Deposit Return Scheme 2027: What Drinks Brands Need to Change in Labelling and Fulfilment

The UK Deposit Return Scheme starts on 1 October 2027 in England, Scotland and Northern Ireland, with Wales running its own scheme from the same date. Single-use PET, aluminium and steel drinks containers from 150ml to 3 litres will carry a 20p deposit, the scheme logo and a new barcode registered with Exchange for Change.

For a brand that sells online, that is more than an artwork job. Your listings have to show the deposit, your warehouse will hold old and new versions of the same drink for months, and new-label stock cannot reach a customer before launch day. Some of the work, such as new codes on outer cases or rebuilt gift sets, can sit with a 3PL's barcoding and re-labelling services, but most of it starts with decisions you make now.

This is general guidance drawn from GOV.UK, the regulations and Exchange for Change. Confirm your obligations with Exchange for Change or a packaging compliance adviser before you act.

What the Scheme Covers and When It Starts

The scheme covers single-use drinks containers made wholly or mainly of PET plastic, aluminium or steel, between 150ml and 3 litres, and deposits apply from 1 October 2027. The GOV.UK guidance on producer and retailer responsibilities lists the exclusions: containers that are not single use, HDPE containers such as milk bottles, liquid medicines and flavour enhancers such as syrups and hot sauce.

Exchange for Change, the not-for-profit deposit management organisation running the scheme, confirmed in April 2026 that the deposit will be a flat 20p on every in-scope container across England, Scotland and Northern Ireland, whatever its size. The deposit is charged per container, so a six-pack carries six deposits.

Glass is the main difference between nations. It is out of scope in England, Scotland and Northern Ireland. Wales includes glass bottles from day one, but the Welsh Government's statement on the Wales regulations sets a four-year transition in which glass carries a zero pence deposit and is exempt from scheme labelling. The Welsh Government appointed Exchange for Change to run the Welsh scheme in August 2026.

Who Counts as a Producer, and Why Online Brands Are Retailers Too

You are a producer if you make in-scope drinks (usually the brand owner), import them into the UK, or fill and seal containers to order. Exchange for Change describes the producer as the business that first places the product on the UK market, and importers often take on the producer obligations. In England, Northern Ireland and Wales a producer must be established in the UK, which matters for overseas brands selling here.

Producers register, apply the deposit, pay deposits to the scheme, meet the labelling rules and report how many containers they place on the market. Sell direct to consumers as well and retailer duties apply on top: charging the deposit and showing scheme information. A direct-to-consumer drinks brand usually holds both sets of obligations. The licensing, age verification and duty side of selling drinks online is covered in our guide to alcohol and drinks fulfilment in the UK.

Labelling: The Scheme Logo and a New Registered Barcode

Every in-scope container needs the scheme logo and a barcode registered with Exchange for Change. The barcode is the part brands most often underestimate. The Exchange for Change FAQs confirm that all existing barcodes, including international ones, will need to change, so a can you sell today will need a new GTIN for its deposit version. International barcodes can be used but may attract an extra charge on top of the standard producer fee.

GS1 UK, which issues barcodes in the UK, summarises the rules from the scheme's material specification: accepted formats are EAN-13, EAN-8, UPC-A and UPC-E, each barcode must be unique to the product, and each container in a multipack needs its own barcode, different from the one on the outer pack. Return machines will also read 2D codes such as QR and Data Matrix, so if you use one, check that it carries the right GTIN.

Timing matters as much as design. Products carrying the new barcode and logo must not be sold to consumers before 1 October 2027. Plan artwork, print and filling so deposit-version stock is ready for launch without slipping into orders early.

Small Ranges: The Low-Volume Exemption

A product line selling fewer than 5,000 units a year counts as low volume, and Exchange for Change allows 6,250 units in the first 15 months of the scheme. Low-volume lines do not need the scheme logo or barcode, do not pay producer fees and do not carry a deposit, but they must still be registered and their volumes reported.

The threshold applies per product line, so one range can mix scheme and low-volume lines. Product data and warehouse records need to show which is which.

