Scotland Deposit Return Scheme

What is the Scottish Deposit Return Scheme?

The Deposit and Return Scheme for Scotland Regulations 2020 was passed by the Scottish Parliament in May 2020.

The implementation of this scheme has been delayed and the new launch date is August 16, 2023. The regulations require the implementation of a 20 pence deposit, paid by the customer, to be applied to each scheme article on Amazon sold in Scotland.

A Scheme Article means a drink (regardless of whether it is sold alone or as a unit in a multipack), which is contained and sold in packaging and is:

1. Mainly made from PET plastic, glass, steel or aluminium.
2. Designed to contain at least 50 millilitres and no more than 3 litres of liquid, and sealed in an airtight and watertight state at the point of sale.
3. Cannot be returned to its state at the point of sale by the consumer.
4. Single-use packaging.

Who is the scheme regulated by?

The scheme will be regulated by the Scottish Environment Protection Agency (SEPA) and administered by Circularity Scotland (CS).

For more information about the role of CS as scheme administrator, go to: https://circularityscotland.com/.

What do I need to do now?

We will provide detailed instructions on the next steps in the coming months, but for now:

• If you have not done so already, familiarise yourself with the obligations to check whether these regulations will impact you and the products you sell on Amazon.
• Amazon will require all sellers providing scheme articles to register with CS when registration opens. This will be available before the scheme launch date and we will issue further communications when available. You may be required to provide proof that you’re working with a SEPA and CS registered producer.
• New packaging/labelling is not mandatory within the regulations, but you are heavily encouraged to do this as it will result in a lower fee rate from CS and provides a better customer experience. If this is something you are considering, we encourage you to plan for this change well ahead of time.

How do I know if I am a Producer and need to register with SEPA and CS?

• You will be a producer if the scheme article is branded in the UK and you are the brand owner, that is, the person who, during their business, puts a name, trade mark or other distinguishing mark on a scheme article or the packaging. You will then be held out to be the manufacturer or the originator of the scheme article.
• If the scheme article is branded outside the UK, the Importer of the scheme article, that is, the person who, during the business, first markets, offers for sale or sells the scheme article in the UK, will be the producer.

If you are not the brand owner or the importer, you must acquire and share proof with us that the producer of the products you sell is registered with SEPA and CS.

Do I need to register with both SEPA and CS?

If you are a producer, you need to be registered with both SEPA and CS, but if you register with CS, they will register with SEPA on your behalf.

How will I provide registration confirmation?

We will provide further details on this in due course. This will likely be via a document submission through Seller Central.

How do customers get their deposit back?

Customers will get their 20 pence deposit back when they return the empty container to a return point or through a take-back service that Amazon will provide. We are working on finalising the operations related to the take-back service and will be able to share more information by the end of the year.

As a seller, will I refund the customer 20 pence upon return?

No. Amazon will be responsible for refunding the 20 pence deposit to the customer once they have returned the container.

As a seller, what will I have to pay?

Every producer registered with CS will need to pay a fee. CS is currently working on ascertaining the fee. We will be able to provide you with more information in this regard by spring 2022.

Click here for more information on cash flow through the supply chain.

Will the process for seller-fulfilled and FBA sellers be the same?

Yes. There will be no difference between FBA and seller-fulfilled products in terms of ASIN creation, labelling and deposit pricing.

As a seller, how will I know which products have had a deposit applied and were paid for by the customer?

We are currently working on this feature and will provide more information once it becomes available.

Do the regulations apply regardless of whether I am based in the UK or not?

Yes. The regulation applies when the end customer is based in Scotland. This includes sales through the UK website by sellers based outside the UK.

Does Amazon plan on keeping one ASIN or creating two separate ASINs for Scotland vs. rest of the UK?

This will depend on whether manufacturers decide to create separate European Article Numbers (EANs) for Scotland vs. the rest of the UK. This is not a mandate in the regulations. For products where the EANs differ, there will be two separate ASINs.

How does Amazon plan on refunding sellers for the deposit if the same ASIN is used for Scotland and rest of the UK?

We are currently working on this and will be able to provide more information in the upcoming days.

How do I get more information?

CS is not currently open for registration. You can now subscribe to receive updates through the CS website. Go to: https://circularityscotland.com/

Useful links –

• Legislation:
  • https://www.legislation.gov.uk/ssi/2020/154/made
  • https://www.legislation.gov.uk/sdsi/2022/9780111052679
• CS: https://circularityscotland.com/
• Zero Waste Scotland (useful information and explanatory videos): https://depositreturnscheme.zerowastescotland.org.uk/