Deposit return scheme for drinks producers: what to do before October 2027

Most of the work comes before launch day. Registration is already open. Pack artwork and billing both take time to change, so plan against the dates that are already fixed and watch the ones still marked provisional.

What are the key dates?

The England and Northern Ireland regulations come into force on 1 October 2027. The part covering registration of scheme producers came into force earlier.

Who is Exchange for Change?

Exchange for Change is the trading name of UK Deposit Management Organisation (UK DMO), the not-for-profit body set up by industry to run the scheme. It took the name in January 2026, and by August 2026 it had also been appointed for Wales.

Exchange for Change administers the scheme in all four nations. It set the deposit at 20p and sets the producer fees. It also runs registration and arranges collection and recycling of the returned containers.

For a producer, it is the organisation you register with and report volumes to. Your deposit payments go to it too.

Is it one scheme across England, Scotland, Wales and Northern Ireland?

Legally, no. There are three legally distinct schemes: one for England and Northern Ireland, one for Scotland and one for Wales. Scotland's scheme also launches in October 2027, alongside England and Northern Ireland.

In practice, you deal with one administrator and one registration and reporting system. The UK and devolved governments agreed that producers would register for all schemes through a single system.

Wales has one difference worth planning for now. Under transitional arrangements, glass bottles are in the Welsh scheme, but no deposit or scheme labelling applies to them until October 2031, and a 0p deposit applies to single-use glass in Wales until then. In February 2026, the UK government offered an exclusion from the UK Internal Market Act for single-use glass bottles in Wales. It is subject to conditions, including extending this glass transition to October 2031, and the UK government says it will be implemented in legislation at the earliest opportunity. PET and metal containers in Wales are due to start on 1 October 2027, the same date as the rest of the UK.

Which containers are in scope?

From 1 October 2027, a refundable 20p deposit applies to single-use drinks containers made from PET plastic, aluminium or steel, from 150ml to 3 litres. Exchange for Change has set a flat 20p deposit for every in-scope plastic and metal container, whatever its size.

Four details to check:

• Lids do not change the answer. A container with a lid made from another material is still in scope.
• HDPE is out. Containers made from HDPE, such as milk bottles, are not included.
• Multipacks are counted by container. A six pack carries six deposits of 20p.
• Glass is in scope in Wales only, at 0p until October 2031.

Who counts as a producer, and what about wholesalers?

You are a producer if you are the first to place in-scope drinks on the market: usually the brand owner, manufacturer or importer. GOV.UK also names businesses that fill and seal drinks containers to order. In England, Northern Ireland and Wales, producers must be established in the UK. Producers based in the Republic of Ireland that supply drinks to Northern Ireland should also register as producers.

Wholesalers do not register as wholesalers. They must still charge the deposit on every in-scope sale, to businesses as well as consumers, apart from registered low-volume lines in England and Northern Ireland and, on Exchange for Change's provisional transition guidance for England, Northern Ireland and Scotland, drinks filled before 1 October 2027. A wholesaler with own-label drinks may count as a producer and must register as one. A wholesaler that also sells direct to consumers may count as a groceries retailer, and may then need to register as a return point operator unless it applies for an exemption.

Hospitality has its own rules. In England and Northern Ireland, a business selling drinks for immediate consumption on the premises can choose not to charge the deposit at the point of sale. In Scotland, where consumption will definitely take place on the premises, the deposit should not be charged.

How does the 20p deposit move along the supply chain?

Every business in the chain charges the deposit to its buyer on deposit items: producers, importers, wholesalers and retailers. In England and Northern Ireland, registered low-volume lines are not deposit items and carry no deposit. On Exchange for Change's provisional transition guidance for England, Northern Ireland and Scotland, drinks filled before 1 October 2027 carry no deposit either. The money moves like this:

1. The producer charges 20p per container to the wholesaler or retailer it sells to.
2. The producer pays an amount equal to the deposit to Exchange for Change for each container it sells to the next business.
3. A wholesaler charges the deposit again when it sells on, whether the buyer is a business or a consumer.
4. The retailer pays the deposit when it buys the drinks and charges it to the shopper at the till.
5. The shopper gets the deposit back when the empty container is returned.

The deposit does not need to be charged on empty, unfilled containers. It applies to filled drinks.

Exchange for Change says the scheme is funded through producer fees, material revenues and unredeemed deposits.

How do producers register with Exchange for Change?

Registration runs in two phases. Phase 1 opened in September 2026 and asks only for basic information: company details, a primary contact, trading name, and business and mailing addresses. Exchange for Change asks businesses to complete it as soon as possible.

Phase 2 opens in January 2027 and asks for more detail about your role in the scheme. Exchange for Change has not published a closing date for Phase 2. From 1 October 2027, producers must be registered and must report the number of drinks they place on the market.

When you register your containers, Exchange for Change also asks for product specifications:

• container material composition
• label material and adhesive type
• cap or closure material
• container dimensions: height, width, weight and volume
• barcode number and format
• material barrier information, where it applies
• material colour

These specifications usually come from your packaging manufacturer. If your product data sits in several systems, now is a good time to agree which one holds the master record for each line.

What changes on the barcode and the pack?

Each in-scope product, apart from registered low-volume lines, needs a DRS-compliant barcode registered with Exchange for Change and the scheme logo. Exchange for Change is direct about the barcode: "All existing barcodes, including international barcodes, will need to be changed", so that each product can be identified, returned and processed within the scheme.

The registered barcode links the product to the scheme's list of registered items and confirms that the deposit and producer fee have been applied. Exchange for Change also says international barcodes, used across several markets rather than for the UK scheme alone, can be used but may carry an extra charge on top of the producer fee.

