EXCLUSIVE: After nearly two years of applications, no exemptions have been granted for indies yet in Scottish DRS

The Scottish government issued updated guidance for the exemptions process last month, with the intention of making it easier for stores to get approval

Minister for green skills, circular economy and biodiversity Lorna Slater

No independent retailer has yet secured an exemption for Scotland’s deposit return scheme (DRS), nine months before its scheduled implementation. 

The applications process opened in April 2020. Under proposals set out by the Scottish government at the time, retailers were eligible for an exemption if they struck up a partnership with an alternative return point within close proximity, or if they felt participating in the scheme would breach environmental-health conditions. 

According to data shared by ZWS and the Scottish government, a total of 36 applications have been lodged, with 16 specifying proximity and 20 citing environmental health. To date, 13 have been successful, and five have been rejected. 

Of those granted exemptions, four of the sites were petrol stations, four were Scotmid Co-op stores, three were Scotmid-owned value discounters that have struck up alternative return points with other stores in the chain, one was a catering trailer and another was an ice cream parlour. 

Morrisons has agreed to be the alternative return point for all the specified petrol stations, with Scotmid taking up the others. 

Last month, the Scottish government issued updated guidance for the exemptions process, with the intention of making it easier for stores to secure approval. 

As a result, return-point mapping and exemption support was issued, helping them identify alternative return points, taking away the need for them secure the partnership themselves. 

In addition, the government said it would take the size of a premises into account when determining the risk of breaching obligations relating to environmental health. 

Biffa has produced a mapping tool, which is available on ZWS’s website. The company is encouraging retailers to fill out the five-point questionnaire to help facilitate the sharing of return points. 

The news was welcomed by the industry, especially after one Scottish retailer filed a lawsuit against scheme administrator Circularity Scotland Limited (CSL), claiming hundreds of independent retailers would be forced to close due to the financial burden of the scheme

However, some independent retailers have since said they are concerned that by not participating they may lose sales to supermarkets, which are more equipped to adopt the scheme. 

From 16 August 2023, every single-use drinks container sold in Scotland – including plastic bottles, cans and glass – will be subject to a 20p deposit. 

This will be refunded to consumers when they take back the container to their local shops acting as a return-point operator, via a reverse vending machine or manually. 


The Scottish Environment Protection Agency, which is the regulator of the scheme, has reassured stores it won’t immediately adopt a strict enforcement approach with businesses when the scheme launches. 

Unit manager Kath McDowall said: “Rather than issue fines, we want to work with businesses that are trying to implement DRS. Advice and guidance is our main route to compliance.” 

A spokesperson told Better Retailing it intended to take a “pragmatic approach”, and will probably link up with local councils and trading standards when patrolling specific regions. 


When addressing attendees, minister for green skills, circular economy and biodiversity Lorna Slater committed to going live on 16 August 2023, despite suggestions the industry isn’t ready. 

“There will be a necessary learning period for businesses and consumers when the scheme is launched,” she said. “I want it to be pragmatic and adaptable, and to grow with the needs of businesses.” 

At the start of the year, drink manufacturers and retailers criticised the UK government’s decision to apply VAT to DRS. 

As a result, a value yet to be determined will be applied to deposits collected in Scotland, and eventually in Wales, England and Northern Ireland. 

Slater was “frustrated” a decision hadn’t yet been made, but said she was “escalating it as quickly as possible”. 

When DRS goes live, independent retailers will also be required to collect bottles delivered to homes through online delivery services such as Snappy Shopper, Uber Eats and Deliveroo

Details have yet to be confirmed with regard to what will be expected of stores, and the issue was barely brought up over the two-day event. However, Slater said she hoped to share an update with those affected “very soon”. 

Read more deposit return scheme (DRS) news and advice


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