Information for businesses

A scheme article is a drink that is contained in single-use packaging that is: 

• made from PET plastic, steel or aluminium;
• between 150ml and 3 litre of liquid in volume;
• sealed in an airtight and watertight state at the point of sale;
• first made available to be sold by the producer on or after 01 October 2027;
• made available to be sold by the producer for the purposes of its retail in Scotland. 

In some guidance, you may also see scheme articles being referred to as scheme containers.

The following is a non-exhaustive list of examples of beverages which, when contained in scheme packaging, would be in scope: 

• bottled water, fruit juice, fizzy drinks;
• beer, wine, spirits;
• sports drinks (including electrolyte and energy drinks);
• milkshakes;
• pre-made drink mixers and ready to drink beverages;
• concentrates such as cordial and squash to be diluted.

A non-scheme article is a drink that meets all the criteria listed in the definition of scheme-article but was produced before 01 October 2027.

A non-Scottish article is a drink that meets all the criteria listed in the definition of scheme article but was not produced for the purposes of retail sale in Scotland, i.e. you cannot buy the drink from a retailer in Scotland.

Scheme packaging is the packaging material that comes into direct contact with the drink (e.g. the bottle or can). This does not include any packaging used to group together two or more drinks in a multipack (e.g. plastic wrap).  

In some guidance, you may also see scheme packaging being referred to as empty scheme containers.

A producer is:

• a drinks brand owner (for scheme articles branded in the UK);
• an importer of drinks into the UK for sale to consumers in Scotland (for scheme articles branded outwith the UK);
• someone selling drinks in single-use containers that are filled and sealed by the retailer at the point of sale (e.g. a crowler). 

You can find more information about producers and their obligations on our Producer page.

The definition of brand owner is set out in the Deposit and Return Scheme for Scotland Regulations 2020. 

You are the brand owner if you are: 

• the person who, in the course of a trade, business, craft or profession, puts a name, trademark or other distinguishing mark on a scheme article,  low volume drink product or packaging for that low volume drink product or scheme article, by which the person is held out to be the manufacturer or originator of the scheme article or low volume product within the UK.

Importers are considered producers under Scotland’s Deposit Return Scheme (DRS) and have producer obligations they must comply with, including registering to be part of the scheme. 

The definition of an importer is set out in the Deposit and Return Scheme for Scotland Regulations 2020. 

You are an importer if you are: 

• the person who, in the course of a trade, business, craft or profession, first markets, offers for sale or sells the scheme article or low volume product in the UK. 

This means if you are buying drinks from abroad (i.e. drinks branded outside the UK) and making them available for retail sale in the UK and are the first UK-based person in the supply chain, you are an importer. 

We are aware that other definitions of importer are used in other regulations and enforcement agencies, however, for the purposes of Scotland’s Deposit Return Scheme, the definition is as above. For example, the importer of record for customs purposes may not necessarily be the same as the importer for the deposit return scheme. 

A retailer is someone who markets, offers for sale or sells scheme articles (drinks) to a consumer in Scotland. This includes face-to-face retail, online retail, sales in a hospitality setting, sales from vending machines, and wholesalers. 

You can find more information about retailers and their obligations on our Retailer page.

A hospitality retailer is someone who sells scheme articles (drinks) in a hospitality setting such as a bar, restaurant, or café for the purposes of consumption on the premises. 

For the purposes of Scotland’s Deposit Return Scheme, hospitality businesses that sell drinks for consumption off site of the premises of sale (i.e. to takeaway) are also retailers.  

A hospitality retailer has slightly different obligations to a retailer. You can find more information about hospitality retailers and retailers, and their obligations, in the retailers section.

Any place in Scotland where scheme articles are sold to consumers are ‘retail premises’ for the purposes of the Deposit and Return Scheme for Scotland Regulations 2020. The definition of Scotland (for the purposes of the Regulations) includes the territorial sea adjacent to Scotland.  

Where scheme articles are sold to consumers, retail premises can include: 

• temporary and movable structures such as tents or stalls situated on land; 
• vehicles such as food vans, trains, planes or buses;
• ferries and other vessels operating in Scottish waters. 

For the purposes of the Deposit and Return Scheme for Scotland Regulations 2020 (as amended), ‘placed on the market’ has the same meaning as defined in the retained EU law Regulation (EC) 178/2002 ‘General Food Law’, which states: 

‘placing on the market’ means the holding of food or feed for the purpose of sale, including offering for sale or any other form of transfer, whether free of charge or not, and the sale, distribution, and other forms of transfer themselves. 

