Updated October 2026: since this post was first published, the operator has taken the trading name Exchange for Change, Wales has joined the October 2027 launch with glass in scope, a 20p deposit has been confirmed, and producer registration has opened. The post has been revised to reflect that.

The UK Deposit Return Scheme launches on 1 October 2027. England and Northern Ireland, Scotland and Wales each have their own scheme in law, but all four nations are run by the same Deposit Management Organisation, trading as Exchange for Change, with a single registration and reporting system for plastic and metal containers. A flat 20p deposit applies to every in-scope container.

The first phase of producer registration with Exchange for Change is open, collecting basic company details, and a second phase asking for role-specific information is expected from January 2027. The detailed rules for product registration have not yet been published, but products have to be registered before launch, so the data work this post describes needs to be done well before October 2027.

What data DRS will require

DRS will require producers and importers of in-scope drinks products to report specific data about each container placed on the UK market:

  • Container material: PET, aluminium, steel, or glass
  • Container type: bottle or can
  • Fill volume: the volume of liquid the container holds
  • Container weight: the weight of the empty container
  • Unit count: the number of individual containers placed on market per reporting period

All of this data must be traceable to individual SKUs. The deposit applies per unit, so aggregate figures at the product range level are not sufficient.

Which products are in scope

DRS applies to single-use drinks containers from 150ml to 3 litres, made wholly or mainly of PET plastic, steel or aluminium. That scope is the same in England, Northern Ireland and Scotland.

Wales is the exception. Its scheme includes glass from launch, under a transition period in which glass containers carry a zero deposit and are exempt from the labelling requirements until October 2031. A producer selling glass drinks containers into Wales therefore has glass container data to hold from day one, even though no deposit is charged on it yet.

Cartons, pouches, HDPE and other plastics, refillable containers, and anything outside the volume range are excluded. There is also a low-volume exemption for SKUs placed on the market in very small numbers, but exempt producers must still register, so the SKU-level data is needed to prove the exemption as well as to claim it.

The SKU-level challenge

Many businesses track packaging at the product range level, not the individual SKU level. A range of flavoured waters might share the same bottle specification, so the packaging data is held once for the range rather than per SKU.

DRS requires SKU-level container data because the deposit applies to each individual unit placed on market. If your packaging database is at a higher level of aggregation, you will need to disaggregate before DRS launches. This is not technically difficult, but it takes time - especially if you have thousands of SKUs and the bottle specification varies by variant (different sizes, different closure types).

Barcodes are packaging data too

The requirement that catches producers out is not weight or volume. It is identification. A return point has to decide, in the moment a container is inserted, whether a deposit is payable on it. That decision is made from the barcode, which means every in-scope container needs a barcode, registered on the Exchange for Change article list, before it can be sold.

This has two consequences that are easy to miss. The first is that a barcode shared across markets is a problem: if the same GTIN is used on stock sold inside and outside the scheme, containers that never carried a deposit can be returned for one. Exchange for Change's material specifications require every in-scope product to carry a new barcode, so this is a change to every affected SKU rather than a relabelling exercise for some.

The second is that your barcode data has to be tied to the same SKU record as the container specification. A barcode registered against a product, with the container attributes held separately at range level, cannot answer the question the scheme is actually asking, which is what this specific container is made of and how much deposit it carries.

Artwork lead times

In-scope containers have to carry the Exchange for Change scheme mark, which is mandatory from October 2027, and in most cases the deposit is communicated on pack. That is an artwork change on every affected SKU, and artwork changes run on the slowest clock in the business: design, brand approval, repro, plate or cylinder costs, and then the existing stock of printed material to run down.

The data work matters here because it defines the scope of the artwork work. Until you can list which SKUs are in scope, with their container material and volume, nobody can size the design programme or sequence it against print runs that are already committed.

Unit counts are harder than they look

Container type, material and weight are static attributes. Unit counts are not. They are a flow, reported per period, and they are the figure the deposit liability is calculated from, so they carry more financial risk than anything else in the return.

The common problems are structural rather than technical:

  • Sales data is held in cases or pallets, not individual containers, so a units-per-case factor has to exist and be correct for every SKU
  • Returns, wastage and samples reduce the number actually placed on market, and are usually recorded in a different system from sales
  • Multipacks have to be counted as their constituent containers, because the deposit applies per container
  • Exports and sales into markets outside the scheme have to be excluded, which requires the destination to be recorded at line level
  • Own-label stock supplied to a retailer may make the retailer the obligated producer, not you, so the same units must not be reported twice

The reconciliation nobody budgets for

Under a deposit scheme, money moves on the strength of your data. You pay a deposit on every container you place on the market and recover it through the supply chain, while the scheme administrator pays out against containers actually returned. The gap between the two is real cash, and the only way to defend your side of it is a unit count you can trace back to source records.

This is why the SKU-level work cannot wait for reporting to start. A report format can be implemented in weeks. A packaging database that has never held container data at unit level, reconciled against dispatch, takes considerably longer, and it is the part that cannot be rushed at the end.

The integration with EPR

If you are already reporting packaging data for EPR declarations, much of the DRS data is a subset of what you already collect. The container material, weight, and type are already in your EPR data. The additions for DRS are container volume, unit counts per period, and in-scope flagging.

Businesses that treat EPR and DRS as separate data exercises will duplicate effort. The container material you report to the RPD for pEPR is the same material you will report to the DMO for DRS. The weight is the same weight. The only new data points are volume and unit counts, which are straightforward to add to an existing packaging data structure.

The two schemes also hand over at launch. Producers keep their existing packaging waste obligations on in-scope drinks containers until DRS goes live in October 2027, after which DRS producer fees apply. Exchange for Change consulted on those fees in July 2026. The date a container moves from one regime to the other is a data change on every in-scope SKU, and it needs to be recorded as one.

What to do now

First, ensure your packaging database captures container type, material, volume, and weight at SKU level. If you already manage this data for EPR, confirm that it is at the right granularity.

Second, flag which SKUs are in scope for DRS in each nation - including glass for Wales - and which qualify for the low-volume exemption. This gives you the working set for data completeness.

Third, register with Exchange for Change and build your article list, with a barcode tied to each in-scope SKU, well before launch rather than waiting for the second registration phase.

Fourth, start collecting unit-count data per reporting period if you do not already. This is typically available from sales or dispatch data and can be linked to your SKU records.

Merchant Packaging does not produce DRS reports. Much of the data DRS draws on - container material, weight and type - is already held for your EPR declarations and PPWR compliance, and can be exported as CSV or Excel to prepare your DRS submissions.