P-05-750 For single use items: introduce a Deposit Return System for drink containers and make fast food containers and utensils compostable, Correspondence – Petitioner to Committee, 04.03.20


MCS welcomes the opportunity to respond to the Deputy Ministers letter of response to your enquiry. Please find below our comments.

Comments on the published survey: Consumer research to inform the design of an effective deposit return scheme

1.    MCS welcomes the finding that nearly three quarters of adult survey participants supported the idea of a DRS; and between 77% and 83% of survey participants reported they would use a DRS on all or most occasions. 

This demonstrates a high level of public support around these proposed measures. We have public support, cross party support and the Deputy Ministers support there should no barriers to implementing this as soon as legally able.

2.    The findings suggested that older people, those in lower social grades and those without access to a household car may be less able to engage with a DRS for practical and financial reasons.

This is to be accepted however it is not insurmountable and has been tackled in other countries where schemes are already in place. As stated in the original Defra consultation document1, in circumstances where people may find it difficult to access return points due to isolation of rural areas, age or lack of access to transport, there would need to be provision which would allow these consumers to return drinks containers and receive their deposit refund. For example:

·         pick-up services for in-scope DRS material in remote and rural areas and for those who would not otherwise be able to access a return point; 

·         RVMs could be located in areas of high footfall such as transport hubs, so that they are more easily accessible than if only placed within retail points; 

·         online retailers selling drinks in in-scope drinks containers could be obligated to pick up and refund DRS material.

3.    10p was the most popular amount amongst survey participants (37%)

Scotland is the first part of the UK to introduce a deposit return scheme for drinks containers with a deposit amount of 20p. MCS are of the view that in order to make the scheme as easy to understand as possible, a standardised deposit across the UK should be in place. It would therefore be beneficial to adopt Scotland’s deposit of 20p per container. The Scottish consultation document states that the 20p deposit will provide a strong incentive for shoppers to return single-use drinks containers for recycling, thereby increasing the number of these containers which are recycled (and reducing the number which could potentially end up as litter)2. As we have seen with the carrier bag charge, the initial 10p cost was a barrier to purchasing a single use carrier bag but over time this appeared to be a less of an incentive. A study by the Environmental Investigation Agency and Greenpeace3 has found that Supermarkets sold 1.5 billion “bags for life” last year (2019), this is an estimated 54 bags per household.  Not only does this suggest that ‘bags for life’ need to be incorporated into the carrier bag charge, but that costs need to promote behaviour change without being a financial hardship. We are concerned that there has been a replacement of one single use disposable item (10p carrier bag) with another (bag for life). We would hope that a 20p DRS fee would be enough of an incentive in the long run to return the bottles.

4.    An ‘all-in’ scheme, where all containers carried the same deposit cost, regardless of size, was considered by participants to be the most effective scheme.

It is important to note that an ‘all in’ scheme should include not only containers of all sizes but also all materials including aluminium, glass, plastic, and paper cartons. The Defra consultation concluded that some respondents felt that introducing a DRS, which could include only certain materials and containers while excluding others, could lead to consumer confusion and have the unintended consequence of dis-incentivising recycling through unnecessary complications.

MCS are of the view that including all materials and sizes will result in levelling the playing field for producers and ensure that producers do not switch to materials not included in the system thus distorting the market and potentially creating further environmental problems. Further to this, the more material captured the higher the chances are of increasing recycling levels and decreasing litter levels of these items. 

The Scottish system currently only includes PET plastic, MCS would like to see all plastic included.

5.    The Defra consultation concluded: We are minded to introduce a DRS for drinks containers in England and Wales from 2023

MCS is of the view that they already have the information and facts they need to adopt DRS, this delay will result in increasing the cost, negatively impacting businesses and resulting in ongoing environmental impacts.  The proposed UK Environment Bill will devolve the powers for a DRS to Welsh Government and enable them to set their own targets, therefore Defra will not be able to introduce an England and Wales scheme however we hope all 4 countries will work together to create a standardised scheme.

6.    In parallel work has been undertaken on the primary legislation that will allow Welsh Ministers to enact regulations to bring in a DRS. This is included in the UK Environment Bill, which is currently before the UK Parliament and expected to receive Royal Assent by Christmas 2020.

See above. Within Wales we would recommend that all background work, stakeholder consultation, decisions and legisation be finalised prior to the UK Environment Act receiving Royal Assent at the end of 2020, to allow for immediate roll out of the deposit return scheme after this time.

7.    We are also facilitating a DRS trial using alternative ICT technology and have provided financial support to another DRS trial from our Circular Economy Fund. 

We have not received any details on these 2 trails so cannot comment of their impact or effectiveness. We would request further information.

8.    MCS welcomes that the Welsh government are looking to take action on Extended Producer Responsibility (EPR), as well as going above and beyond the EU Single Use Plastic Directive (SUDP). 

 The Defra consultation on Extended Producer Responsibility for the UK concluded that the Government’s intention is to make the necessary legislative changes for a reformed packaging producer responsibility system by 2021, with a new system to be operational from 20234. Similarly to the timelines given for DRS, MCS is of the view that they already have the information and facts they need to adopt EPR successfully in the UK as soon as the Environment Bill reaches Royal Assent. 

We would also welcome more information on a timescale for incorporating measures on single use plastics into Welsh legislation. To date the European Legislation includes a ban on the following items:

A EU-wide ban of single-use plastic cotton buds, straws, plates, cutlery, beverage stirrers, balloon sticks, oxo-degradable plastics, and expanded polystyrene food containers, beverage containers and beverage cups by 2021.

We have been informed that the delay to introducing ban on cotton bud sticks, straws etc. is that Welsh Government want to introduce comprehensive legislation covering multiple items rather than piecemeal individual legislation. This is logical but it has led to delays and items banned elsewhere in the UK, are still on sale in Wales, therefore we would recommend swift implementation of the SUPD.

Additionally, we would hope Welsh Government would be more aspirational in the types of items being banned, above those within the SUPD.

Yours faithfully, 


Gill Bell 


Head of Conservation Wales 

Marine Conservation Society