The Deposit and Return Scheme for Scotland Regulations 2020 define a ’drink’ as a beverage intended for human consumption, including concentrated soft drinks. The Regulations do not limit or expand on the meaning of ‘beverage’ in this definition. 

If you are unclear if a product is in scope of Scotland’s Deposit Return Scheme, you may find the HMRC’s Beverage Test helpful in deciding if a product should be identified as a beverage. 

Any flavourings, syrups (including coffee syrups), sauces or ingredients (e.g. lemon juice) that might be added to a drink but are not themselves a drink, are not in scope of Scotland’s Deposit Return Scheme. 

SEPA may request information from producers to demonstrate why they consider that a product is not in scope.

The scheme administrator is responsible for the day-to-day management of Scotland’s Deposit Return Scheme. They must comply with the obligations as set out in the Regulations and act in accordance with their approved operational plan. Their role includes being responsible for registering producers and return point operators, overseeing the return point exemption process and meeting minimum collection targets.

UK Deposit Management Organisation Limited (trading as Exchange for Change) was approved as the scheme administrator in the Deposit and Return Scheme for Scotland (Designation of Scheme Administrator) Order 2025. For ease, these FAQs refer to the Scheme Administrator as "Exchange for Change".

The timetable for the introduction of Scotland's Deposit Return Scheme is set out in The Deposit and Return Scheme for Scotland Regulations 2020. 

The scheme goes live for consumers on 01 October 2027. All drinks in scheme packaging must bear a deposit, display a scheme logo, and groceries retailers who market, offer by sale or sell scheme drinks must operate return points (unless exempt).

Scotland’s Deposit Return Scheme goes live to consumers on 01 October 2027. This means that from the 01 October 2027 onwards, if you are selling any drinks that are part of the scheme (scheme articles) to consumers you will have to charge the deposit on each drink you sell. You cannot charge the deposit to consumers before this date.

Drinks are scheme articles and part of the scheme if they are packaged in a single-use container made from PET plastic, glass, steel or aluminium sized between 150ml and 3 litres, and were first marketed or offered for sale on or after the 01 October 2027. 

Yes, you will still be able to sell these items. They are called ‘non-scheme articles’ and a deposit should not be charged to the consumer on these drinks. Retailers must make it clear to consumers at the point of purchase that they are buying a non-scheme article and that they will not receive a refund for the packaging if they take it to a return point. 

The Regulations do not set a time limit for the consumer to return scheme packaging to a return point or use a takeback service, if one is offered. 

The timeframes for return will be influenced by consumer behaviour, with some scheme packaging being returned more quickly than others. For example, a consumer might return a bottle of water within days of purchase but wait longer to return a premium or limited edition product.

Any deposits that are not redeemed by the consumer will be held by the Scheme Administrator and used to help fund the operation of the scheme.

If you operate a return point (either a reverse vending machine (RVM) or manual return) or collect scheme packaging through a takeback service, you should be familiar with waste Duty of Care requirements and what that means for you and your business. This includes how you store, segregate and transport your waste. 

More information about Duty of Care is available in the Duty of Care: code of practice for managing controlled waste.

Empty scheme containers (scheme packaging) returned by a consumer are waste and therefore subject to regulatory control. 

Storage, sorting and transport of scheme packaging will need to be carried out with the appropriate duty of care and waste authorisation in place. The waste authorisation you need will depend on the amount and type of material handled of if the waste is segregated (PET plastic and metals stored separately) or co-mingled. If you operate a reverse vending machine or manual return point it is likely that you will fit within the limits of a General Binding Rule.

More information is available on our website.

Yes. Empty containers (scheme packaging) are waste and therefore subject to regulatory control. Any person that operates a takeback service should ensure that they, or their service provider, are authorised to carry/transport waste and are registered as a waste carrier. 

A business only needs to hold one waste carriers licence – there is no need to register each employee individually unless they are working as private individuals. Further information and guidance on registering as a waste carrier is available on the Waste carriers and brokers web page.  

Any takeback service provider  using a third-party waste company to collect scheme containers as part of their takeback service is responsible for ensuring that they are a registered waste carrier. Check our registered waste carriers list for of details of currently registered waste carriers or brokers.

Yes. By offering a cash deposit back to consumers, this ensures that Scotland’s Deposit Return Scheme is accessible to everyone.   

If the retail or hospitality premises operates entirely cashless, SEPA would not expect the retailer to provide a physical cash deposit so long as wireless transfer is available. It is not acceptable to only offer the deposit as points or vouchers solely for redemption within a specific retailers' premises.

