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".

A groceries retailer means a retailer which is a supermarket of any size, a grocery store, a convenience store, or a newsagent which sells groceries.

"Groceries" means one or more of the following sold by a retailer—

• food suitable for human consumption (other than sold exclusively for consumption on the premises of sale),

• scheme articles or other drinks (alcoholic and non-alcoholic, other than sold exclusively for consumption on the premises of sale),

• pet food,

• cleaning products,

• toiletries and household goods, other than petrol, clothing, DIY products, financial services, pharmaceuticals, newspapers, magazines and books, greetings cards, CDs, DVDs, videos and audio tapes, toys, plants, flowers, perfumes, cosmetics, electrical appliances, kitchen hardware, gardening equipment, books, tobacco and tobacco products

“Returnable packaging” means an item of packaging in which a drink was contained or sold and which is subject to any other deposit and return scheme established in another part of the United Kingdom.

For example, the container for a drink purchased in England for which a deposit was paid under the English DRS can be returned to a registered return point within Scotland.

The deposit is a refundable 20p charge which is added to scheme articles. The deposit is collected at the point of sale and is intended to be reclaimed when the empty scheme container is returned by a consumer. The deposit amount is determined by the scheme administrator, Exchange for Change. The same deposit amount will apply to all in-scope scheme articles, including those within multipacks.

The scheme administrator must make a handling payment to each return point operator from whom they have collected scheme packaging or returnable packaging. This is in addition to the refund of deposits for each item collected.

The scheme administrator will determine the amount of the handling payment, having regard to all relevant factors including:

• the costs of purchasing or leasing any machinery, materials or equipment required for the collection or storage (or both) of scheme packaging and returnable packaging;

• the costs of rental value of the floor space or any other part of any premises used solely for the collection or storage (or both) of scheme packaging and returnable packaging;

• the costs of staff time dedicated to the collection or storage (or both) of scheme packaging and returnable packaging.

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. 

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).

The deposit is 20p per drink (scheme article). The 20p deposit is charged on each drink bought and redeemed on each empty scheme container returned. For multipacks, the deposit is charged per drink in a pack rather than per pack. For example, for a multipack containing six drinks the deposit would be £1.20.

The 20p deposit applies to drinks (scheme articles) that are part of Scotland’s Deposit Return Scheme. This includes all drinks that are sold on the Scottish market from 01 October 2027 in single-use containers made from PET plastic, steel or aluminium, sized between 150ml and 3 litres.

You do not have to charge the 20p deposit if you are selling drinks to consumers in a hospitality setting where the drink is consumed on-site, for example, in a pub or restaurant. This is because the container is not expected to leave the premises and you will be able to collect all your empty drinks containers.

The deposit is not applied to drinks you sell in export (duty free) shops or to consumers outside Scotland.

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.

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 transports waste on a professional basis, e.g. a company collecting packaging from a return point should ensure that they, or their service provider, are authorised to transport waste.

A business only needs to hold one transporting waste 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 transporter is available on our website under Authorisations and Compliance. Please note that before 1 April 2026, waste transporters were known as waste carriers.  

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).

In most cases, yes. Whether something is a scheme article is decided at the point of production. Therefore if a drink meets the definition of a scheme article (including that it is made available to be marketed, offered for sale or sold by the producer for the purposes of its sale to a consumer in Scotland) at the point of production, it remains a scheme article even if it later becomes a complimentary drink.

You will know if a drink is a scheme article as it will carry the scheme logo and scheme return barcode. The following is a non-exhaustive list of situations where a complimentary/free drink is could still be deposit bearing:  ​

• complimentary drinks in hotel rooms and on transport;

• drinks that accompany free school meals or are distributed at food banks;

• drinks given out as part of a promotional or sports event.

If a product line is produced specifically without the intention to be marketed, offered for sale or sold for retail sale in Scotland (e.g. a sample line not for retail sale), then SEPA would not consider them as being scheme articles. A scheme logo should not be displayed on these drinks and deposits should not applied. It should be clearly communicated to consumers and any third party distributing the product that these complimentary drinks are not part of the Deposit Return Scheme, they cannot be sold and that they are unable to be returned to reclaim a deposit. It would be an offence to market, sell or offer these drinks for sale to consumers in Scotland.

There must always be an option for the deposit to be available as a cash redemption. A return point operator must pay out a sum equal to the deposit (20p) for each empty scheme container accepted at the return point. The return point operator can offer the consumer options for how the deposit is returned, for example, by way of charitable donation, store points or in-store vouchers, or wireless transfer. You cannot only offer the consumer store points or vouchers.

