UK Deposit Return Schemes Developments: beverage containers

All four nations of the UK have now passed legislation establishing deposit return schemes (DRS) for certain types of beverage containers, with the Welsh Parliament approving their regulations on 24 March 2026. With a target launch date of October 2027, many developments are underway which will have an impact on the marketing, supply and pricing of in-scope products and the flow-through of deposit and return handling fees. It is critical for all affected businesses to have visibility of the expected timings, an assessment of impacts and a solid understanding of how DRS interacts with packaging extended producer responsibility (pEPR). 

In this article, we recap key elements of the UK DRS, recent updates and some areas of uncertainty.   

DMO: Exchange for Change

Exchange for Change is the trading name of the UK Deposit Management Organisation (UK DMO), which will administer the DRS across England, Northern Ireland and Scotland (Wales is to appoint a DMO, with an application pending by Exchange for Change). It is engaging stakeholders to design and operate the scheme.  Its functions include setting the deposit amount, producer registration fees and payments to return point hosts, providing detailed guidance to help businesses in the drinks supply chain prepare for the DRS, informing consumers about the scheme, handling queries, meeting the scheme's collection targets, arranging collection and recycling of in-scope materials, and making collected material available to producers for purchase. 

England and Northern Ireland

The legislative basis for the English and Northern Irish scheme is The Deposit Scheme for Drinks Containers (England and Northern Ireland) Regulations 2025. 

Under these Regulations, the deposit will apply to all single-use drinks containers made wholly or mainly from aluminium, steel or PET plastic, with a capacity of between 150 millilitres and 3 litres. The scheme does not cover containers made from high-density polyethylene (HDPE) - e.g., milk bottles - nor containers used for liquid medicines or flavour enhancers.

Drinks producers — including manufacturers (typically brand owners), importers and those who fill and seal containers to order — must register with the DMO, apply a deposit to all in-scope containers, pay collected deposits to the DMO, comply with labelling requirements and report the number of drinks placed on the market. An exemption is available for "low-volume products", being product lines with fewer than 5,000 units per year, which will not incur producer fees, or need to apply deposits or carry scheme labelling, although registration and reporting obligations still apply. Producers based in the Republic of Ireland which supply drinks to the Northern Ireland market must also register as a producer under the scheme.

All retailers selling in-scope drinks must charge the deposit at the point of sale, having paid it themselves when purchasing from producers or wholesalers. Supermarkets, grocery stores, convenience stores and newsagents must host a return point (manual or via reverse vending machine), register with the DMO, refund the deposit upon return (by voucher, card or cash), store returned containers for collection and display scheme information. Retailers in urban areas with a retail space of less than 100 square metres are exempt from hosting a return point, though they may apply to do so voluntarily. Other organisations — such as hospitality venues, food-to-go stores, schools, gyms and mobile caterers — may also apply to host a voluntary return point. Premises selling drinks for immediate on-site consumption (for example, cafes, restaurants and pubs) may opt out of charging the deposit, provided they collect containers and display clear information about the opt-out. 

Scotland

The legal framework was originally created by the Deposit and Return Scheme for Scotland Regulations 2020, designed at a time when Scotland was significantly advanced with its DRS plans in comparison to the rest of the UK.  That scheme did not proceed when the previous Westminster government declined to grant permission under the Internal Market Act 2020 to enable glass to be covered in the Scottish scheme. The present scheme excludes glass, providing maximum alignment with England and Northern Ireland. 

Wales

A notable distinction in the newly passed Deposit Scheme for Drinks Containers (Wales)​ Regulations 2026 is that glass will also be included (aligning with the original proposal throughout the UK). In 2025 Wales secured an exclusion subject to conditions from the UK Internal Market Act 2020 under the current Westminster government. In an attempt to reduce interoperability issues, there will be a four-year transition period during which glass drinks containers will be exempt from labelling and will carry a zero-pence deposit. In addition, from October 2031 there will be a collection target for drinks containers that are capable of reuse.

Wales has proposed the establishment of an implementation taskforce to oversee interoperability across the UK schemes, working in partnership with the appointed DMOs. 

Industry Engagement

There is ongoing consultation activity relating to the DRS that businesses should be tracking, including: 

• RVM Material Specifications: A draft RVM Material Specification was issued for consultation on 15 December 2025, with the feedback deadline extended at stakeholders' request. A revised RVM Specification was published in February 2026.
• Deposit Value and Structure: Following a first consultation between 10 December 2025 and 30 January 2026, Exchange for Change consulted until 31 March 2026 on the proposed deposit structure and value. EFC's current recommendations are for a single, flat deposit of 20 pence. 
• Return Handling Fee (RHF): PwC ran a consultation on the cost model between 19 February and 5 March 2026. Exchange for Change expects to launch a final consultation on the RHF after Easter, with a proposed recommendation. The final RHF is expected to be published in May or June 2026. 

Comment and Next Steps

The UK DRS represents a significant change that will affect drinks producers, retailers, the wider supply chain and the waste management sector. Businesses should be actively monitoring and engaging with the ongoing developments and implementing action plans. 

The inclusion of glass solely in the Welsh scheme will need to be navigated carefully. Whilst the transitional lack of labelling and deposit requirements may assist to some extent, the inclusion of glass may impact infrastructure such as reverse vending machine specifications, and cross-border supply – including by distance selling and take-back – will need consideration.

Permitted development rights are being progressed for RVMs in England which should be reviewed. It is hoped that the DMO for Wales will be appointed promptly and practical guidance for all the UK will be forthcoming so that unnecessary and often expensive issues are avoided for a sector experiencing significant pEPR costs and intensive resource demands.