Rolling-out the Deposit Return Scheme, what to expect and key requirementsThe UK DRS system is set to go live from the 1st of October 2027.
This will require customers to pay a deposit on single-use drink containers which will be refundable on return of the container to a designated return point. The scheme administrator Exchange for Change are responsible for the design, implementation and operation of the DRS system in England, Scotland, and Northern Ireland. At current, Wales are yet to confirm their scheme administrator.
Who will the system apply to?
The DRS will apply to producers who manufacture, import or are the brand owners of drinks containers made of the in-scope materials, PET, aluminium and steel which hold between 150ml and 3 litres of drink. It is important to note that producers will be required to display the scheme logo and barcode on all in scope items. By the end of March 2026, the scheme will have released their material specifications for further information on the steps producers need to take to become compliant with the regulations, including details on the barcode requirements and the scheme logo. It is important to note that glass is exempt, and that these regulations will not at this current point apply to Wales and products sold in Wales, or retail businesses based in Wales.
The DRS will also apply to grocery retailers who will be mandated to host a return point. There are exemptions to this requirement for small retailers with a selling space less than 100. There is also the opportunity to voluntarily host a return point for various other premises. There will be further exemption criteria released in Q2 of 2026 for retailer requirements.
What do producers need to do to become compliant:
Producers will be obligated to pay a producer fee per container they place on the UK market. The fee details are expected to be communicated during Q2 of 2026. This fee will be determined by the value required to maintain the financial viability of Exchange for Change as a not-for-profit organisation. This fee will be reviewed on an annual basis and could be adjusted. On top of this, producers will also be expected to pay a deposit to Exchange for Change per container the place on the market. Producers will also be required to keep a record of and report on in-scope containers placed on the market and provide specific information on each container.
It is important that all drinks producers register with exchange for change. Registration is set to begin in late 2026 and producers are encouraged to register as early as possible. Once registered, approved producers will be added to the article list, which will be updated daily. The final article list is set to be completed by the 1st of July 2027.
Exchange for Change will be releasing a transition plan for consultation in Q2 of 2026. This will inform the steps to be taken by producers after the DRS goes live in October 2027. It will include details on the length of the transition period and the introduction of in-scope products, whilst stock of out-of-scope products are being sold through. After the transition period is over, only in-scope containers which are listed in the article list will be allowed to be placed on the market.
What do retailers need to be aware of:
The obligation of retailers are to act as return point operators. These can be run through two systems. The first being automatic, by using a reverse vending machine (RVM), and the second being manual, which is available for smaller grocers. Some small retailers will be exempt from all forms of collection, but further guidance on the exemption criteria will be confirmed later this year.
Hospitality sites, despite selling in scope products, will not be obligated to operate return points. Examples of these are coffee shops, recreational facilities, bars and restaurants. However, hospitality locations can collect materials, though guidance on this is yet to be released.
Retailers will be required to pay an upfront cost for the automatic return points though Exchange for Change is working on how to support retailers in the purchasing of these required materials. The upfront costs should be offset in the long term by the compensation of the retail handling fee which is paid per container to the retailer operating the return points. This fee is set to be released in Q2 of 2026.
Wrapping up the UK DRS:
There is still much information to be disclosed by Exchange for Change, and a lot to be developed over 2026. One such key date to monitor is the Q2 of the upcoming year which will bring lots of clarification on the requirements and expectations of the DRS. A secondary point for companies to bear in mind is for Wales to yet to confirm the scheme administrator. Companies should bear in mind that there is potential for the rollout in Wales to be implemented differently than the rest of the UK.
The rapid rate at which DRS and EPR regulations are evolving can be frustrating for businesses that seek to make sense of how they might be affected by a potential law. Ecoveritas has and will continue to keep track of and interpret EPR regulations, along with other environmental laws impacting packaging, textiles, electricals, batteries, and wider sectors.
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