Empty scheme packaging returned by a consumer is waste and therefore subject to regulatory control but, if you comply with certain rules, you will not need to apply to SEPA for a permit.  All groceries retailers who are not automatically exempt must however register with the scheme administrator to operate their return point. 

For those able to store metal and plastic scheme packaging separately there is a General Binding Rule (Waste GBR 3) - The temporary storage of waste at a collection point - under Part 1, Chapter 3 of Schedule 9 of the Environmental Authorisations (Scotland) Regulations 2018. 

General Binding Rules are mandatory rules that apply to low-risk activities. As long as you comply with the rules in full, you are authorised and do not need to apply for a permit. 

For those who need to mix waste types (metal and plastic scheme packaging) SEPA has published a Regulatory Position Statement which, if certain conditions are met, enables a return point operator to store mixed waste without the need to apply for and obtain a permit from SEPA.

Please see SEPA Position Statement - Collection of scheme packaging as part of Scotland’s Deposit Return Scheme (Reference: DRS-PO-01).

You must display the deposit amount clearly and separately from the price in any place where a drink in a scheme container is offered for sale. This includes online retail platforms. 

Providing deposit information means the customer is aware of the cost of the deposit before deciding to purchase so can make an informed choice. It is an offence under the Regulations not to display this information. 

We understand that there will be different scenarios for different retailers and producers, and we want you to be able to apply the best solution for your online retail platform. Deposit information should always be clear to ensure customers are not confused about the deposit associated with the drink or drinks they are buying. 

The Regulations also require that you provide information about how the deposit can be redeemed.

The Regulations do not require the deposit to be displayed on receipts, although a retailer may wish to include or itemise it to help customers understand the difference between the amount charged and the price of their goods. 

Similarly, the Regulations do not require the deposit to be displayed on tills. It will be down to individual retailers to decide how they set-up their tills, although a retailer may wish to include or itemise the deposit to help customers understand the difference between the amount charged and the price of their goods.

The Regulations do not require the value of the deposit to be printed on the drink container. However, you must clearly display the deposit any place where the article is marketed for sale, and it is an offence under the Regulations not to do so.  

There may be other legislation or regulations that cover trading standards, pricing and labelling that you may need to consider. 

We understand that the exact labelling solution or price display may be different for different producers, retailers and drinks but price information should always be clear to ensure consumers are not confused about whether there is a deposit associated with the drink or not. 

Under the Deposit and Return Scheme for Scotland Regulations 2020, all drinks producers that want to sell their products (scheme articles) in Scotland must register with the scheme administrator to be part of the scheme. One registration is required per producer, regardless of the number of sites they operate.  

For further information on producer registration please visit the Exchange for Change website. 

A producer is:

• a drinks brand owner or importer into the UK market;
• a low volume drinks product brand owner or importer;
• companies that fill and seal drinks into single-use scheme containers at the point of sale for customers to takeaway. 

If a drink has been produced and marketed, offered for sale or sold before the scheme go-live date (1 October 2027), it will be considered a non-scheme article. This means it can still be marketed and sold without a deposit attached.

It must be made clear to consumers at the point of purchase that they are buying a non-scheme article and that they will not receive a refund for the empty packaging if they take it to a return point. 

It is likely that a return point will not accept the empty containers of non-scheme articles. 

No. If the original producer cannot be identified, the drinks would be non-Scottish articles. Another person or business would not be able to register as the producer for the drinks and could not sell them to consumers in Scotland.

Yes. We are aware that for some drinks more than one business will import them for sale in the UK. This means there will be multiple importers placing the same drink with the same SKU that has been branded outside the UK, on the market.

Where this occurs each importer needs to register independently and report on the number of units that they place on the market for sale to consumers in Scotland and/or the UK.

If you think this is the case for any of your products, you should speak to the scheme administrator, UK DMO Ltd trading as Exchange for Change, about how to manage this.

In this scenario, under the DRS Regulations, you would be the importer and it would be your business that should register as the producer. This is because you are the person who first markets, offers for sale or sells the drinks in the UK. Your customer is collecting them after you have made the sale to them.  

An importer for the purposes of the DRS Regulations is the person who makes the first transaction within the UK for a scheme article branded outside the UK. This may differ from the importer of record for customs purposes.

Yes. You do not need to take physical possession of scheme articles in order to be the producer if you are the first person to market, offer for sale or sell the drinks in the UK. This is because, for the purposes of the DRS Regulations, the importer (producer) is the person who makes the first transaction within the UK for a scheme article branded outside the UK. 

However, if you are only paid a commission or ‘finder’s fee’ and do not purchase the drinks to then sell on, then you would not be considered the producer.

