UK Deposit Return Scheme 2027: Implementation Guide
Understanding the UK Deposit Return Scheme is one thing. Getting your labels compliant — registered, specified, printed, tested, and in production before the deadline — takes a disciplined process that needs to start in 2026. This guide walks through every step, in sequence, from scope assessment to production sign-off.
If you haven’t read our DRS overview yet, start there. This guide assumes you understand what the scheme requires and are ready to implement it.
Step 1: Confirm Which of Your Products Are In Scope
Before any label work begins, you need a definitive list of in-scope products. The DRS applies to single-use drinks containers made from PET plastic or aluminium and steel, with a volume between 150ml and 3 litres. Work through your range and confirm each container against those three criteria: material, category (drinks), and volume.
In scope:
- PET plastic bottles, 150ml–3 litres, containing any drinks
- Aluminium and steel cans, 150ml–3 litres, containing any drinks
Out of scope for England, Northern Ireland, and Scotland:
- Glass containers (England, NI, and Scotland have excluded glass at launch)
- HDPE milk bottles
- Containers below 150ml or above 3 litres
- Liquid medicines and certain specialist categories
Wales is different. The Welsh scheme includes glass containers in the same volume range. If you sell into Welsh retail — supermarkets, off-licences, food service — and have glass-packaged drinks in scope, those containers need DRS labelling even though the same product sold in England does not. Track this separately.
Create a definitive scope register: every SKU, every container material, every volume, and which markets it sells into. This is your compliance baseline for everything that follows.
Step 2: Check Whether You Qualify for the Low-Volume Exemption
Before committing to a full label redesign programme across all in-scope products, check your annual volumes at SKU level.
Producers placing fewer than 5,000 units per SKU per year are exempt from both the labelling requirements and the producer fee obligations for those specific product lines. The exemption applies per-SKU, not across your total range — a product with 4,800 units annually is exempt even if other products in your range are well above the threshold.
Important: the exemption from labelling does not mean you can ignore the scheme entirely. You are still required to register with Exchange for Change and report your volumes. Non-registration is not an option regardless of your volume position.
For small craft brewers, independent soft drinks producers, and artisan brands with limited retail distribution, the low-volume exemption may cover a meaningful part of your product range. Identify those SKUs now, set them aside from your redesign programme, and proceed with the remainder.
Step 3: Obtain the Exchange for Change Logo and Regulatory Specifications
The Exchange for Change scheme logo is the first of the two mandatory label elements. It is a regulated mark — you cannot use an approximation, a stylistic interpretation, or a substitute. The approved artwork must be obtained from Exchange for Change directly via exchangeforchange.co.uk.
The logo regulatory requirements were published in early 2026. These set out minimum size requirements, approved colour variants, and placement rules. Read them carefully before briefing artwork — specific constraints apply to placement relative to the container’s return face, and to size scaling relative to label dimensions.
Portrait and landscape variants are available. The right choice depends on your container shape and available label space. On a tall PET bottle, portrait typically works better. On a short can, landscape may suit the label proportions better. Confirm this with your label supplier when you map the layout.
Download the official logo files and keep them with your compliance documentation. Do not allow artwork to regenerate or redraw the logo — use only the official approved files.
Step 4: Confirm the Machine-Readable Identifier Format
The second mandatory label element is a barcode or QR code that reverse vending machines can scan. The RVM hardware specification was published in October 2025. The software specification — which will confirm exactly what data needs to be encoded and in what format — is expected in Summer 2026.
At the time of writing, the recommended approach is to plan your label layout for a GS1-format barcode or QR code, using your existing GTIN as the core identifier. This aligns the DRS machine-readable element with your GS1 Sunrise 2D code requirements, potentially allowing a single 2D symbol to serve both purposes — reducing the number of distinct code elements that need to fit on the label.
When the DMO software specification is published in 2026, verify your planned format against it before final artwork sign-off. The specification may require additional data elements — batch identifiers, scheme-specific prefixes — that need to be incorporated.
If you haven’t already confirmed your GS1 company prefix is current, do it now. The machine-readable DRS identifier almost certainly builds on the GS1 GTIN system.
Step 5: Map Your Label Layout — All Elements Together
This is where the practical challenge becomes visible. A fully compliant 2027 label for an in-scope drinks container must accommodate:
- Existing EAN-13 barcode
- GS1 2D code (Sunrise 2027) within 50mm of EAN-13 centre
- Exchange for Change scheme logo
- DRS machine-readable identifier
- All existing mandatory content: allergens, nutritional data, volume, country of origin, ABV (if applicable), recycling marks, ingredients
On a 330ml can, that’s a lot of elements on a small surface. Don’t start from your existing artwork and try to squeeze everything in — that approach produces crowded layouts where quiet zones are violated and logos are undersized.
Start from scratch. List every mandatory element. Define the minimum space each element requires — including quiet zones around all code elements. Map those spaces against your available label area. What’s left is available for brand identity and marketing claims.
If mandatory elements don’t fit at compliant sizes, the answer is a layout reconfiguration, not reducing elements below their minimum specifications. For very small containers, this process will reveal that a larger label, a wraparound format, or a repositioned label zone is necessary. Better to find this out in early 2026 than during a rushed Q3 2027 amend.
Step 6: Assess Your Label Substrate for DRS Durability
Most existing label materials will not perform adequately for DRS compliance. This is the technical requirement that catches brands off-guard.
