Done together, you redesign once, correctly, and you’re compliant with both.

This guide covers exactly how to achieve that.

Why These Two Changes Converge So Completely

GS1 Sunrise 2027 and the UK Deposit Return Scheme were developed entirely independently — different regulatory bodies, different industry drivers, different technical specifications. But for drinks manufacturers selling into UK retail, they land on the same label, in the same year.

GS1 Sunrise 2027: By end of 2027, retail POS systems must be able to scan both traditional 1D barcodes and 2D codes (Data Matrix or GS1 QR) at checkout. The transition target means your EAN-13 stays, and you add a GS1 2D code next to it — positioned within 50mm of the EAN/UPC centre, meeting defined print quality and size specifications.

Deposit Return Scheme: From 1 October 2027, every in-scope PET bottle and metal can must carry the Exchange for Change scheme logo and a machine-readable identifier (barcode or QR code) that reverse vending machines can scan to validate returns. Both elements are mandatory on every individual container. Neither alone is sufficient.

The overlap zone: Both changes require adding barcode-format elements to an already crowded label. Both have the same effective planning deadline. Both will affect every drinks brand selling into UK retail. And both create identical print quality and durability requirements for the label itself.

What a Fully Compliant 2027 Drinks Label Must Carry

A drinks container that is fully compliant with both sets of requirements from October 2027 must include all of the following:

Existing required elements (unchanged):

• EAN-13 or UPC barcode
• Brand identity, product name, variant
• Volume declaration
• Ingredients and nutritional information
• Country of origin
• Allergen information (where applicable)
• Alcohol by volume (where applicable)
• Recycling information and On-Pack Recycling Label (OPRL) markings
• Any applicable regulatory icons or marks

New elements required by GS1 Sunrise 2027:

• GS1 2D barcode (Data Matrix or GS1 QR Code) encoding GTIN plus any applicable Application Identifiers (batch, expiry date, serial number)
• Positioned within 50mm radius of the EAN/UPC centre
• Sized to meet minimum module specifications for your print process
• Surrounded by compliant quiet zones on all sides

New elements required by the Deposit Return Scheme:

• Exchange for Change scheme logo (approved regulatory mark, portrait or landscape variant as appropriate to container shape)
• Machine-readable DRS identifier (barcode or QR code), scannable by reverse vending machines after the container has been used, crushed, and handled
• Both elements on every individual container, including those sold inside multipacks

On a 330ml can or a small PET bottle, fitting all of this cleanly is a genuine design challenge. It requires a complete label layout rethink — not an incremental amend.

The Technical Specification Requirements That Overlap

Here’s where the good news starts. Because both changes involve adding 2D/barcode elements to the same label, several technical requirements are shared — which means you only need to solve them once.

Print resolution and contrast: GS1 Sunrise 2D codes require higher contrast and finer module precision than 1D barcodes. Reverse vending machine scanning of DRS identifiers requires scannable contrast on crushed, wet, handled containers. Both requirements point to the same solution: higher-specification label materials, more consistent print processes, and formal barcode verification testing. Assess this once, specify it once.

Label substrate durability: GS1 2D codes on dynamic labels (encoding variable batch or expiry data) need to be printed on materials that hold fine detail. DRS labels need to survive the full consumer lifecycle — refrigeration, condensation, handling, transport in a bag, insertion into an RVM. Film-based substrates with moisture resistance and dimensional stability satisfy both requirements simultaneously. This substrate decision feeds both compliance needs.

Quiet zones around all code elements: Both the GS1 2D code and the DRS machine-readable identifier require defined blank margins. A label redesign that maps all code elements together can allocate quiet zones efficiently across the available real estate. Doing this in two separate amend rounds risks creating conflicting zone requirements that only become apparent when both elements are on the label at the same time.

Print verification testing: GS1 recommends verifying 2D codes against ISO/IEC 15415 quality standards. The DMO expects producers to test DRS labels against prototype RVM equipment during 2026. Both validation steps can be run on the same test batch from a single print run — saving significant time and cost compared to two separate validation exercises.

The Placement Puzzle: Fitting Everything on One Label

The practical challenge is space. Here’s how to think about the layout systematically.

Zone 1 — The barcode cluster: The EAN-13 and the GS1 2D code must sit within 50mm of each other. The DRS machine-readable identifier needs to be accessible on a crushed container. In practice, grouping all three barcode-format elements together in one dedicated zone of the label is the most efficient approach — it consolidates the quiet zone requirements and makes the scanning target predictable for both POS scanners and RVMs.

