Background
All the nations in the UK are moving towards Deposit Return Schemes (DRS) for drinks bottles and cans, which aim to improve recycling levels and reduce littering on land and sea. This mirrors EU legislation, which amended the Packaging and Packaging Waste Regulation earlier this year.
Manufacturers, retailers, importers and wholesalers operating across Europe will face significant regulatory changes to effect different requirements in different jurisdictions.
What do the schemes intend to cover?
Whilst the schemes vary, all cover beverage bottles and cans made mainly of wholly from of aluminium, steel or polyethylene terephthalate. UK schemes will apply to drinks cans and bottles with a capacity of between 150ml and 3 litres that are likely to be used once or for a short period of time. The EU scheme does not set a lower capacity limit for containers, though does allow for possible exemption for those below 100ml where participation is "not technically feasible".
The schemes also include the provision of "return points", where consumers hand over empty drinks containers in return for reimbursement. UK legislation requires some retailers to host return points and make deposit repayments to consumers. Retailer responsibility is also envisaged in EU legislation.
Which business will be affected?
Manufacturers, retailers, importers and wholesalers are most directly affected by the schemes, though those in the hospitality sector will want to check the applicability of the schemes for them.
In the UK, there are exemptions for low-volume product lines. Across both the UK and the EU, businesses that sell drinks for immediate consumption on the premises can choose not to charge the deposit – but must collect and store the empty containers.
What do the regulations look like?
In the EU
The latest legislation requires Member States to ensure the separate collection of at least 90% by weight of single-use plastic and single use metal beverage bottles, and to establish Deposit Return Schemes by 2029.
The EU requires recycled content for plastic beverage bottles to go up from 30% per container in 2030 to 65% in 2040. It also requires packaging covered by the DRS to be marked with a clear and unambiguous label. Nation States are able to legislate whether to require manufacturers to use a national label, or a label harmonised with the EU as a whole.
Around the UK
The nations of the UK have expressed their intent to operate closely aligned systems, despite different legislative frameworks. The joint policy statement in 2024 between the UK Government and devolved nations and a recent Senedd statement shows this desire. Each government emphasises its commitment to interoperability across the nations, though differences in approach persist.
The UK Government appointed the UK Deposit Management Organisation (UK DMO) in February 2025 to develop and deliver the schemes across the UK nations. UK DMO will design the infrastructure, manage collection, processing and sorting of cans and bottles, and oversee deposit collections and returns. However, the Welsh Government is seeking to appoint its own DMO.
The UK DMO reported in its October newsletter that it is "strengthen[ing] the foundations" of its organisation and has now published the Reverse Vending Machine Specification.
There are a raft of key dates expected to be published by the DMO. Retailers are yet to find out what they will be paid to handle returns but it is expected that retailers will be asked to charge a deposit of c.20p.
England and Northern Ireland
The regulations for England and Northern Ireland’s DRS are now on the statute books and will come into force from October 2027. These regulations set out what is included in the scheme, which businesses it applies to and the penalties applicable for non-compliance with the regulations.
Scotland
Since the Scottish Government abandoned a broader DRS (which was to include glass containers) its DRS is is likely to be similar to England and Northern Ireland and will begin from the same date. Amendments to Scottish legislation were made in June which update existing regulations first approved in 2020. In May 2025 the Scottish Government published a series of impact assessments, which helped shape the legislation and explain the changes over time.
Wales
The Welsh Government is diverging the most, including glass bottles in their DRS and putting reuse at the heart of its programme. Ministers have expressed an intention also to begin their DRS from October 2027.
The Welsh government closed its consultation on the scheme in November 2025. The Welsh Government is going to phase in its introduction of glass to try to ease interoperability within the UK.