No. The deposit paid on each drink is 20p and so 20p must always be returned to the consumer. This is set out in the Regulations (Regulation 20 (2)(b)). Any other incentives a retailer or return point operator may wish to use must remain separate to the redeemed deposit.

Yes. The deposit amount for each scheme article will be the same across the UK.

Yes. The empty scheme packaging that is identifiable as being subject to another UK deposit and return scheme can be returned to a Scottish return point and the deposit redeemed. These containers are known as "returnable packaging".

Yes. The deposit amount for each scheme article will be the same across the UK.

Yes. The empty scheme packaging that is identifiable as being subject to another UK deposit and return scheme can be returned to a Scottish return point and the deposit redeemed. These containers are known as "returnable packaging".

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. 

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

Please note for multipacks this would mean that the total amount of the deposit is displayed, rather than the deposit amount per item. For example, for a multipack containing six drinks the deposit displayed would be £1.20.

The Regulations do not specify the format for displaying the deposit. We understand that prices displayed in-store may be different for different retailers and different drinks, but 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 you to display information in-store about how the deposit can be redeemed. 

Any scheme article which is made available for sale to a Scottish consumer online must carry the scheme logo. There is no specific requirement to display the scheme logo on the website where the article is offered for sale or marketed, but information must be clearly displayed so that the consumer is made aware of the drink being a scheme article or not, and the amount of the deposit that is being applied. Online retailers may choose to display the DRS Logo when meeting this obligation.

Any person who markets, offers for sale or sells a scheme article in Scotland must ensure that the scheme article carries the scheme logo and a scheme return code (e.g. barcode registered with the scheme administrator). Each individual drink within a multipack will be required to carry the scheme logo and a scheme return code. This is to enable consumers and return point operators to identify scheme articles and redeem deposits.

The scheme administrator will issue and publish the scheme logo, and there may be a separate logo for scheme multipacks . If a separate logo for scheme multipacks is issued, any person who markets, offers for sale or sells a scheme article in Scotland as part of a scheme multipack must also ensure that the multipack carries the scheme multipack logo. Further information, when available, will be on the Exchange for Change website.

Yes. The same logo must be used for all scheme articles, including those sold in multipacks. For details on the logo and how to obtain a copy for use please visit the Exchange for Change website.

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.

Until DRS is operational on 01 October 2027 DRS materials are excluded from the 'disposal costs' element of packaging EPR requirements. However DRS material still carries the packaging EPR 'recycling' obligation. This means that producers still have to arrange for PRNs/ePRNs to be purchased to demonstrate that they have met recycling requirements.

After DRS becomes operational DRS materials will be excluded from both disposal costs and recycling obligations. 

Yes. If the packaging (container) for your drink is designed to be capable of holding between 150ml and 3l of liquid and meets the rest of the definition of being a scheme article, then it is included within the scheme and a deposit must be applied. This includes drinks where the producer has chosen not to completely fill the container and where the volume of liquid within the packaging may be less than 150ml. For example, cocktails sold in cans designed to contain up to 150ml but where only 100ml of liquid is filled are scheme articles.

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.

Hospitality retail occurs at locations where scheme articles sold are to be consumed on the premises where they are purchased. This includes sites not traditionally considered as hospitality but where consumers have limited/no ability to leave and access a return point to redeem the deposit. Examples may include prisons, schools, secure military locations, onboard vessels or oil rigs. Such hospitality retailers do not charge the deposit to consumers, instead they must gather and retain the empty scheme packaging for collection by the scheme administrator, Exchange for Change. Hospitality retailers must still only buy scheme articles from registered producers and must pay the deposit on all in-scope drinks they purchase for sale.

On collection, Exchange for Change will pay hospitality retailers the amount equal to the deposits which have been paid by those hospitality retailers in respect of the collected scheme packaging. 

Yes. A hospitality retailer under DRS is a retailer who sells scheme articles for consumption on the premises of sale. Such retailers may also sell drinks to takeaway. A consumer should not be charged a deposit for scheme articles consumed on the premises and packaging should be retained by the hospitality retailer for collection by the scheme administrator, Exchange for Change. However, when selling scheme articles for takeaway the retailer must meet the general retailer obligations such as charging the deposit, clearly displaying information that the drink is a deposit bearing scheme article, the amount of the deposit and how it can be redeemed.