All producers must register with the scheme administrator, Exchange for Change. Producers must apply to register before 01 October 2027 or within 28 days of becoming a producer.

Further information, when available, will be on the Exchange for Change website. 

Producers must apply to register with the scheme administrator prior to 01 October 2027 or  within 28 days of becoming a producer.

Further information, when available, will be on the Exchange for Change website. 

Producers are required to register with the scheme administrator and may be required to pay a producer registration fee. The level of the producer registration fee, if any, will be determined by the scheme administrator, Exchange for Change.

If you are the first person in the supply chain to market, offer for sale or sell in the UK  scheme article branded by a brand owner outside the UK, you must apply to the scheme administrator to register as a producer before 1 October 2027 (or  where you do not meet this definition on that date, but later do, within 28 days of meeting this definition). 

Where a scheme article branded by a brand owner outside the UK is being sold for the first time in the UK, to a consumer in Scotland through a website or online marketplace,  the person who controls access to, and the content of, that website or online marketplace is the producer and will need to apply to the scheme administrator to register as a producer within the timescales set out in the paragraph above. 

You may be an importer (and therefore a producer) for Scotland's Deposit Return Scheme even if you are not considered the importer for customs purposes.

Drinks produced during experience days would not be in scope of Scotland’s Deposit Return Scheme.  

The Deposit Return Scheme for Scotland Regulations 2020 apply to all scheme articles. A scheme article is a drink that is:

• contained in single-use packaging made from PET plastic, steel or aluminium;
• between 150ml and 3 litres;
• sold in a sealed container;
• first marketed, offered for sale or sold on or after 1 October 2027; and
• made available to be sold by the producer for the purposes of retail sale in Scotland.  

During a make your own experience, you are selling the experience of making the drink and not the drink itself. As a result, the drinks are not for retail sale and not scheme articles. 

For online or distance retail sales, in any place where a scheme article is displayed for sale, you must clearly display information about how the deposit can be redeemed. It is an offence under the Regulations not to display this information.  

We understand that there will be different solutions for different retailers, and we want you to be able to apply the best solution for your online retail platform. Customers buying drinks through online sales do not have to use a takeback service if provided and can return their empty containers to any return point.

Return points are where consumers can return their empty scheme containers (scheme packaging) and get their deposit back. A sum equal to the deposit will be reimbursed for each item of scheme packaging returned. Scheme packaging can be returned to any return point regardless of where the drink was originally bought. 

A return point can be operated manually (scheme containers handed over the counter and the deposit refunded by the retailer), or a retailer can install a reverse vending machine (RVM) on their premises (automatically accepts empty containers and refunds deposits).

A voluntary return point is a return point operated by an organisation or business that has no obligation under the Regulations to operate one but has chosen to do so. For example, voluntary return points may be operated at transport hubs or in shopping centres. Voluntary return points can also be run by charities or community groups.

A reverse vending machine (RVM) is a machine that allows a consumer to insert an empty scheme container (item of scheme packaging) in exchange for their deposit. The machine scans the scheme packaging to ensure it is part of the scheme before issuing the deposit.

The returned scheme packaging is stored within the RVM for collection by the scheme administrator. Scheme packaging can be returned to any RVM, regardless of where the drink was originally bought. 

Yes, groceries retailers can apply for an exemption from acting as a return point. There are two types of exemption:

• Proximity exemption - if there is an alternative return point located within reasonable distance to your premises.
• Premises exemption - if it is made on the grounds that the location, layout, size, design, or construction of those retail premises does not permit, or cannot reasonably be altered to permit, the operation of a return point on those premises.  

The exemptions service for Scotland’s Deposit Return Scheme is run by the scheme administrator, Exchange for Change. Please visit their website for further information on exemptions. 

Registered return points including voluntary return points and hospitality businesses must accept returns/collect scheme packaging and store them for collection by the scheme administrator.  

The scheme administrator will inform return point operators and hospitality businesses how their packaging will be collected for inclusion in the scheme. Further information on collections by the scheme administrator is available on the scheme administrator's website. 

If you are a hospitality business that sells drinks for consumption on your premises (i.e. operating a closed loop system), you should collect and store scheme packaging for collection by the scheme administrator, Exchange for Change.

Further information on collections for hospitality businesses is available on their website. 

No, there is no requirement for retailers to register with SEPA. 

If you operate a return point you will have to register with the scheme administrator, Exchange for Change. They are responsible for the day-to-day management of Scotland’s Deposit Return Scheme. This includes responsibility for the collection of all returned containers and the management of deposits and payments.

