The Scottish Deposit and Return Scheme (DRS) has been delayed for what is expected to be the final time. It was due to come fully in force on 1 October 2025 however, in order to align it with similar schemes coming into force in England and Northern Ireland on 1 October 2027, the Scottish DRS will now come into force on the same 2027 date.
Since the Deposit and Return Scheme for Scotland Regulations SSI 2020/154 were first published in May 2020, it has been delayed four times in total due to various reasons. This time, the delay was necessary in order to meet a commitment to work alongside other UK devolved administrations to introduce a UK-wide DRS by October 2027. However, Wales subsequently decided it would not align with the rest of the UK; the Scottish Government decided to continue with a three-nation DRS instead.
Alongside the date change, the Deposit and Return Scheme for Scotland Amendment Regulations SSI 2025/188 also introduce several other changes to the scheme. The remainder of this guide sets out what has changed in more detail.
What is a DRS?
The concept of a DRS is quite simple really. When someone buys a drink contained in single-use PET plastic, steel or aluminium that holds between 150ml and three litres of liquid, they will be charged a deposit. If they return that packaging to a designated return point (once the drink is finished) then that deposit will be returned to the consumer.
It is designed to be a financial incentive to encourage consumers to return their used drinks containers so that they can be recycled.
Whilst the concept is simple, the implementation of such a scheme requires careful control, which is what the Deposit and Return Scheme for Scotland Regulations SSI 2020/154 try to do.
Scope
The packaging that is in-scope of the Scottish DRS has been changed. As a result:
Any drinks containers that fall outside of the scope will instead be subject to the Extended Producer Responsibility for packaging under the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations SI 2024/1332.
Logos
Any drinks container that will be subject to the DRS will have to carry the scheme logo, a scheme multipack logo (if any) and a scheme return code. All of these will be issued by the scheme administrator.
Low volume drink products
Low volume drink products are subject to an exemption from the DRS. The previous exemption applied if the producer had product lines of less than 5,000 units placed on the market in Scotland.
This has now been changed to specify a threshold of 5,000 units across the whole of the UK.
Producers of such products still have to register with the scheme administrator if they want to market, offer for sale or sell the product, but the products themselves will remain exempt if the threshold levels are not breached.
Producer registration and obligations
Following the amendments, producers are now required to register with the scheme administrator designated under the Deposit and Return Scheme for Scotland (Designation of Scheme Administrator) Order SSI 2025/189 instead of registering with the Scottish Environment Protection Agency (SEPA). Registration must be completed before 1 October 2027.
The application for registration now requires the producer to give information of the anticipated number of scheme articles to be placed on the marker in Scotland in any relevant year. This must be accompanied by details of materials used in the packaging, the sizes of the packaging and the size of any multipacks being made available.
Once registered, producers of scheme articles are subject to different obligations, which have been altered by these amendments. They now obligate the producer to;
However, producers are no longer required to pay an annual registration payment.
Return points and groceries retailers
The amendments have introduced the term "groceries retailer", which is defined as a supermarket of any size, grocery store, a convenience store or a newsagent which sells groceries (such as food, scheme articles and other drinks, pet food, cleaning products and toiletries and household goods).
It is specifically these groceries retailers that are now obligated to operate a DRS return point if they market, offer for sale or sell scheme articles. However, there are exemptions to this. For instance, if the retail space is in an urban area and has a floor space of less than 100m2 then a return point doesn't have to be provided. They also don't have to be provided if the:
Grocery retailers that have to operate a return point must register with the scheme administrator and clearly display information on their premises about how a deposit on a drinks container can be redeemed. Other groceries retails that are exempt from operating a return point must also display information about redeeming a deposit on qualifying drinks marketed, offered for sale or sold either on its premises, where the drink is displayed for sale (in the case of distance retail selling) or on a vending machine.
Under the previous requirements, return points were obligated to accept the return of empty scheme packaging. This has been extended so that they must also accept returns of equivalent drinks containers that are subject to the DRS established in England and Northern Ireland. However, an exemption has been granted to any return point operator which does not or would not sell alcohol because of faith or belief. In such cases, the return point operator can refuse to accept containers of alcoholic drinks.
In addition, voluntary return point operators are now required to register with the scheme administrator, not the Scottish Ministers.
Takeback services
Before these changes, large retailers were required to offer takeback services to consumers who had purchased scheme articles online. This has now been changed so that the provision of takeback services is entirely voluntary.
As such, if anyone wants to collect empty scheme packaging from consumers, refund their deposits and return that material to the scheme administrator, they can register with the scheme administrator as a takeback service. However, deposits don't have to be refunded if the packaging collected by the takeback service is:
What happens next?
Anyone who now qualifies as a groceries retailer, or who will operate a return point or a takeback service, can begin to apply for registration. Producers can continue to apply for registration This must be done before 1 October 2027 and all applications for registration must be made to the scheme administrator.
