The Return Scheme for Drinks Containers (England and Northern Ireland) Regulations 2024: RPC opinion (green rated)
Regulatory Policy Committee’s opinion on Defra's Impact Assessment (IA) in respect of the Deposit Return Scheme on beverage containers in England and Northern Ireland
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The measure introduces a Deposit Return Scheme (DRS) covering polyethylene terephthalate (PET) drinks bottles, steel drinks cans and aluminium drinks cans between 150ml and 3l in size.
On first submission the IA received an initial review notice (IRN) from the RPC. A revised IA has satisfactorily addressed issues around the assessment of direct impacts on business. The overall analysis has been strengthened since 2022 but there are some areas for further improvement, such as the assessment of risk, uncertainty, consumer and wider impacts. The link to the published IA is here.
The Department received a fit for purpose opinion on a previous final stage IA on 3 March 2022. The RPC validated an EANDCB figure of £100.1 million. The estimated net present social value was £876 million. The measure is broadly as before but the new IA takes account of policy developments, including:
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Implementation date of October 2027. (Previously, mid-2024).
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Collection target rising to 90 per cent by year 3 of the scheme (Previously assumed to be 85 per cent)
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Minimum size of container increased to 150ml. (Previously, 50ml).
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Supermarkets and convenience stores obligated to host a return point. (Previously, all retailers selling an in-scope container would be obligated to host a return point).
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Exemptions for retailers in urban areas less than 100sqm in size.
The Department has undertaken extensive stakeholder engagement since 2022 and has used this to update cost estimates and refine assumptions. In addition, the new IA presents a full appraisal of all of the consultation options, rather than just the preferred policy option.
This measure is part of the wider set of government initiatives to tackle littering, increase recycling rates and to incentivise producers to take greater responsibility for the environmental impacts of their products. Other measures are Simpler Recycling and the Packaging extended producer responsibility. The RPC has issued opinions on the IAs for these measures to Defra, with the latter being published on its website.