Too many drinks producers are still looking at the UK Deposit Return Scheme through the wrong lens. They see packaging change, compliance obligations, and regulatory updates as issues to monitor until more operating detail emerges.
However, this outlook is exactly how businesses will get caught out.
The UK Deposit Return Scheme is more than a regulation to comply with. It is a business change programme that will need to work across finance, commercial, marketing, supply chain, IT, data, compliance, customer arrangements, and governance. By the time some organisations realise that, though, they are already under pressure.
For producers, the Deposit Return Scheme will change far more than what appears on the packaging. It can affect product scope, producer obligations, reporting, data quality, reconciliation design, pricing, customer treatment, internal controls, and cross-functional ownership. It can introduce new cost lines, new process requirements, and new dependencies across teams that do not always work closely together today.
In this post, DRS International’s consultant, George, will share his insights on why the Deposit Return Scheme should be effectively managed early by producers and what risks they should be mindful of.
The Risk of Underestimating the Deposit Return Scheme
Most producers know that the Deposit Return Scheme is heading their way. Current policy is for the scheme to launch in October 2027 in England, Northern Ireland, and Scotland, with Exchange For Change appointed to deliver it. Wales is pursuing its own scheme alongside this rather than the same fully aligned model, with plans to include glass.
In England, Northern Ireland, and Scotland, the scheme targets specific in-scope containers. This includes single-use PET plastic bottles, steel cans, and aluminium cans from 150ml to 3 litres.
Although the scheme’s date appears set in stone, the real problem is that many producers still underestimate what implementation will entail. George believes that, “Most producers assume the Deposit Return Scheme is mainly a packaging or compliance issue, but in reality, it’s a much broader business change programme, with consequences across multiple functions.”
Simple in Policy, Hard in Practice
On paper, the Deposit Return Scheme can look relatively straightforward for producers. The mechanics are intended to be simple: in-scope containers carry a refundable deposit from October 2027, and Exchange For Change will oversee scheme operations. This looks to include setting the deposit amount and working alongside stakeholders and partners to develop the return point network.
However, some complexities emerge when businesses try to make the scheme work operationally. They need to understand which products are in scope, how responsibilities apply to their routes to market, what data and reporting capability they need, how internal controls and reconciliations will work, and how customer-facing processes may need to change. Some of that work can begin now.
Product scope sounds manageable until portfolio complexity, pack formats, customer channels, and product data quality are tested. Reporting sounds straightforward until questions emerge around ownership, system capability, and data quality. Deposit flows can look easy in theory – until finance, commercial, and customer teams have to make them work in practice.
Many of the biggest producer risks do not sit in the headline regulation itself. They appear when businesses try to turn that regulation into daily operations.
Why Producers Get Caught Out With the Deposit Return Scheme
For producers, the biggest risks are often not about whether they have read the DRS regulations, but how they plan to implement them across the business:
They Underestimate the Scope of the Deposit Return Scheme
The Deposit Return Scheme is treated as though it belongs to one team or one workstream, instead of being recognised as a cross-business operational change.
DRS can require decisions across product master data, reporting, controls, finance process design, customer arrangements, artwork and labelling, internal governance, and implementation ownership. These do not sit neatly inside one function.
Ownership Falls Apart
This scheme has wide-reaching ramifications across organisations. Finance, IT, supply chain, commercial, and customer-facing teams are all affected. However, many businesses still have no unified structure in place to coordinate the decisions between these areas.
What is often misunderstood is that weak ownership creates indirect commercial and operational risk. Responsibilities become blurred. Dependencies are missed. Key assumptions are made in silos. Rework follows.
False Confidence
October 2027 still sounds far enough away that some organisations believe they can wait for more detail before acting. Unfortunately, that is where delay creates risk. Government guidance already provides enough information for businesses to begin internal scoping and mobilisation.
By the time every detail is confirmed by Exchange For Change, the real work still has to be done. That means having:
- Systems reviewed
- Data assessed
- Ownership clarified
- Processes redesigned
- Financial exposure understood
- Customer impacts worked through
The longer that practical work is delayed, the narrower the runway becomes for producers. So, although the rollout isn’t for more than a year, it is prudent for producers to start preparing for the scheme now.
