Recycling DRS in Scotland - Evidence suggests the government pass on glass

At the 2019 LARAC Conference, held last week from 2-3 October, Zero Waste Scotland (ZWS) delivered a warning to local authorities (LAs). This warning was against ‘rash decisions’ following the implementation of DRS, specifically the alteration of current waste services. It was suggested that any changes could cause LAs to lose out when Extended Producer Responsibility (EPR) is introduced. However, have ZWS made a rash decision of their own when developing the DRS scheme?

Clear glass is the most recyclable technical material in the Scottish residual waste stream, however it is also the least recycled. The proposed inclusion of glass in a DRS scheme has the intention of increasing recycling rates, but what data is this assumption based upon? We have compiled a comprehensive evidence base for FEVE and, as an impartial third party, our findings are that the enforcement of a DRS including glass may be a barrier to increased recycling rates, the Scottish glass industry and the overall progression of the Circular Economy in Scotland.

Below, we draw out some of our key findings from the evidence base.

The first of which relates to the role of DRS in attaining best practice across Europe.  While DRS is being considered in Scotland as a means to increase recycling rates, it has been found that the 4 best performing EU countries do not have a DRS scheme in place, only an EPR scheme. Therefore, the role of DRS in attaining best practice is arguably non-existent. Improving the EPR scheme in place (or in the case of the UK, the PRN system) is a well proven route to increased recycling rates and best practice.

Our second key take away is on the note of legislation. While EPR is being updated to cover the full net costs of recovery, there are no such plans for a newly introduced DRS. Even if DRS was upgraded to this degree, it is likely the costs to industry would exceed those of a full net cost EPR scheme due to the high infrastructure and operating costs associated with DRS. Another concerning finding is the lack of incentive for eco-design associated with DRS. EPR legislation, especially the modulated variety, can have a large eco-design impact by incentivising factors such as recycled content, minimisation of material use and improved recyclability. When looking at DRS from these perspectives, it is clear that it falls short in areas where EPR does not.

Thirdly, our attention has been drawn to scope bias and unforeseen costs. The proposed DRS only covers beverage containers (i.e. bottles, cans etc.). While this covers a large proportion of plastic and aluminium containers, it does not cover one of the largest clear glass waste streams, jars. Since jars are not included, commonly go for recycling in a contaminated state and some councils are likely to reduce their curb side collections with the introduction of DRS, clear glass recycling rate in Scotland is likely to suffer. This will have a dramatic impact on the Scottish spirits industry, who rely on clear glass for the majority of products. Historically, the inclusion of glass in DRS schemes has also been more costly than initially anticipated. In Norway, the cost per unit of glass is 15 times higher than the cost per unit of plastic, mainly due to more complicated and less efficient collection.

So, what is our message here? From our research and analysis, it is clear to us that the inclusion of glass in the Scottish DRS should be reconsidered due to the overwhelming evidence we have reviewed. The fact that glass was included in the first place, without the grounding of a substantial evidence base, reveals a lack of due diligence. Oakdene Hollins have been working within the Circular Economy for 25 years. Our research and consulting experts have knowledge on a range of topics and are always keen to branch out into new ones. If your business or trade association requires the support a comprehensive evidence base, contact Owain Griffiths ( For queries regarding our work on glass and DRS, contact Peter Lee (

Jake Harding