A DRS label must remain readable by an RVM on a container that has been filled, chilled, sweated with condensation, drunk, crushed by hand, carried in a bag, and fed into a machine. The machine reads the barcode in a fraction of a second and must return a valid result. Paper labels that have absorbed moisture, partially delaminated, or torn during crushing will fail.
What your DRS label substrate needs to do:
Resist moisture — PET bottles and cans are routinely chilled and will attract condensation throughout their lifecycle. A label that softens, wrinkles, or delaminates in wet conditions will produce failing results at the RVM.
Survive deformation — PET bottles are typically returned crushed. The label must remain readable on a deformed surface. Film substrates with higher dimensional stability hold barcodes readable after deformation better than paper.
Maintain adhesion — the label must stay on the container through the complete consumer lifecycle. Adhesive failure before the return point produces a non-refundable container and a frustrated consumer.
Hold barcode quality — the machine-readable identifier needs to scan reliably under RVM lighting conditions after the label has been subject to all of the above.
In most cases, this means a move to film-based self-adhesive materials — PP, PE, or PET film with appropriate adhesive systems. Positive ID Labels can specify the right material for your container type, your fill environment, and your distribution chain. Don’t assume your current material will pass until you’ve tested it.
Step 7: Validate Labels Against RVM Equipment During 2026
Exchange for Change has made clear that producers should test their DRS labels against prototype RVM equipment during 2026, before committing to full production volumes. This is not optional for any producer serious about being compliant at launch.
RVM validation testing checks whether your machine-readable identifier is readable by actual reverse vending equipment under real-world conditions — including on crushed and wet containers. A label that passes standard barcode verification (ISO/IEC 15415 or equivalent) may still fail on an RVM due to the way the machine presents the container, the lighting conditions, or the specific scanning technology used.
The practical sequence: get test prints produced on your intended substrate and print specification, age and stress the samples (wet them, crush them, handle them), and submit for RVM validation. Identify any failures and iterate before committing to production runs.
If you’re also running GS1 2D code verification for Sunrise compliance, run both tests on the same test batch. This saves significant time and cost compared to two separate test and iteration cycles.
Positive ID Labels can help co-ordinate test batches for RVM validation. Ask us when you’re approaching print approval stage.
Step 8: Register with Exchange for Change — Q3 2026
Producer registration with Exchange for Change opens in Q3 2026. Missing this window has direct consequences — without registration, you cannot legally place DRS-labelled containers on the market, and Exchange for Change needs your registration to process returns attributable to your products.
Prepare your registration data in advance. You’ll need:
- Your legal entity details and company registration number
- A register of all in-scope products with GTINs and annual volume estimates
- Confirmation of which products qualify for the low-volume exemption
- Your production volume data by SKU for fee calculation purposes
Registration should be a brief administrative exercise if your data is prepared. It becomes a scramble if you’re trying to assemble product registers and volume data at the same time you’re completing artwork and dealing with production lead times.
Note the deposit value and producer fee announcements, expected Q2 2026. These affect your pricing and commercial planning and should be factored into your cost models as soon as they’re published.
Step 9: Attend the DRS Conference — 30 April 2026, London
The Exchange for Change DRS Conference on 30 April 2026 in London is the principal industry event for producers, retailers, and brand owners ahead of the October 2027 launch. This is where detailed guidance, implementation updates, and RVM specification progress will be shared.
Attending — or having someone from your team attend — is strongly recommended. The conference typically covers issues not yet addressed in published guidance, provides the opportunity to ask direct questions of the DMO, and gives advance visibility of any specification changes before they’re formally published.
Book early. These events fill quickly once registration opens.
Step 10: Final Artwork Sign-Off With Full Compliance Documentation
Before any production run, your compliance documentation should confirm:
- Exchange for Change logo is the approved official artwork, correctly sized and positioned
- Machine-readable identifier format confirmed against DMO software specification
- Both elements present on every individual container (including inside multipacks)
- Label substrate confirmed as film-based and appropriate for wet/crush performance
- RVM validation testing completed and passed
- GS1 2D code (if applicable) verified to ISO/IEC 15415 Grade A or B
- Quiet zones compliant around all code elements
- Written confirmation from label supplier that specification meets DRS requirements
Keep this documentation. If a regulatory query or enforcement action arises, your ability to demonstrate that you followed a documented compliance process is your primary protection.
Your Timeline — What Needs to Happen When
Now — Q1 2026: Complete scope assessment, volume check for exemptions, and obtain Exchange for Change logo specifications. Make the layout mapping decision on all container formats.
Q2 2026: Artwork redesign incorporating DRS and GS1 Sunrise changes simultaneously. Brief label supplier on material specification for DRS durability. Deposit value and producer fee announcements expected — update commercial pricing models.
30 April 2026: DRS Conference, London.
Q3 2026: Producer registration opens with Exchange for Change. Labels should be at production-ready stage. RVM software specification expected — final format verification against spec.
2026 generally: RVM validation testing on production samples. GS1 barcode verification. Final sign-off and production authorisation.
October 2027: Scheme goes live. All in-scope containers on the market must carry compliant DRS labelling.
Download the Free 2027 Label Compliance Checklist
We’ve produced a free 20-point DRS compliance checklist — plus an 18-point GS1 Sunrise checklist — designed to be used alongside this guide when briefing your packaging team and label supplier. Download it free at pid-labelling.co.uk/labelling-compliance.