Notably, the new guidance confirms that high-density polyethylene (HDPE) drink containers will be excluded from the scheme and that pubs and restaurants will be able to opt out of charging their customers a deposit.
Although the scheme will only be launched on 1 October 2027, the legislation came into force today (27 January 2025) after passing a parliamentary vote last week.
The new legislation will allow for the creation of a scheme administrator – known as the Deposit Management Organisation (DMO) – in April 2025. The DMO will be responsible for managing the scheme, including setting the deposit amount, meeting collection targets and providing future guidance to consumers and businesses.
What will be included in the DRS?
The new guidance confirmed that the DRS will apply to all drinks containers that are “likely to be used only once or for a short period of time” and have a capacity of between 150 millilitres and three litres. The containers must be made wholly or mainly from aluminium or steel, or polyethylene terephthalate (PET) plastic. Containers with a lid made from other materials are still included.
Drinks containers made from high-density polyethylene (HDPE) will be excluded, for example milk bottles. A 2019 consultation on the DRS found that HDPE does not make a significant contribution to litter in the environment.
Items that contain liquid medicines, flavour enhancers or sweeteners will also be excluded. This includes products such as cough syrup, flavoured syrups and hot sauce.
“Low-volume products” will also be excluded from the scheme. This is defined as products with product lines with fewer than 5,000 units per year. These producers will still need to register with the DMO.
Everyone in the drinks supply chain must charge the deposit to their buyers when they sell filled drinks versions of containers included in the scheme. This extends to drink producers, importers, wholesalers and retailers. The containers must carry the scheme labelling.
The items included in the DRS will be excluded from extended producer responsibility for packaging (pEPR).
What must producers do to prepare for the scheme?
If you are an obligated producer, you have until 1 October 2027 to:
- Register with the deposit management organisation – your producer fee will be based on the number of containers you place on the market
- Apply the deposit to all containers included in the scheme
- Pay the deposits collected to the deposit management organisation when containers are sold to the next business in the supply chain
- Comply with scheme labelling requirements
- Report the number of drinks placed on the market
The DMO will provide additional information on compliance one it has been set up in April this year.
Return points
All supermarkets, grocery stores, convenience stores and newsagents which sell drinks that are included in the scheme must provide returns points.
The return point will either be manual or automated using a reverse vending machine. 
These retailers must also:
- Register with the deposit management organisation
- Pay the deposit back to consumers at the point of return (via voucher, card or cash)
- Store returned containers for collection
- Display information so customers know how the scheme works
Retailers in urban areas are exempt from hosting a return point if they have a retail space of less than 100m2.
Businesses that are not automatically exempt you can apply for an exemption if either:
- The business is close to another return point
- It is not possible (or easy) to host a return point due to the location, layout, size, design or construction of the premises
Businesses can register with the DMO to provide online takeback services. This will allow business to recover empty containers at the point of delivery to refund the deposit.
Businesses which sell drinks containers to be consumed on premises like pubs and cafes can choose not to pass the deposit onto the consumer at the point of sale. If opting for this, the businesses should store these containers to be collected by the DMO so the deposit can be refunded.
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