift towards online purchasing. Requiring customers to travel to redeem deposits is out of step and flies in the face of this retail trend.

Our final concern is around how local authorities will receive funding for managing the cans and plastic bottles they will be required to still provide a collection service for. The Government’s response makes it really clear that local authorities will not receive automatic refunds for any DRS material that ends up in their collections. We therefore need clarification on how local authorities will process refunds for the collection of these materials, which effectively contribute to the costs of the public recycling service. There needs to be a simple, cost-effective solution for local authorities to redeem deposits on material.

In conclusion, we see the Government’s response to DRS as an important step towards the much-needed reform of waste policy, but a whole system picture is urgently needed along with more clarity and certainty. Local government is keen to work with Defra and industry to come up with a realistic transition plan to reform local waste services, supporting the shift to a more circular economy.

Steve Palfrey is chair of the Waste Group for the Association of Directors of Environment, Economy, Planning & Transport (ADEPT).