Only groceries retailers are obligated to operate a return point at any retail premises in Scotland at which a scheme article is marketed, offered by sale or sold by that groceries retailer. All such groceries retailers must operate a return point unless one of the following criterial applies:

• those retail premises have less than 100 m² of retail space (even if they are part of a larger building, and regardless of what the rest of the building is used for), and are located in an urban area, meaning an area classified by the Scottish Government (Urban Rural Classification 2020, published 31 May 2022) as either a large urban area (class 1), or another urban area (class 2).

• those retail premises are an export shop,

• the sale of a scheme article on those retail premises is solely by way of a vending machine,

• the sale of a scheme article on those retail premises is solely by way of a distance retail sale (e.g. internet sale with delivery to the consumer’s home address), or

• the groceries retailer has been granted an exemption by the scheme administrator in relation to those premises.

A groceries retailer that is required to operate a return point must be registered with the scheme administrator in respect of each of their retail premises and clearly display information on those premises about how a deposit can be redeemed in relation to a scheme article.

If you are a groceries retailer who isn't required to operate a return point, or any other person who wished to operate a return point you may apply to the scheme administrator, Exchange for Change, to operate a voluntary 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.

SEPA has published a regulatory Position Statement which, if certain conditions are met, allows Return point operators to store empty scheme packaging made from PET plastic, aluminium and steel together (mixed) 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).

If you would otherwise have to operate a return point (see FAQ “Do I have to operate a return point?”), then you would still have to operate a return point. You may be able to apply for a proximity exemption to operate a return point if there is an alternative return point located close by. The exemptions service is run by the scheme administrator, for further information please visit their website (Exchange for Change).

If an exemption is granted, you must display clear information to advise customers about how a deposit can be redeemed.

See the definition section of our FAQs for further information. 

While an RVM makes it easier to operate a return point, it is not essential and does not change your obligations. You will still need to register the return point with the scheme administrator, Exchange for Change, and accept empty DRS packaging from consumers. If operating a return point without an RVM you must be able to accept returns manually. Returned scheme packaging should be stored separately from other waste and kept securely for collection by the scheme administrator, Exchange for Change.

Groceries retailers who have multiple premises may choose to collect and consolidate returned scheme packaging from return points across their stores prior to collection by the scheme administrator. These containers are waste and therefore subject to regulatory control.

For those able to store metal and plastic scheme packaging separately (not mixed with plastic scheme packaging) at the consolidated storage site there is a General Binding Rule (Waste GBR 3) "The temporary storage of waste at a collection point" under 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.

SEPA’s Regulatory Position Statement only applies where scheme packaging is stored at a return point. Therefore, if you need to mix waste types at the consolidated storage site, or if you are unable to comply with the Waste GBR 3 rules, you will need to ensure that the site being used is authorised under a permit issued by SEPA, or apply to SEPA for a permit if one is not already in place.

Groceries retailers are retailers which sell groceries (see the FAQ “What is meant by the term 'groceries'?”) and are either a supermarket of any size, a grocery store, a convenience store, or a newsagent). If your shop’s main business activity clearly isn’t the sale of groceries (such as a coffee shop or a pharmacy also selling scheme articles to take away), you will not be obligated to host a return point. There may be some larger shops with a dual purpose where significant retail space is given over to groceries. An example is a larger garden centre which also has a lot of retail space for groceries. These will be considered as grocery stores where they market, offer by sale or sell scheme articles and will be obligated to operate a return point (unless exempt) . If you aren't sure where you fall, email depositreturn@sepa.org.uk

If multiple companies are sharing a wider open plan retail space, each company is responsible for the retail space they directly control. If Company A's retail space sells scheme articles and mainly groceries, and Company B does not then it is only Company A which needs to operate a return point (unless exempt). Likewise, if both Company A and B are grocery stores selling scheme articles then both would need to operate a return point if not exempt.

No. There is no obligation to offer a takeback service but doing so would support customers who have reduced access to return points and further supports the collection of scheme packaging. Any person considering offering a takeback service should contact the scheme administrator, Exchange for Change to discuss. You need to be registered as a takeback service provider with the scheme administrator to provide a takeback service.

If you wish to offer a takeback service then you will need to apply to the scheme administrator, Exchange for Change, for registration as a takeback service provider and should contact them to discuss. They will either grant your application or refuse it. You need to be registered as a takeback service provider with the scheme administrator to provide a takeback service.

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 transports waste on a professional basis, e.g. a takeback service provider should ensure that they, or their service provider, are authorised to transport waste.

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 articles as part of their takeback service is responsible for ensuring that they are a registered transporter. Check our registered waste transporters list for of details of currently registered waste transporters, brokers or dealers.

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.