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Wales announces divergence of DRS

On 18th of November 2024, the Welsh Government announced that it will not proceed with a joint DRS for drink containers with the other nations of the UK.

Introducing a DRS in the UK has not been short of its ups and downs, with the collapse of the Scottish DRS in June 2023 which was due to go live in July 2022, then August 2023, then October 2025 alongside the rest of the UK, following the delay of introducing the joint UK DRS until 2027. UK Government had previously intended to bring a joint UK DRS in October 2027. Whilst there would legally be three separate DRSs across the UK, defined as such as they will have separate Regulations, each of the four nation Governments agreed that the DRSs should be as interoperable as possible, and as such would be ‘joint’.

Why are Wales not aligning their DRS with the rest of the UK?
  1. Wales are a global leader when it comes to recycling, currently ranked as the second best nation in the world for recycling performance. The Welsh government have attributed this unique position as a factor for the diversion from the joint UK DRS, as Wales wants to ensure its DRS works to benefit its high performing recycling system and not detract from the incredible progress already made on recycling.
  2. The Welsh Government have also stated that another factor contributing to their divergence, was that they could not address issues caused by the Internal Market Act 2020 inherited by the previous Conservative Government, which seeks to prevent internal trade barriers among the four constituent countries of the United Kingdom. This follows the publication of a policy paper in April 2024 by the UK Government, that outlined that glass bottles would be excluded from the scheme(s), though noted that the Welsh Government still intended to include glass within their scheme. 

The UK Internal Market Act 2020 also resulted in the separate Scottish DRS collapsing. The UK Government declined the Scottish Government’s application for exemption from the UK Internal Market Act, to include glass within its DRS. This resulted in the further delay of the Scottish scheme roll out and Circularity Scotland Ltd (the scheme administrator) went into administration.

What does this mean for DRS in the other UK nations?

Shortly after the announcement from the Welsh Government, on the 19th of November 2024 the UK Government reaffirmed its commitment to delivering a DRS for drink containers in Northern Ireland, Scotland, and England in October 2027. The UK Government reaffirmed the benefits of a DRS focused on PET plastic, aluminium and steel drink containers, citing how 55% of litter by volume, from a 2020 composition analysis by Keep Britain Tidy, was plastic and metal drink containers. 

Next steps for Wales and the UK

Wales:

  • Despite the divergence from the joint UK DRS, the Welsh Government stated it remains committed to introducing a DRS for drink containers that will support the transition to a circular economy, that looks beyond recycling to reuse, in line with their Beyond Recycling Strategy for a circular economy in Wales.
  • The Welsh Government will continue to actively engage with industry and stakeholders, to understand the range of views on transitioning to reuse for drink containers, including glass, and drawing from international best practice.

UK:

  • The UK Government notified the draft Statutory Instrument (SI) for the English and Northern Irish DRS to the World Trade Organisation (WTO) on the 25th of April 2024 meeting the UK’s obligation as a member state. With Scotland needing to amend the Regulations (as amended) which are already in force. The Regulations for DRS for Scotland, Northern Ireland, and England are expected to come into force in early 2025.
  • This aligns with applications for the Deposit Management Organisation (DMO) opening in January 2025. Following this process, the DMO will be appointed in April 2025, and will take some time throughout the remainder of the year to establish itself. Including securing funding, appointing a leadership team, and designing and publishing decisions on key operational areas. The DMO will then need to provide businesses with the information to prepare for DRS launch in October 2027, and lead on establishing the necessary national collection and IT infrastructure, retailers procuring and installing reverse vending machines (RVMs), labelling activity, system wide testing, and commencement of consumer engagement.
Key takeaways
  • Wales intends to introduce a DRS separately to the rest of the UK nations, that compliments their existing high performing recycling system and supports the transition to reuse.
  • The UK Government intends to continue working in partnership with the Welsh Government, to understand the direction the Welsh DRS will take, but remains committed to rolling out a DRS for Scotland, Northern Ireland and England in October 2027, with PET plastic, aluminium and steel drink containers in scope.
  • Both the UK Government and the Welsh Government specifically will continue to engage with stakeholders to understand and incorporate their views into strategy, to ensure the DRSs to be introduced across the UK are a success.

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