Circularity Scotland Limited (CSL) was incorporated in November 2020 and approved by the Scottish Government as the Scheme Administrator for Scotland’s Deposit Return Scheme (DRS) in March 2021. CSL is the vehicle set up by Members to deliver their collective legal obligations arising from The Deposit and Return Scheme for Scotland Regulations 2020, passed by the Scottish Parliament in May 2020. The legislation had cross party support when it was passed by the Scottish Parliament on May 2020; the scheme will go live on 16^th August 2023. The scheme is designed to encourage the maximum possible recycling of single-use drinks containers in the country as part of the Government’s commitment to the circular economy.

CSL is a company limited by guarantee whose members comprise the country’s largest drinks producers and retailers and relevant trade associations. It is regulated by the Scottish Environmental Protection Agency (SEPA). The company will work with organisations throughout the supply chain: producers, wholesalers, importers, retailers and the hospitality sector.

In full implementation CSL will have turnover in excess of £700m per annum, and will have significant cash reserves primarily driven by the timing impact of receiving deposits from producers and paying out deposits to consumers. CSL will act on behalf of c4,500 producers to deliver their legal responsibilities. All costs of operating and funding the DRS are the responsibility of these producers through the contracted producer fee charged to them by CSL.

Scotland is following in the footsteps of more than 40 other countries with DRS implementation, and the governments at Westminster and Dublin are in advanced planning for their own legislation. CSL’s stated ambition is also to become the Deposit Management Organisation for the equivalent scheme, which is to be implemented in England and Wales, thereby ensuring a seamless DRS scheme right across mainland Britain and in so doing delivering increased efficiencies through economies of scale. CSL has been designed to be capable of extending its operations to deliver that scheme – moving it to a company with turnover in excess of £5bn.

CSL will need to set up the processes, systems, infrastructure and staffing required to deliver those obligations by the agreed scheme Go Live date. The infrastructure required to deliver the management of logistical and financial transactions associated with 3bn scheme articles will be significant and needs to be incredibly robust given the high volume of low value transactions (20p deposit on each scheme article).

There will be reporting requirements to a number of high level stakeholders including Scottish Government, Scottish Environment Protection Agency (SEPA) and the members/producers themselves, many of which are large corporations. CSL is transforming from a ‘start up’ to a high profile company of significant scale and complexity from day one of Go Live. In addition, CSL will need to operate and be able to demonstrate a robust ‘control environment’ and have processes in place to control fraud attempts.

To learn more about Circularity Scotland Limited (CSL) was visit their website: https://circularityscotland.com