Further information about registering as a return point operator is available on their website. 

Yes. In many cases it will be the preferred approach for a landlord to register a voluntary return point to manage reverse vending machines on behalf of a group of groceries retailers in a shopping centre or retail park.   

The landlord would have to register as a voluntary return point with Exchange for Change, the scheme administrator, and ensure that the return point is proportionately sized and reasonably located for the businesses it covers. All retailers not operating their own return points would have to register an exemption with the scheme administrator. 

Exchange for Change will provide guidance on exemptions and process the application(s) for both operating a voluntary return point and the exemption from operating a return point for the retailers concerned. 

No. There would be no obligation to allow members of the public or unauthorised persons to have access to return points at sites with restricted access (e.g. corporate canteens, prisons, police bases, army bases, school canteens).

Return point operators have a legal responsibility to accept all scheme packaging regardless of size and shape and must have a means to accept all empty containers that are part of the scheme. Some drinks packaging may not fit in a reverse vending machine (RVM). For example, some bottles may be too long or too wide. 

 If an RVM cannot accept scheme packaging due to size or shape, then return point operators will need an alternative option for those containers.  

Other than for the reasons listed below, SEPA expects return point operators to accept all scheme packaging and may investigate any non-compliances.  

A return point operator can refuse to accept scheme packaging from a consumer if:  

• the container is soiled, broken, not empty or not identifiable as being part of the scheme;
• the return point is full and waiting for collection or uplift;
• a consumer attempts to return more empty scheme containers than the number of drinks normally sold in a single transaction, or which exceeds the number of items the voluntary return point operator identified in their application to the scheme administrator. 
• the container is for a drink that the return point operator does or would not sell for reasons of faith or belief

A return point operator has a legal responsibility to accept scheme packaging or returnable packaging that is returned from a consumer. However, the operator can refuse to accept scheme packaging or returnable packaging if:

• the container is soiled, broken, not empty or not identifiable as being part of the scheme.
• the return point is full and waiting for collection or uplift.
• a consumer attempts to return more empty scheme containers or returnable packaging  than the number of drinks normally sold in a single transaction, or in the case of a voluntary return point operator, than it agreed to accept when applying.
• the scheme packaging, or returnable packaging, is for a drink that the operator does or would not handle for reasons of faith or belief. 

Empty scheme containers (scheme packaging) returned by a consumer are waste and therefore subject to regulatory control. 

Storage, sorting and transport of scheme packaging will need to be carried out with the appropriate duty of care and waste authorisation in place. The waste authorisation you need will depend on the amount and type of material handled of if the waste is segregated (PET plastic and metals stored separately) or co-mingled.

If you operate a reverse vending machine or manual return point it is likely that you will fit within the limits of the General Binding Rule for temporary storage of waste at a collection point.

The scheme administrator must pay a handling payment to return point operators from whom they collect scheme packaging or returnable packaging. Among other things, the scheme administrator must have regard to the costs incurred for time, equipment, and additional storage needed to operate as a return point when determining the handling payment amount. 

The handling payment amount will be determined at least every three years. Further information about handling payments, when available, will be on the Exchange for Change website.

A takeback service is a collection service that allows for the collection of empty scheme packaging or returnable packaging from the consumer's location (e.g. your home address). 

A person may provide a takeback service only if they are registered with the scheme administrator. The scheme administrator, Exchange for Change, must publish and maintain a list of registered takeback service providers.

Following collection, a sum equal to the deposit will be reimbursed to the customer for each item of scheme packaging returned.

No. There is no obligation for online retailers to offer a takeback service, but any person may apply to the scheme administrator to register as a takeback service provider.  

No. A takeback service may be offered for scheme articles purchased through online or distance sales. Customers do not have to use the takeback service if offered and can return their empty containers to any return point.

Yes. Empty containers (scheme packaging) are waste and therefore subject to regulatory control. Any person that operates a takeback service should ensure that they, or their service provider, are authorised to carry/transport waste and are registered as a waste carrier. 

A business only needs to hold one waste carriers registration  there is no need to register each employee individually unless they are working as private individuals. Further information and guidance on registering as a waste carrier is available on the Waste carriers and brokers web page.  

Any takeback service provider  using a third-party waste company to collect scheme containers as part of their takeback service is responsible for ensuring that they are a registered waste carrier. Check our registered waste carriers list for of details of currently registered waste carriers or brokers.

The Regulations do not specify a service level agreement or timeframe for redeeming the deposit or refunding the customer. We would consider a reasonable delay to allow for verification of returned packaging to be acceptable. This should be communicated to the customer at the point of choosing the takeback option.