Timing matters here. Products with the new barcode and logo must not be sold to consumers before 1 October 2027. A producer that ships them to customers earlier must make it clear that they are DRS items to be supplied on or after 1 October 2027.

If the barcode on your pack changes, check every place your own systems use it: product master data, the product files you send to customers, and order, despatch and invoice lines. This is the product barcode, a different number from the SSCC on a pallet label, which identifies a pallet or case in transit.

What are the producer fees, and which lines are exempt?

The producer fee is 0p for the first 15 months, from October 2027 to December 2028. After that, the figures are only anticipated so far. Exchange for Change expects 0.6p per unit for aluminium and steel and 2.3p per unit for PET from January 2029, to be reconfirmed in May 2027.

Small lines have their own route. A producer can apply to Exchange for Change to register a product line as a low-volume line for a scheme year, if the line will not exceed 5,000 containers in that year. The first scheme year runs for 15 months, from 1 October 2027 to 31 December 2028, and its limit is 6,250 containers.

In England and Northern Ireland, a registered low-volume line is not a deposit item. It carries no deposit and no producer fee, and it must not carry the scheme logo or a scheme return code. It must still be registered with Exchange for Change and its volumes reported. Registration is line by line, so a producer can have some lines registered as low volume and others in the full scheme.

What happens to stock filled before 1 October 2027?

Exchange for Change has published transition rules, and it says this guidance is provisional and covers England, Northern Ireland and Scotland; Wales will follow. Final guidance comes after agreement with regulators.

On the provisional rules, drinks filled before 1 October 2027 are outside the scheme and can still be sold after launch. They carry no deposit, need no deposit logo and incur no producer fee. Exchange for Change encourages the industry to sell through that stock by April 2028, and says this is not a regulatory requirement.

Empty packaging is treated differently. On the same provisional guidance, packaging without a deposit logo and a scheme-registered barcode cannot be filled and placed on the market after launch unless it can be updated to meet scheme requirements. Packaging linked to an order placed before 1 October 2027 would normally fall within the scheme too: Exchange for Change is discussing possible flexibility for it with regulators, and any flexibility depends on their agreement.

Two lines of stock will therefore sit side by side for a while: older packs without the logo or registered barcode, and new packs with both. Your product data and stock records need to tell them apart.

What does the deposit change on invoices and VAT?

The deposit is charged per container on business sales of in-scope drinks, so your bills will need to carry it. Two kinds of line carry no deposit. In England and Northern Ireland, registered low-volume lines are not deposit items, so no deposit goes on their invoice lines. On Exchange for Change's provisional transition guidance for England, Northern Ireland and Scotland, drinks filled before 1 October 2027 carry no deposit either, so old-stock lines sold after launch need no deposit line.

VAT is still moving. Under current law, the deposit is left out of the value of each sale for VAT, and the manufacturer or importer that first supplies the drinks in the UK accounts for VAT on deposits that are never refunded. HMRC has proposed that the scheme administrator for each scheme accounts for that VAT instead, through Finance Bill 2026-27, from the start of the schemes. It is a proposal in draft legislation and is not yet law, so take advice before you set up VAT codes for the deposit.

Ireland shows what a deposit line can look like. In Ireland, where a scheme has run since February 2024, GS1 Ireland's guidance adds the deposit per unit on each invoice line it applies to and the deposit total in the summary. That is Ireland's approach; the UK specifications will come from the scheme and your trading partners.

If you trade by EDI, see which EDI messages may change for DRS and how the deposit can be carried in them.

What records must a producer keep?

The England and Northern Ireland regulations set out what a registered producer records for each drink supplied, and the record must be kept for seven years. It includes the container material and its capacity, and whether the drink is a registered low-volume product.

It also records where each drink is, or is intended to be, supplied for consumption: England, Northern Ireland or both. When a producer sells to another business without a condition on where the drinks go, it records where it reasonably expects them to be supplied. Sales into Scotland and Wales fall under their own schemes, even though reporting runs through one system.

What should drinks producers do first?

Start with the steps that have no reason to wait:

1. Register for Phase 1 with Exchange for Change, if you have not already.
2. List every in-scope line, with its material, size and the nations it is sold in. Flag any line that could stay within the low-volume limit, and decide whether to apply to register it.
3. Collect container specifications from your packaging suppliers, ready for product registration.
4. Plan the barcode and logo change so new packs reach consumers on or after 1 October 2027.
5. Plan the run-down of filled stock and old packaging against the provisional transition rules, including when to stop ordering packaging without the logo and registered barcode.
6. Check your billing and product data can carry a 20p deposit per container and a deposit total, and can leave it off lines that carry none: registered low-volume lines in England and Northern Ireland, and stock filled before 1 October 2027 under the provisional transition rules for England, Northern Ireland and Scotland.
7. Ask your customers for their DRS specifications for orders, product data and bills.
8. Take VAT advice while HMRC's proposal is still in draft.

For the wider picture of how food and drink suppliers trade with retailers, read our guide to EDI for food and beverage suppliers.

Where does Transalis fit in your preparation?

The deposit is a physical change on pack and a data change in the systems that handle those packs, from the order to the bill. The digital supply chain runs the physical supply chain, and DRS touches both.

Transalis is a managed outcomes provider for B2B integration, EDI and eInvoicing, connecting supply chains for 15,000+ organisations across 50+ countries. Our specialists can help identify which EDI messages may require changes for DRS, and whether your invoice and product data mappings can accommodate DRS requirements.

Book a complimentary, no-obligation DRS EDI Readiness Assessment for a clearer understanding of the EDI changes your business may need before October 2027.