Scotland’s Deposit Return Scheme (DRS) will go live on the August 16 this year, and micro drinks producers from across the country have deep concerns that, without urgent review, the scheme will have a negative impact on existing sustainability measures within their industry.

Fiona Walsh of Toll House Sprits in Arbroath said: “I think we all agree that a Deposit Return Scheme is a good thing.

"Done well, it can reduce litter, increase recycling rates and reduce landfill and I have yet to meet a fellow producer who doesn’t encourage that”.

Small producers are already outperforming the brand leaders when it comes to being more sustainable and environmentally friendly.

Fife based Tay Spirits have put considerable investment into being kinder to the planet.

Co-founder Duncan McDougal explained their process, saying: “The spent grain from mashing and pot ale from distilling is fed to the local biogas plant which generates gas for the local villages. We recycle all by-products from our distilling process."

This is echoed by England based Tappers Distillery, who will need to register for the DRS if they wish to continue to trade in Scotland.

“Our spent botanical waste is sent for conversion into green biogas at a regional anaerobic digestion facility.

"We do what we can as a small business to minimise our impact on the environment," said founder Steve Tapril.

The current DRS legislation includes all single use drinks containers from 50ml to three litres, made from PET, aluminium and glass and it is the latter that is of most concern to small batch producers.

As a “Polluter Pays” designed scheme, it is the producers who will pick up the costs of running the scheme and it is putting considerable strain on smaller producers.

Sally Robertson of Own Label Company based in Edinburgh explained her issue with the inclusion of glass, saying: “DRS works well in other countries across the globe but most of them recognise and address the issues that including glass can add.

"A lot of the existing schemes exclude wines and spirits due to the added nuances within these sectors; vintage wines and champagnes are more likely to find their way into a cellar than a reverse vending machine (RVM) and smaller spirits or beer producers release tiny batches of single distillations and brews, which under the new legislation would require new barcodes and item registration with Circularity Scotland.

"The sector also has lots of varied bottle shapes, sizes and weights of glass which will be challenging for the counting machines and RVMs.

"It makes for a very clunky process which will stifle creativity and limit consumer choice.

“Existing schemes and research have shown that including glass in a DRS increases the cost of the scheme, it can drive up single use plastic and it can decrease the amount that glass is recycled as jars and sauce bottles are not included.

Dave Pert of Aberdeenshire based Easterton Cider added: "Most successful DRSs were introduced due to a lack of existing kerbside and bottle bank provision, something which is already well established here in Scotland where we have strong glass recycling rates."

Latest figures show that 60-70% of domestic and 95% of commercial glass is recycled in Scotland, whilst Circularity Scotland Ltd, the private company which has been appointed as scheme administrators for Scotland’s DRS, are aiming to achieve 80% return rate of all scheme articles (domestic and commercial) in year one.

By adding glass to the scheme, it adds layers of complexity not least for storage space of returns but also for collection services, as the bottles must remain intact until they reach the nearest counting centre, of which there are only three across Scotland (Aberdeen, Grangemouth and Motherwell).

The returned glass bottles are only smashed and processed once the barcodes have been successfully read at these centres, operated by BIFFA, the appointed logistics partner for the DRS.

Producers have asked BIFFA to provide data on the fleet of 172 vehicles they are planning to put onto the road to facilitate the bottle returns, hoping to see the procurement of lower emission or electric vehicles but the logistics partner to Scotland’s DRS are yet to make this information public, which is adding further concern to the environmental credentials of this scheme.

“The DRS will undermine our efforts to minimise our impact on the environment, through generating additional pollution from journeys undertaken by consumers to deposit points and BIFFA to counting and bulking centres.” said Steve Tapril.

Kit Carruthers, of Ninefold Distillery near Lockerbie, highlighted a further concern regarding transport, saying: “In rural areas with kerbside recycling, there will be an increase in the number of recycling vehicles on the road, operating with associated emissions”

It is understood that non DRS scheme articles like glass jam jars and sauce bottles will still need to be collected by local authorities.

If a reduction of litter is one of the primary aims of the DRS, there is valid confusion around the exclusion of some drinks containers.

Fiona Walsh explained producers confusion over containers: “We approached Circularity Scotland Ltd in summer 2022 and asked why fast food and coffee cups weren’t included in the scheme as they are single use drinks containers too, and are visibly a huge percentage of the litter found on our streets, hedgerows and beaches.

"They couldn’t give us a response or a reason for this decision and these items continue to be out of scope of the scheme.

