Producer registration is expected to open in October 2026. For drinks producers and importers, that should not be treated as a simple administrative step.
Producer registration is not the same as product registration. Existing in-scope products must be registered no later than 12 weeks before go-live, by 9 July 2027. However, the information, ownership, and decisions needed for areas like producer registration, product registration, reporting, fee modelling, and customer planning are all connected.
The risk is not that producers are unaware of the Deposit Return Scheme (DRS). Most know the scheme is coming. The greater risk is false confidence: assuming key questions are understood, owned, or under control when they have not been tested across the business.
Which DRS Assumptions Should Producers Test Before Registration?
With producer registration expected to open in a matter of months, businesses now have a clearer milestone against which to assess their DRS readiness. Registration will be managed by Exchange for Change, the UK deposit management organisation (DMO) for England, Scotland, and Northern Ireland.
Several DRS assumptions may appear reasonable at first glance, but each can conceal gaps in ownership, data, planning, or cross-functional alignment. Testing them early gives producers and importers more time to resolve issues before registration deadlines begin to drive decisions.
1. “We have someone owning DRS”
Having someone close to DRS is not the same as having clear business ownership. DRS cuts across multiple areas of a producer’s business, including:
- Finance
- Commercial
- Supply chain
- Packaging
- Data and systems
- Technical and regulatory
- Customer/route-to-market planning
One function may coordinate activity, but that does not mean it has the authority to make decisions across the business. The assumption to test is whether the DRS programme has an executive owner with enough authority to resolve trade-offs involving cost, customer treatment, data, packaging, systems, and timing.
If ownership is too narrow, decisions may sit between teams until they become urgent.
2. “Producer registration will be a simple admin step”
Producer registration may look like an administrative milestone, but it should not be treated as a form-filling exercise. It should prompt producers to test whether they have the evidence, ownership, reliable data, and internal sign-off needed to support scheme participation.
The issue is not only whether a form can be completed, but whether the business understands the assumptions behind the information being submitted and the implications for the next stages of DRS readiness.
If those assumptions are unclear, producer registration may expose wider gaps in ownership, data, and decision-making.
3. “Product registration can be dealt with later”
Producer registration and product registration are connected, but they are not the same thing. Existing in-scope products have a later registration deadline, but producers should not treat that as a reason to delay preparation.
The assumption to test is whether the business already has a reliable view of product scope, pack formats, container information, barcodes, and internal ownership. They also need to understand how each product and container will be identified through its packaging and registered barcode. If that information is incomplete, inconsistent, or spread across several teams and systems, product registration may take longer to prepare than expected.
4. “We know which drinks containers are in scope”
Most producers will have a broad view of which single-use drinks containers are likely to be in scope and how empty drinks containers will move through the return system. That is not enough.
The question is whether finance, commercial, technical, supply chain, and data teams are working from the same view of the drinks containers covered by the scheme. Seasonal products, limited editions, multipacks, imported brands, co-packed products, promotional formats, and price-marked packs can all create uncertainty.
If product scope is not agreed across the business, the same issue can affect reporting, fee modelling, packaging decisions, customer planning, and stock transition.
5. “Our product data is good enough”
Many businesses have product data. Fewer have a single reliable version of that data that all relevant teams trust. Product information may sit in commercial records, technical specifications, packaging files, finance systems, and supply chain data. Those records may not always match.
The question is not simply whether the data exists. It is whether the business knows which version is correct, who owns it, and whether it is reliable enough to support product registration, reporting, and financial controls.
If the data cannot be trusted, the business may struggle to move from broad DRS planning into reliable execution.
6. “Imported products are already covered”
Imported products can create specific DRS readiness risks. Businesses that import and sell drinks in the UK may still depend on overseas brand owners, bottlers, co-packers, distributors, or packaging suppliers for key product information.
The assumption to test in this area is whether the business knows who holds the required information, who is responsible for providing it, and how quickly it can be obtained. If those roles are unclear, imported products can become a source of last-minute delays.
7. “Packaging and barcode decisions are technical details”
Packaging and barcode decisions for in-scope containers are often treated as technical, artwork, or operational issues. Under DRS, however, they can affect product identification, reporting, production planning, customer communication, and stock transition.
The assumption to test is whether existing packaging and barcode structures have been reviewed early enough to identify decisions that could affect timing. This does not mean every producer will need major changes. However, if decisions are needed, late discovery can compress supplier, artwork, production, and customer timelines.
8. “Finance and commercial teams are working from the same numbers”
The producer fee and deposit will create new financial and operational flows that need to be understood against actual stock-keeping units, volumes, customers, and routes to market.
Finance may be modelling one set of assumptions. Commercial teams may be basing customer discussions on a different set of figures. Supply chain may hold a different view of pack formats, stock movement, or launch timing.
The assumption to test is whether finance, commercial, and supply chain teams are working from the same product and volume base. Without that alignment, the business may have a headline cost view but lack confidence in margin, pricing, reporting, cash flow, and reconciliation.
9. “There is still plenty of time”
The biggest assumption for producers may be timing. Several areas are connected:
- Producer registration
- Product registration
- Fee modelling
- Deposit handling
- Reporting
- Packaging decisions
- Customer planning
- Stock transition
If there is a delay in any one of these areas, pressure can quickly build elsewhere. The question is not whether the UK DRS go-live date feels distant. It is whether the business has enough time to test assumptions, resolve ownership, align data, prepare customer answers, and sequence the work before formal deadlines start to drive decisions.
Businesses that wait for registration to expose these issues may have less room to resolve them properly.
Producer Registration Should Test Assumptions, Not Expose Them
With producer registration expected to open in October 2026, the preparation window is narrowing for producers and importers. They should not wait for the registration process to reveal whether their key assumptions are reliable. Before registration opens, they should be able to answer questions such as:
- Do we have the right executive owner?
- Is producer registration being treated as more than administration?
- Are we clear on the difference between producer and product registration?
- Do we know which products are in scope?
- Is our product data reliable enough?
- Are imported products clearly owned?
- Have packaging and barcode assumptions been tested?
- Are finance and commercial teams working from the same numbers?
- Have we sequenced the work before registration opens?
The producers in the strongest position will test these assumptions before registration begins rather than wait for the process to expose them.
Prepare for DRS Producer Registration With Confidence
DRS International helps producers and importers test the assumptions behind UK DRS readiness, identify where ownership or data is unclear, and prioritise the finance, packaging, commercial, and implementation decisions that need attention before producer registration begins.
Speak to DRS International today to test your assumptions, clarify ownership, and prepare for producer registration with greater confidence.