For businesses across the drinks supply chain (producers, importers, retailers), the Exchange for Change scheme will bring new responsibilities around registration, labelling, deposits, reporting and the collection of empty containers.
The scheme for England and Northern Ireland is established under the Deposit Scheme for Drinks Containers (England and Northern Ireland) Regulations 2025 and is scheduled to go live on 1 October 2027.
The Deposit Return Scheme (DRS) will require consumers to pay a refundable deposit when purchasing single-use drink containers. The deposit can be reclaimed by returning empty containers to designated collection points.
This circular economy initiative aims to boost recycling rates, reduce litter and ensure materials are reused in new packaging.
Which Containers Are Included?
The DRS will apply to certain single-use drinks containers made from polyethylene terephthalate (PET) plastic, aluminium or steel, with capacities between 150 millilitres and 3 litres.
Containers with lids made from other materials are also included.
However, certain drinks containers are excluded:
- HDPE containers, including standard milk bottles
- Reusable containers
- Containers used for liquid medicines
- Containers used for certain flavour enhancers or sweeteners added to drinks
DAERA stated that containers excluded from the scheme should continue to be recycled in accordance with current practices.
Producer Obligations & Cross-Border Rules
The new requirements will affect manufacturers, brand owners, importers and businesses that fill and seal drinks containers to order.
A business can have producer responsibilities if it:
- manufactures an in-scope drink, typically as the brand owner
- imports drinks into the UK
- fills and seals drinks containers to order (includes hospitality operations)
Producers in the Republic of Ireland that supply drinks to Northern Ireland must register with the scheme and meet all producer obligations.
Producer fees will be based on the number of containers placed on the market.
However, if a product line contains fewer than 5,000 units per year, it is classed as a low-volume product. These products are not required to carry scheme labelling, have deposits or incur producer fees.
They will still need to register with the scheme operator and report the number of containers placed on the market.
Return Point Host Duties
Retailers selling drinks included in the DRS will need to:
- pay a deposit when purchasing in-scope drinks from producers or wholesalers
- charge the deposit to consumers at the point of sale
- register with the scheme operator
- provide refunds upon return of eligible empty containers
Retailers will generally be required to operate a return point. Return points can be operated manually or via automated reverse vending machines.
However, not every retailer needs to host a return point if they meet the exemption criteria.
Retailers in urban areas with less than 100 square metres of retail space; and or are located near another return point or the location, layout, size, design or construction of their premises makes operating a return point impractical.
Hospitality Opt-Out Provision
Pubs, cafes and restaurants selling drinks for immediate consumption on-site can opt out of charging deposits at the till.
Instead, they will be expected to collect and store the empty containers for collection by the scheme operator.
Clear information must be displayed to customers to leave empty containers behind.
Businesses should use the period before October 2027 to understand which products and operations will be affected and to follow the detailed guidance issued by Exchange for Change, DAERA and the UK Government as implementation progresses.