Registration: What to Do and When

Exchange for Change opened Phase 1 registration for producers and retailer return points on 29 September 2026, asking for basic company and contact details. Phase 2 opens in January 2027 and collects more detail about your role in the scheme. Producers need to complete both before launch.

No official source has confirmed a fixed product registration deadline, so register early and take any dates from Exchange for Change directly, not from industry guides.

Selling Online: Deposits on Listings, Multipacks and Takeback

Deposits apply online exactly as they do in shops, and your product pages have to say so. Under regulation 26 of the England and Northern Ireland regulations, a business offering in-scope drinks on a website, app or catalogue must show the scheme information clearly and accessibly in the product description: a statement that a deposit is charged on each item, the price without the deposit, the deposit and the price including it, and, for retailers, how customers can get their refund.

If you sell through a marketplace you do not control, the duty is to give that information to the platform and ask it to display it. Before October 2027, check your own store's product data, your marketplace listings and any product feeds, and make sure multipack listings reflect the deposit on every container.

You do not have to collect empties from online customers. Exchange for Change says online grocery retailers are not obliged to collect containers on delivery, and customers can return them to any return point. If you choose to offer collection, you register with Exchange for Change as a takeback service provider.

The Changeover in the Warehouse: Two Versions of the Same Drink

From a warehouse point of view, the scheme turns one product into two. Exchange for Change's update on transition arrangements confirms that drinks filled before 1 October 2027 sit outside the scheme and can still be sold after launch with no logo, no registration and no deposit. Empty packaging without the logo and a registered barcode generally cannot be filled and sold after launch, although talks with regulators continue on packaging tied to orders placed before that date. Industry is encouraged to sell through older stock by April 2028, but that is not a legal requirement.

So for months the same drink will exist as a no-deposit version with the old barcode and a deposit version with the new one. The two must never be mixed, and each order has to be picked from the version the customer was charged for. In practice that means:

• Separate SKUs: set up the deposit version as its own SKU with its new GTIN before the first pallet arrives, rather than overwriting the old barcode in the system.
• Held stock until launch: deposit-version stock can be received and put away, but should be blocked from picking until 1 October 2027.
• Batch and location control: record batches or filling dates at goods-in so you can show which stock was filled before launch. The same discipline underpins shelf life, stock rotation and batch traceability for food and drink brands.
• Matching listing and pick rules: if the website charges a deposit, the pick comes from deposit-version stock. When old stock runs out, the listing switches.
• Bundles and gift sets: a gift set built with old-label cans and one built with new-label cans are different products. Each kitting run should use one version, and the deposit shown online must match the containers inside.
• Damages and returns: returned or damaged units go back to the correct SKU or are written off, never restocked into the other version.

Over-labelling existing cans or bottles is not a safe shortcut. The material specification sets placement and readability rules for container barcodes, so check with Exchange for Change before planning any relabelling of the containers themselves. New codes on outer cases, sleeves and shipping cartons are a more ordinary re-labelling job.

Questions to Ask Your 3PL Before October 2027

• Can your warehouse system hold the old and deposit versions of a drink as separate SKUs, each with its own GTIN, and report stock for each?
• Can deposit-version stock be received and blocked from picking until 1 October 2027?
• Is stock tracked by batch and location, with an audit trail we can see?
• How are goods-in deliveries checked against what we told you to expect, including the barcode on each line?
• How will multipacks and gift sets be rebuilt for the deposit version, and how are those jobs quoted?
• Who plans the cutover with us, and when does that conversation start?

Running a DRS Changeover From a Northampton Warehouse

Fulfil with Synergy is a founder-led UK third-party logistics (3PL) provider that runs multi-channel, retail and Amazon Seller Fulfilled Prime fulfilment for growing and household brands from purpose-built facilities in Northampton. It combines AutoStore automation and the RedPrairie Dispatcher warehouse management system with high-touch services such as kitting, bonded warehousing and returns management, and supports alcohol and drinks brands with age-restricted delivery, tamper-evident packaging and controlled-access bonded zones.

