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NAWDO supports the recent call from LARAC and other waste operators for a comprehensive review of the proposed Deposit Return Scheme (DRS). NAWDO urges Government to fully assess the implications for local authorities, waste disposal authorities, and the wider resources and waste sector.
NAWDO shares concerns that the current evidence base does not adequately reflect the likely financial, operational, contractual, and infrastructure impacts on local government. The DRS Impact Assessment relies on historic data and assumptions that may no longer reflect current collection systems, material composition, consumer behaviours, or the cumulative effect of recent and forthcoming waste reforms.
Waste disposal authorities have invested substantially in treatment, transfer, sorting and disposal infrastructure based upon long-term policy objectives and waste composition assumptions. The removal of high-value aluminium and PET containers from local authority-managed waste streams has the potential to affect material revenues, increase processing costs, alter facility economics, and create contractual risks across existing infrastructure arrangements. These impacts require fuller consideration and quantification before implementation.
NAWDO is particularly concerned that DRS has largely been assessed in isolation from other significant reforms, including packaging Extended Producer Responsibility (pEPR), Simpler Recycling, Digital Waste Tracking and wider decarbonisation measures. A cumulative assessment is necessary to understand the combined effect of these policies on local authority finances, infrastructure planning, service delivery and statutory responsibilities.
NAWDO also believes there remains considerable uncertainty regarding actual scheme performance, public participation rates, impacts on recycling performance reporting, interactions with pEPR funding mechanisms and the practical consequences for existing waste management infrastructure. This calls into questions how environmentally beneficial the scheme will be in its current form.
Some overseas schemes have also seen widespread issues arising from scavenging of bins for material and significant extra expenditure to tackle vandalism and litter.
A precautionary approach to the scheme should now be adopted, supported by robust monitoring and review of arrangements involving local government representation.
NAWDO calls upon Government to:
- Publish an updated DRS Impact Assessment based on current local authority and industry data.
- Undertake a comprehensive cumulative assessment of DRS alongside pEPR, Simpler Recycling and related reforms.
- Ensure that waste disposal authorities are fully compensated for any loss of income, increased operating costs or contractual impacts.
- Review arrangements with meaningful local authority sector representation, and take into account local authority concerns.
- Consider whether implementation should be delayed until the impacts of pEPR and Simpler Recycling have been properly understood and evaluated.
- Assess the likely environmental outcomes of the scheme in its current form.
NAWDO remains committed to supporting measures that improve resource efficiency, increase recycling and reduce waste. However, any DRS must apply the above measures to ensure it is as beneficial as possible, and not implemented to the detriment of local authorities, who are working hard to achieve positive outcomes (both environmental and financial) for residents across the country.
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