The Deposit and Return Scheme for PET bottles and Aluminium and Steel beverage cans officially started on 1 February 2024 across Ireland. In many places it has been a slow beginning as shops and consumers got used to the change. It is a hugely divisive approach to managing theses very specific waste streams and the waste industry and environmental commentators are quick to identify the obvious disadvantages of the Deposit and Return Scheme. They have cited the energy costs used to produce and run the machines, the space requirements, depletion of existing dry mixed recycling schemes and many other valid un wanted consequences. Popular across Europe these schemes are not new to many countries and achieve high level recovery of the target materials often greater than 95% recovery and include a broader range of materials including glass. The link to Single Use Plastics recycling is there, but not that entirely comprehensive as it only includes PET – reported to account for only 67% of the total beverage market. None of the other polymers used for beverage containers are included.
The first regulations SI 599 of 2021, set up the scheme and signalled the need for an approved body and retailer registration, but there were obvious gaps and weaknesses in these 2021 regs. A new set of regs was issued to replace the 2021 regs on 2 February 2024 – SI 33 of 2024. These replace the regs of 2021 and plug the gaps and offer a more comprehensive legal basis for the scheme. Key points now included that were missing in the first round of regulations are:
recognition that online supply and vending machines cannot easily work with returning deposits
reinforcement of exemptions for on premises consumption of beverages in these in-scope containers in hotels, restaurants, bars etc
a new exemption for small stores less than 250m2 from the need to participate
smoothing out of transition through to 1 June 2024 as a final change over date
We are in an era of generally over regulating in waste and that appeared in the first set of regulations as a need for all retailers to obtain a waste facility certificate of registration for each return location effectively mini local authority permits for every shop included in the scheme! This would have doubled the number of local authority regulated waste authorisations overnight. Thankfully the receipt and storage of containers prior to collection as part of this scheme has been excluded from the scope of S39(1) of the Waste Management Act and therefore it doesn’t need any form of authorisation. An insertion into the Waste Facility Permit Regulations in 2023 to create these CORs, has been swiftly removed in February 2024 by the 2024 DRS regulations.
As producers phase in the new containers with labels and QR codes old stock can still be sold by retailers up to 31 May 2024. Producers must switch their supply into the wholesale market with fully compliant labelling by 16 March 2024. Undoubtably there will be further learning from the phasing in of all this before it becomes part of our normalised behaviour but for now the rules are set in the new 2024 regulations.
Deposit and Return Scheme revised 2024 regulations issued | Environmental Training Solutions 2024