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Return Point Operator (RPO) Registration

Your Obligations

Retailers have a vital part to play in operating a successful Deposit Return Scheme in Scotland. As a Retailer, there are legal obligations to accept returns of empty drinks containers to be recycled, as well as paying and charging deposits on drinks bought and sold.

A Retailer is defined as an organisation who markets, offers for sale or sells drinks in Scotland which include face-to-face retail, online retail, sales in a hospitality setting, sales from vending machines, and wholesalers.

While hospitality businesses must take part in the scheme, their obligations will differ depending on the type of business. Organisations that only sell drinks to be consumed on the premises (e.g. pubs and restaurants) are classed as “Closed Loop” as their drink containers remain on-site. When drinks are sold by a hospitality business to be consumed elsewhere (e.g. take away outlets) the organisation is classed as a Retailer.

Anyone with an obligation to operate a Return Point must register with Circularity Scotland for returned drinks containers to be collected. If you require more information on your obligations, please visit Circularity Scotland’s website or SEPA’s website.


Sites are not obliged to operate a Return Point, and therefore do not need to register, if:

  • the site is an export shop
  • drinks are only sold from vending machines
  • drinks are only sold online or via telephone


Operating as a Return Point might not be right for every organisation and you may prefer to apply for an exemption. You are eligible to apply for an exemption for one of the following reasons:

Proximity – your site is within reasonable distance of another Return Point and they have agreed to accept the returns on your behalf.

Environmental health – your site does not allow you to operate a return point on your premises without risking being in breach of legislation, such as environmental health, food or fire safety.

You can apply for your exemption on Zero Waste Scotland's website.

Voluntary Return Points

You may not have a legal obligation to operate a Return Point but want to become a Voluntary Return Point to support the scheme, for example if you are a transport hub or a shopping centre. You must apply on Zero Waste Scotland’s website to become a Voluntary Return Point. Zero Waste Scotland must have granted your Voluntary Return Point status before you can register your Return point with Circularity Scotland.