Reed Smith In-depth

Key takeaways

  • Two new deposit return schemes (DRSs) will go live from 1 October 2027 in England and Northern Ireland, and separately in Scotland.
  • The schemes will require drinks suppliers to add a deposit to the price of their products and larger groceries retailers to host return points, where consumers can obtain a refund when containers are returned.
  • The DRSs are intended to drive recycling rates for plastic (PET), aluminium and steel drinks containers up to 90% by the end of 2030. Glass is not included.

The English/NI scheme in a nutshell

  1. From 1 October 2027, the price of drinks sold in England and Northern Ireland (NI) in single-use closed containers made of plastic (PET), aluminium or steel, with a volume of between 150ml and 3 litres, will need to include a deposit.
  2. Consumers will be entitled to obtain a refund of the deposit paid when they return the drinks containers to one of a network of return points.
  3. Numerous retailers will be obliged to set up return points on their premises, but will be reimbursed a handling fee to cover their costs and compensate for the lost retail space.
  4. Eligible drinks containers will be marked with a new logo and include prescribed information in an electronic barcode or QR code, which will identify the relevant drinks manufacturer.
  5. The new Deposit Management Organisation (DMO), which will shortly be appointed by the government, will set the amount of deposit that must be charged on containers, establish the annual registration fees payable to it by drinks manufacturers and reimburse retailers the deposit on containers that are returned to the DMO.
  6. Upon collection from return points, the containers are to be delivered to recycling facilities for materials recovery, on behalf of the DMO.
  7. The DMO will be responsible for ensuring that collection targets are met and will be subject to regulatory oversight.
  8. Drinks manufacturers must register with the DMO and will be given first right of refusal to buy back a proportion of the recovered materials from the DMO at a market rate.

The Scottish scheme is broadly similar.