Zone 2 — The scheme logo: The Exchange for Change logo must be prominent and immediately recognisable by consumers and retail staff. It needs its own dedicated space, clear of the barcode cluster, and sized according to the DMO’s published regulatory requirements. Portrait or landscape variants are available to suit different container shapes.

Zone 3 — Mandatory regulatory text: Allergen information, nutritional data, country of origin, alcohol percentage, and recycling marks all have fixed legal requirements for legibility and positioning. These cannot be reduced or moved arbitrarily.

Zone 4 — Brand identity: Product name, brand, variant description, and marketing claims. These are the elements that typically shrink under regulatory pressure, but need enough real estate to maintain shelf recognition.

The order of planning is important. Don’t start from the brand identity and try to fit compliance around it. Start from all mandatory elements — including both sets of 2027 requirements — map the minimum space each needs, and then allocate the remaining real estate to brand.

For small containers (330ml cans, 250ml bottles), this exercise will almost certainly reveal that a physical label size increase or a move to a wraparound format is necessary to accommodate all elements legibly. The time to find this out is during artwork planning in 2026 — not during a rushed amend in Q3 2027.

The Artwork Freeze Reality Check

Both sets of requirements share the same critical constraint: containers going to market in late 2026 will still be in circulation when the scheme goes live in October 2027.

This means the artwork freeze for 2027-compliant labels is not “end of 2027” — it’s mid-2026 at the latest for products with standard stock turn, and potentially earlier for products with slower distribution cycles or large pre-print volumes.

The practical planning sequence:

Now — March/April 2026: Finalise your understanding of all mandatory elements for both changes. The Exchange for Change logo specifications have now been published. GS1 Sunrise placement and sizing specifications are already available from GS1 UK. No further guidance is needed to begin artwork planning.

Q2 2026: Artwork redesign and internal approval. Get both changes into the same artwork brief. Brief your label supplier on material specification, print resolution, and verification requirements.

Q3 2026: DRS producer registration opens. Label redesigns should be production-ready before this point. Exchange for Change expects producers to have compliant labels in production during this period, not at approval stage.

2026 generally: Label validation — test 2D code quality against GS1 verification standards, and test DRS label readability against prototype RVM equipment. Both tests can be run on the same batch.

October 2027: Go-live. Containers already in the supply chain must be compliant.

The One Decision That Changes Everything: Static vs Dynamic 2D

The biggest technical decision in the GS1 Sunrise element of this redesign is whether to use a static or dynamic 2D code. This choice also has knock-on implications for the DRS machine-readable identifier.

Static 2D code: Fixed data — the same code on every label in the run, just as your EAN-13 is the same on every label. This requires no change to your label printing process beyond artwork. It does not unlock the supply chain benefits of 2D (expiry tracking, batch-level recall, serialisation), but it is Sunrise compliant and requires the least change to your operations.

Dynamic 2D code: Variable data — batch number, expiry date, and/or serial number encoded at print time, changing with every production run. This unlocks the full supply chain value of 2D codes. It is also a requirement for any producer who wants to use GS1 Digital Link to connect their product to a digital product page or comply with EU Digital Product Passport requirements. It requires a shift to on-demand digital label printing rather than pre-printed label rolls.

For the DRS machine-readable identifier, the DMO’s detailed guidance (expected Q2 2026) will confirm whether serialisation or unique per-unit identifiers are required for fraud prevention purposes. If they are, dynamic printing for the DRS element will be mandatory regardless of your GS1 Sunrise choice. This is a strong reason to move to dynamic printing across both elements simultaneously rather than starting with static and having to revisit the decision.

What to Do Now

Step 1: Confirm scope. Which of your products are in-scope for DRS? Which will also need GS1 Sunrise 2D codes for retail distribution? Prioritise the intersection.

Step 2: Pull your current label artwork files. Look at available space across your container formats. Can the existing layout accommodate a barcode cluster zone, an Exchange for Change logo, and all existing mandatory content? If not, what changes are needed?

Step 3: Speak to your label supplier about material specification. Film-based substrates with higher moisture resistance and 2D print quality are likely to be required. Your current material may not perform adequately for either change in isolation — and certainly not for both together.

Step 4: Decide now whether you’re going static or dynamic 2D. This determines your printing process and workflow. If dynamic, begin the conversation about on-demand digital label printing capability.

Step 5: Download the PID 2027 Label Compliance Checklist — a practical walkthrough of all requirements for both changes. It will tell you exactly what your artwork needs to include and what technical specifications to brief your supplier on. Available free at pid-labelling.co.uk.