Digital deposit return scheme: we know little more than a year ago

Photo credit: Saskia Risseeuw A year ago, Belgian industry was tasked with proving that their digital deposit return system is a better solution to litter than the classic system. We share our conclusions on the advisory board process and on what the pilots have taught us (or not). Advisory board pilot projects: public transparency or window-dressing? When the pilot projects were launched to test digital deposit return in 2023, an advisory board was established, consisting of environmental, consumer and poverty organisations. What was the purpose? As the Flemish Minister for Environment Zuhal Demir herself said in January 2023 “ An advisory board will be set up including, among others, environmental organisations that can also transparently question, share, consult and analyse all information ” ( Plenary session 18 January 2023). Transparency and constructive feedback from public stakeholders were therefore the objectives. A much-needed transparency and involvement of these actors, given the over-representation of industry in the pilots. A few examples. Who was in charge of the rollout of the pilots? The industry (Fost Plus). Who has three seats on the steering committee of the pilots? The industry (Fost Plus, Comeos, Fevia). Who was heard in a first hearing in July and is the only stakeholder invited to the hearings tomorrow alongside OVAM? Yes, you guessed it right: the industry (Fost Plus). Isn't it a bit like asking a student to design their own test and then grade it? As Zuhal Demir said “ the pen is held by OVAM and by our services ” ( 18 January ), so Fost Plus should have no say in this. The fact that the steering committee was able to inspect OVAM's final report is in itself a question of 'who holds the pen'. So you may now wonder: have the members of the Advisory Board been heard in their feedback? Hard to say, as we haven't seen the final report yet. As a result, it is also difficult to know whether our advice has been taken into account. And yes, we were able to provide feedback on the pilots. But this was not made easy for us. A few examples: For instance, in the final phase of the pilot, we had to insist a lot on extra follow-up meetings. Preparatory material for the meetings (latest reports of more than 150 pages) was sent at the last minute (e.g. less than 48 hours in advance) despite several requests to receive the agenda in a timely manner. OVAM published press releases about the progress of the pilots without involving or informing the advisory board. The press release of 15 November even appeared a few hours before the meeting with the advisory board and already contained preliminary conclusions about the pilots. What was the point of meeting then, if the conclusions were already set? Today, Wednesday 13 December, hearings are taking place on the definitive pilots. In light of these upcoming hearings, we share our own assessment of the five evaluation criteria determined by OVAM that the pilots must be able to address. Digital deposit return pilot projects: what have we learned? Despite the efforts of the industry and all the work (and money) put into these pilots, we must be realistic. The results are insufficient to confirm whether digital deposit return can be effectively set up in 2025 and, even more worryingly, whether it would actually contribute to reducing the amount of packaging in litter. 1. Effectiveness: what are the actual benefits of digital deposit return? No measurable return rate Although the 'scan ratio' (scanned quantity / sold quantity) is interesting to look at, it does not say much about the 'return rate' (packaging collected in a certified manner). That being said, one must acknowledge that the fact that at most 1 in 4 potential users used the system remains low. Impact on litter: we know no more than before This was the most important and highly anticipated result. The whole point of the pilots was to see whether digital deposit return reduces the presence of packaging in litter. The answer is simple: we know no more about this than we did a year ago. That is a fact. Both the pilots in Bobbejaanland and Center Parks De Haan yielded no significant results. This was even mentioned by the consultancy firm brought in for the occasion (Normec-OWS). This is due to methodological errors such as the lack of a post-measurement (to compare results) but also ignorance of consumption patterns. An example: A simple calculation (see our spreadsheet) of the Bobbejaanland results demonstrates this point (Report 1a. p33 ove

Photo credit: Saskia Risseeuw

A year ago, Belgian industry was tasked with proving that their digital deposit return system is a better solution to litter than the classic system. We share our conclusions on the advisory board process and on what the pilots have taught us (or not).

Advisory board pilot projects: public transparency or window-dressing?

When the pilot projects were launched to test digital deposit return in 2023, an advisory board was established, consisting of environmental, consumer and poverty organisations.

What was the purpose? As the Flemish Minister for Environment Zuhal Demir herself said in January 2023 “An advisory board will be set up including, among others, environmental organisations that can also transparently question, share, consult and analyse all information“ (Plenary session 18 January 2023). Transparency and constructive feedback from public stakeholders were therefore the objectives.

A much-needed transparency and involvement of these actors, given the over-representation of industry in the pilots. A few examples.

Who was in charge of the rollout of the pilots? The industry (Fost Plus).

Who has three seats on the steering committee of the pilots? The industry (Fost Plus, Comeos, Fevia).

Who was heard in a first hearing in July and is the only stakeholder invited to the hearings tomorrow alongside OVAM? Yes, you guessed it right: the industry (Fost Plus).

Is it not a bit like asking a student to design their own test and then grade it? As Zuhal Demir said “the pen is held by OVAM and by our services“ (18 January), so Fost Plus should have no say in this. The fact that the steering committee was able to inspect OVAM's final report is in itself a question of 'who holds the pen'.

So you may now wonder: have the members of the Advisory Board been heard in their feedback? Hard to say, as we haven't seen the final report yet. As a result, it is also difficult to know whether our advice has been taken into account.