For a DRS changeover, stock control matters most. RedPrairie Dispatcher gives real-time visibility down to unit, SKU, batch and location, a time-stamped, user-tagged audit trail of every stock movement, and exception handling that flags issues before they hold up orders. That is what keeps two versions of the same drink apart in one building.

The value-added services team handles barcoding and re-labelling at thousands of units a day, and quotes small ad hoc jobs from a packing list, a job specification and samples or images. Kitting covers bundles, subscription boxes and promotional packs with branded inserts, which is where multipacks and gift sets get rebuilt for the deposit version. Brands importing drinks can hold stock in the HMRC-approved bonded warehouse, with duty and VAT deferred until release. Each client has a dedicated account manager, so the cutover plan can start well ahead of October 2027.

A Timeline to Work To

• Before the end of 2026: list every drink, pack size and multipack, mark which are in scope in each nation and which are low volume, and complete Phase 1 registration.
• January to spring 2027: complete Phase 2 registration, allocate new GTINs, update artwork with the logo and new barcode, and agree print and filling schedules.
• Spring to summer 2027: set up deposit-version SKUs with your 3PL, update listings and checkout to show the deposit, and agree how gift sets and multipacks will be rebuilt.
• July to September 2027: receive deposit-version stock into held locations, run down old stock and plan the listing switch for each product.
• From 1 October 2027: release deposit stock, charge the deposit, and review mis-picks, returns and customer questions weekly until old stock has sold through.

FAQ

Do drinks in glass bottles need a deposit?

Not in England, Scotland or Northern Ireland, where glass is outside the scheme. Wales includes single-use glass bottles from 1 October 2027, but under a four-year transition they carry a zero pence deposit and need no scheme labelling. Exchange for Change says no deposit or DRS labelling will be required on glass supplied in Wales until October 2031. If you sell glass into Wales, follow the Welsh scheme separately, because Wales has its own regulations and plans for reuse, and more guidance is still to come. Keep glass and non-glass lines clearly coded in your product data so the right rules follow each SKU, and check the position again before each artwork change.

Can I still sell stock with old labels after 1 October 2027?

Yes, if the drink was filled before 1 October 2027. Exchange for Change treats those products as outside the scheme, so they can be sold after launch without the logo, registration, producer fee or deposit. Packaging that is still empty at launch is different and generally has to meet the new requirements before it is filled. Exchange for Change is in talks with regulators about flexibility for empty packaging linked to orders placed before launch, and encourages the industry to sell through older stock by April 2028, though that is not a legal requirement. Keep filling records or batch data for every delivery, so you can show when each batch was filled if anyone asks.

Do overseas drinks brands selling into the UK have to register?

Usually someone in the UK supply chain does. The producer is the business that first places the drink on the UK market, and importers often take on the producer obligations. In England, Northern Ireland and Wales a producer must be established in the UK, so a brand based abroad will need a UK entity or an importer to hold the obligation. Agree in writing who registers, who applies the deposit and who reports volumes before the first deposit-version shipment lands. Bonded storage can still help with duty and VAT on imported drinks, but that is a separate question from who the producer is. Confirm your position with Exchange for Change or a compliance adviser before you ship.

How much will the scheme cost a drinks producer in its first year?

Producer fees are set at 0p for the first 15 months, from October 2027 to December 2028, under the stepped fee plan Exchange for Change announced in September 2026. From January 2029, projected fees are 0.6p per unit for aluminium and steel containers and 2.3p per unit for PET, with a review in May 2027. The real first-year costs sit elsewhere: new GTINs, artwork and print changes, packaging that can no longer be filled, website and listing updates, and warehouse work such as separate SKUs, held stock and rebuilt gift sets or multipacks. Budget for those now, because most of them land before launch rather than after it.

If your drinks range needs new barcodes, separate deposit-version SKUs or rebuilt gift sets before the scheme starts, talk to Fulfil with Synergy about planning the changeover with your account team.

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