"This seems rather remiss given the scheme is aiming to tackle the problem of littering, and yet craft spirit bottles are included."

Colin McLean of McLean’s Gin; a micro-gin producer in rural Strathaven, South Lanarkshire has deep concerns around the added road miles his bottles will have due to the DRS.

He said: “Our ‘Gin Lab’ is powered by solar energy. The same energy that runs the electric van that we use to make all of our local deliveries.

"It’s hard to overstate how small our carbon footprint is. At present our customers pop their empty bottles straight into the recycling bin outside their home for collection by the council, it couldn’t be simpler.

"Under the DRS proposals, our customers will now have to drive their empties to their nearest return point, a 15 mile round trip for many of our more rural customers, for their bottle to be transported halfway around the country putting a far more significant carbon footprint on each bottle than is necessary or sensible”.

These concerns are echoed by Stephen Kemp of The Orkney Distillery, based on their namesake islands.

He said: “Any of our bottles that do find their way into the DRS locally will now be transported by road by BIFFA, in small quantities, down to a central mainland Scotland sorting point.

"At present, all glass collected on Orkney is amassed until eventually there is a full ship load that can be more efficiently taken off the island in bulk to be recycled.

"Whilst the scheme may work in densely populated areas, it is going to create a massive environmental impact in terms of road miles and inefficiencies across all of the Scottish Islands and most of rural Scotland."

These concerns are also voiced by Finlay Geekie of Wild Thyme Spirits on Colonsay. He said: “We have no information on how often collections will take place on the island therefore we have no way of knowing how much space we will have to provide to cope with returns. Space is already at a premium.”

Many micro producers have already made great inroads to be sustainable, including operating their own in house bottle return scheme, similar to the old ‘Irn Bru scheme’ of days gone by.

Since 2020 Tweed Valley Distilling Co of Peebles has encouraged customers to either have their existing bottle refilled and relabelled at the doorstep or bring back empty bottles to be rinsed and reused.

“If only the DRS was a return to this system, it could work really well. Instead we will have to stop our own bottle refill scheme, and our bottles will need to be trucked all over Scotland to be smashed into cullet glass and resold to the big producers at a reduced cost” added Ben Glasgow of Tweed Valley Distilling Co.

A similar return scheme is operated by Dumfriesshire based Steilhead Cider, who also use locally gathered fruits in their cider production, saving the fruit from going to rot or ending up in landfill.

They have been recognised by the Galloway & South Ayrshire UNESCO Biosphere for their environmental endeavours.

The introduction of DRS to these small batch producers would see an end to these localised return schemes.

Other producers have introduced “Bottle for Life” type initiatives, where customers keep hold of their glass bottles and can purchase a more environmentally friendly refill pouch.

Fiona Walsh explained what may happen to these: “Each refill pouch removes 700g of packaging weight from the system and they are returned to us via Royal Mail’s freepost system, at our cost, to be responsibly recycled via the TerraCycle scheme.

"It’s working well and we can see our consumer behaviours changing, incentivised by a cost saving but also by the clear environmental benefits.

"Sadly, once the DRS kicks in, we will be penalised for every “bottle for life” that our customers keep hold of to refill.

"We have spent a lot of time and effort to reduce our carbon footprint in recent years, including installing solar panels and an air source heat pump at our production facility and removing all single use plastic from our packaging.

"This scheme feels like a step backwards for glass recycling and for the environment.

"There has been wide press coverage that Scottish Government, Lorna Slater, the minister in charge of the DRS, and Circularity Scotland have been working with industry however they have not directly consulted with smaller producers, and this is becoming more and more evident by the day, as further complexities emerge”.

At a recent workshop roadshow, Circularity Scotland presented figures that showed 35-40% of the largest drinks producers, including household names like Coca Cola, Tennents and Irn Bru, account for 95% of all scheme articles but they are intent on bringing all 4500 drinks producers into this new scheme, whether they currently operate environmentally beneficial initiatives or not and regardless of the volumes they produce.

“This seems very shortsighted and potentially damaging to the environment, particularly in remote and rural areas of Scotland, Walsh stated.

“We continue to ask Circularity Scotland, Scottish Government and Lorna Slater to listen to our concerns and to invite us to the table to present alternatives for small and micro producers, which will enable the DRS to proceed without a negative impact on our businesses and the environment.

"We collectively ask that producer registration, due to close at the end of February, is paused whilst these concerns are addressed”.