And yes, we were able to provide feedback on the pilots. But this was not made easy for us. A few examples:

For instance, in the final phase of the pilot, we had to insist a lot on extra follow-up meetings.

Preparatory material for the meetings (latest reports of more than 150 pages) was sent at the last minute (e.g. less than 48 hours in advance) despite several requests to receive the agenda in a timely manner.

The OVAM published press releases about the progress of the pilots without involving or informing the advisory board. The press release of 15 November even appeared a few hours before the meeting with the advisory board and already contained preliminary conclusions about the pilots. What was the point of meeting then, if the conclusions were already set?

Today, Wednesday 13 December, hearings are taking place on the definitive pilots. In light of those upcoming hearings, we share our own assessment of the five evaluation criteria determined by OVAM that the pilots must be able to address.

Digital deposit return pilot projects: what have we learned?

Despite the efforts of the industry and all the work (and money) put into these pilots, we must be realistic. The results are insufficient to confirm whether digital deposit return can be effectively set up in 2025 and, even more worryingly, whether it would actually contribute to reducing the amount of packaging in litter.

1. Effectiveness: what are the actual benefits of digital deposit return?

No measurable return rate

Although the 'scan ratio' (scanned quantity / sold quantity) is interesting to look at, it does not say much about the 'return rate' (packaging collected in a certified manner). That being said, one must acknowledge that the fact that at most 1 in 4 potential users used the system remains low.

Impact on litter: we know no more than before

This was the most important and highly anticipated result. The whole point of the pilots was to see whether digital deposit return reduces the presence of packaging in litter.

The answer is simple: we know no more about this than we did a year ago. That is a fact.

Both the pilots in Bobbejaanland and Center Parks De Haan yielded no significant results. This was even mentioned by the consultancy firm brought in for the occasion (Normec-OWS). This is due to methodological errors such as the lack of a post-measurement (to compare results) but also ignorance of consumption patterns.

An example: A simple calculation (see our spreadsheet) of the Bobbejaanland results demonstrates this point (Report 1a. p33 over p25). When we neutralise the quantities sold in the park (footnote: we must recognise that this only reflects a trend in purchasing behaviour and not the full spectrum of purchasing behaviour, since drinks can also be bought outside the amusement park), we see that the ratio (amount of litter / amount of drinks sold) remained similar throughout the pilots. A slight increase can even be observed.

The pilots did not measure any significant impact on litter. Any attempt to conclude otherwise is misleading and untrue.

Most threatening is the fact that 'deactivated' packaging can still end up in litter. The presence of 32 packagings with unique codes in the litter in the De Haan pilot shows the limited effect of this system. Much worse is that 28% of the packaging found in the litter had been deactivated (9). Users can get their money back while the packaging still ends up in the litter.

2. Accessibility: can everyone use the system?

Digital deposit return is claimed to be more accessible because everyone can use it anywhere and 24/7. However, not everyone has access to a smartphone, internet or a bank account (for example refugees, people in situations of over-indebtedness or homelessness). Home scanners were offered as a solution to this problem. While this is interesting at home, it does not solve the problem on the go. The most 'vulnerable' part of the population would remain excluded from the system where litter occurs. Doing more of what already works is not a solution. This will also not be a solution for the million tourists travelling through Belgium. The barrier for them to participate in the system will be very high (compared to a 'classic' system).

During the pilots, the system was only used by a small (non-representative) part of the population: bank employees or students, visitors to an amusement park, families in a Center Park and only a few residents of one shopping street. This does not say much about the whole population. Methodologically, the surveys carried out are of little value, as they were mainly shared with users. As users, they had already agreed to participate and were therefore probably more positive about the system than the average consumer (i.e. response bias). It would have been necessary to investigate why non-users (3/4 of potential users) do not use the system.

Here too, much more research would be needed to conclude that the system is accessible to all consumers of plastic bottles and cans.

3. Fraud resistance: can people abuse the system?

The sector claims that fraud was successfully prevented during the pilot projects. However, problems with large-scale fraud such as cyber attacks (i.e. hacking the system to access all generated unique codes) were not resolved.

The industry also proposes to activate the codes on production lines, which, as we mentioned about a year ago, would invariably lead to many fraud attempts.

People can be very creative when it comes to abusing systems to get money. And digital deposit return (compared to classic deposit return) seems to offer far more opportunities to do so, because people do not have to properly return their packaging to get their money back.

A few examples: In KBC Leuven, people tried to take photos of the QR codes in the vending machines to get their money back. In Bobbejaanland, more than 1 in 10 users tried to abuse the system. Bins were moved. Those were fraud attempts that we had not even anticipated a year ago.

4. Compliance with GDPR / Privacy legislation

These aspects relate to the security of data management and compliance with GDPR rules for digital deposit return. The industry assures that secure data management is possible and that the system is GDPR compliant. But that does not detract from the risk that citizens may not want to participate in the system due to mistrust or fear, as seen in Bobbejaanland with 1 in 4 users who could not participate because they had deactivated their geolocation.

Especially given that consent to share geolocation was required in the last two pilots to be able to use the system. Can you honestly force people to provide that data to get their money back?