How does the Scotland Bottle Deposit Scheme work and what should drinks producers do to comply?

The Scottish Deposit Return Scheme (DRS) is widely viewed by members as poorly designed and potentially unworkable. Key concerns raised:

**Complexity and enforcement gaps** — Members highlighted a critical flaw: there's no clear mechanism to distinguish where bottles were initially supplied (e.g. England vs. Scotland), making it difficult to prevent cross-border arbitrage (someone buying stock in Carlisle and returning it in Scotland to claim deposits). Without separate bar codes or tracking, enforcement appears impractical.

**Industry response** — Several producers are treating it as too bandwidth-intensive to plan around right now. One member reported switching their Scotland supply to **Nitro Cans only** (which fall outside the scheme) to avoid the administrative burden entirely.

**Advice sought** — Members recommend attending specialist briefings (e.g. **Johnston Carmichael** hosted a talk on 25 October) to understand obligations, though attendees acknowledged the scheme remains confusing.

**Wider sentiment** — There is broad scepticism that the scheme will proceed as planned; members compared it to Brexit-style policy that creates months of planning uncertainty only to be amended or abandoned at the last minute.

**Caveat**: The excerpts don't contain detailed compliance requirements, pricing, or a clear operational roadmap. Until the scheme is finalised and clarified by regulators, it's unclear whether full compliance is even practical for multi-region suppliers.