Deposit Return Scheme: update on transition arrangements
Exchange for Change is providing an update on how producers, retailers, wholesalers and hospitality operators should manage the transition from non-DRS product to DRS-compliant product around the launch of the scheme.
This update covers PET and metal containers in England, Northern Ireland and Scotland only. Arrangements for Wales will follow.
The Deposit Return Scheme will go live on 1st October 2027 and at the point of implementation there will be a mix of non-DRS and DRS-compliant products on the market. To minimise disruption for producers and reduce the risk of product and raw material waste we have undertaken extensive engagement with industry and worked closely with regulators to agree a flexible transition period for products.
This update refers to the following areas:
Filled containers made before 1 October 2027
These products are outside the scope of DRS and can still be sold after 1 October 2027. They do not need to be registered with Exchange for Change, carry a deposit logo, or incur a producer fee or deposit. Exchange for Change encourages industry to sell through this stock by April 2028 to support a smooth transition, and in the vast majority of cases this will happen much faster, but this is not a regulatory requirement.
Unfilled containers linked to orders placed before 1 October 2027
These containers would normally fall within scope. However, Exchange for Change is discussing possible flexibility with regulators. This would allow non-DRS-compliant packaging to be filled and sold after launch, but only if they are associated with orders placed before 1 October 2027. Talks are ongoing, and any flexibility depends on regulators’ agreement.
Unfilled packaging not linked to existing orders
Packaging that does not comply with DRS and is not associated with an order made prior to 1 October cannot subsequently be filled with product and placed onto the market. Non-compliant means packaging without a deposit logo and a scheme-registered barcode. No flexibility applies to this packaging unless it can be updated to meet scheme requirements.
Further details of the transition arrangements will be published in due course and producers with any questions should email enquiries@exchangeforchange.co.uk
If you are a Producer or Return Point Operator*, it’s important that you register your business with Exchange for Change. Don’t worry, we’ve made it quick and easy to do. Join 270,000+ other businesses creating a cleaner country for all of us.
*most supermarkets, grocery stores, convenience stores, or newsagents