In its second round DRS consultation Defra set out the huge responsibilities to be given to the deposit management organisation (DMO), which will oversee large parts of Defra’s “industry led” DRS.
The DMO is due to be named by the summer of 2024 after the relevant legislation is laid out, ahead of the scheme’s rollout in England Wales and Northern Ireland by October 2025.
Responsibilities include, but are not limited to, setting the deposit level, ensuring ‘interoperability’ between the UK schemes, setting producer registration fees and deciding which retailers can be exempt from providing return points (see letsrecycle.com story).
The DMO will also have to seek private finance to fund the start-up, implementation, and operational costs of the scheme from day one, Defra explained.
The DMO will have the tools to incentivise consumers to return empty containers
- Defra
Interest
In its latest newsletter outlining progress on the DRS, Defra fielded a number of questions on how the DMO will work.
The department clarified that England and Northern Ireland will be appointing a single DMO, with Wales and Scotland taking a different route.
“However, it remains our ambition to have as much consistency between the schemes and DMOs as possible to ensure an efficient and interoperable scheme can be delivered,” Defra explained.
Defra also said it “no longer plans” to put in place a contract with the DMO, which will instead be appointed “through the regulations”. This comes as 70% of respondents favoured longevity.
Defra was also asked why the DMO is liable for collection rates, “when ultimately it is the consumer who determines whether they return the container”.
In response, the department said: “The DMO will have the tools to incentivise consumers to return empty containers. The DMO will need to ensure a good network of return points for consumers and develop a communications strategy to ensure consumers understand what they need to do and the reasons for it. These will be explored during the DMO appointment process.”
Funding
Considering the DMO is responsible for sourcing private funding for return points, which Defra said is likely to be in the form of a bank loan from the private sector, one asked why anybody would be interested in doing so if the DMO is also a not-for-profit.
Here, Defra reasoned that in the absence of a DMO the responsibilities would fall on producers individually and they would be subject to penalties if they did not meet the collection targets.
“Producers and retailers are incentivised to set up the DMO to discharge their responsibilities under the regulations,” the answer explained.
Another asked why government isn’t funding the set-up costs as it is government legislation being introduced.
Defra said however that not for profits are able to obtain funding and repayment of the funding would form part of the DMO’s cost base.
Labelling
Away from the management organisation, Defra also fielded questions on fraud and labelling.
Defra explained that it is seeking “a coherent approach to fraud” and it will continue to work with relevant stakeholders to develop these proposals.
A key part of the approach to minimising fraud is through labelling.
Defra intends to mandate the use of both a mark to identify the product as part of a DRS and the use of an identification marker such as a barcode or QR code to enable the container to be recognised at the return point as being part of the DRS.
The specific details and design of these markings would be for the DMO to decide and announce after they have been appointed.
Reverse Vending Machines/staff at manual collection points would not accept containers which are not part of the scheme.
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