Waiting May Seem Smart, But It Invites Risk
One of the biggest mistakes producers can make now is assuming there is not enough certainty to start. Although not every final detail is known about the UK DRS, there is enough to start planning. George highlighted his concerns that many producers are waiting too long to start the process, saying:
“The biggest problem I see for producers is waiting for the finite detail from Exchange For Change on the regulations.
With October 2027 on the horizon, it’s actually a short time period to apply those required changes, and every day of delay increases the risk of rework and additional cost.”
Scheme-wide, not every detail is final. Deposit levels, some operational rules, and detailed guidance still sit with Exchange For Change. That uncertainty is real and should not be glossed over.
However, producers can already identify in-scope products (such as single use drinks containers), assess likely functional impacts, review systems readiness, map deposit and data flows, understand financial exposure, and start building internal ownership.
Ideally, this should already be under way. You shouldn’t be waiting for absolute clarity, as it may not arrive early enough to help. Organisations that delay in the name of caution often end up creating the very problems they were trying to avoid: rushed decisions, late rework, duplicated effort, and unnecessary cost.
The most credible first step is not to jump to detailed design before the final detail is available. It is to understand where the business is already exposed, where readiness gaps may exist, and which decisions need leadership attention sooner rather than later.
The Deposit Return Scheme Isn’t Tied to a Single Function
One of the most damaging assumptions producers can make is treating DRS as a packaging or compliance issue. That misses the true impact of the scheme.
Every Function Feels the Impact
DRS can create exposure across multiple functions:
- Finance has to deal with producer fees, reporting implications, reconciliation, controls, cash flow, and working capital.
- IT has to support master data, reporting, and systems change.
- The supply chain has to handle pack transition issues, inventory implications and implementation disruption risk.
- Commercial teams have to consider pricing, customer terms, and market execution.
- Marketing has a role in both pack change and external communication.
- Customer-facing teams will need to explain the implications to wholesalers, retailers, and hospitality customers.
The Hard Part is Effective Coordination
The biggest issue for producers isn’t that these impacts are invisible or difficult to understand. The more pressing concern is finding a way to provide each function in the organisation with the whole picture.
DRS implementation needs to be treated as a coordinated change programme; without that approach, gaps and problems appear fast.
Ownership around things like in-scope drink containers becomes unclear, dependencies get missed, decisions are made in silos, and costs rise. From there, pressure builds, and businesses can quickly realise that the scheme’s effects are far larger than they first assumed.
The Hidden Costs Are Often Internal
A lot of attention goes to visible scheme costs, but much less towards the costs of getting ready for the Deposit Return Scheme.
That can be a costly mistake, as the hidden costs are often the internal efforts required to implement it properly. This includes:
- Systems changes
- Data work
- Pack transitions
- Project management
- Cross-functional coordination
- Internal resourcing
- Control design
- Manual workarounds
These are the costs businesses often fail to model early enough.
Bringing Finance and IT in Late Causes the Risks to Climb Fast
Finance is often involved too late to shape the operating model properly. This leads to businesses underestimating not just fee exposure, but the wider operating model implications for controls, reporting, reconciliation and cash handling logic.
A similar argument can be made for IT and data teams, who are often brought in after key commercial or regulatory assumptions have already been made. This is often when reporting weaknesses, reconciliation problems, and manual burdens start to surface.
The reality is that the cost of the Deposit Return Scheme is much more than the external scheme cost. In many instances, the true costs also stem from underpreparing for its implementation.
Internal Misalignment Is a Huge Risk That Is Rarely Discussed
A lot of conversation around this scheme still centres on regulation and deadlines. Although these aspects of the Deposit Return Scheme are important, it usually isn’t the most prominent issue to focus on. One of the biggest operational risks is much less visible: poor alignment across the business.
Problems Emerge Before Going Live
The organisations that struggle most are not always the ones that misunderstand the regulation. In many cases, it will be the ones that fail to align internally early enough.
This can happen in many different ways. One team assumes another team owns a decision, or data dependencies go unnoticed. There may be commercial implications that are factored in too late. Or, customer messaging begins drifting away from what operations can actually deliver.
It could be that governance stays vague until deadlines force action. By then, though, the business is no longer planning well – it is reacting.
Consequences That Extend Beyond Internal Inefficiency
Poor alignment on DRS implementation doesn’t just create confusion and a need to rework things internally. It can do much more damage, from harming customer communication and weakening confidence to increasing the risk of disruption close to implementation.
George shares this outlook, highlighting that, “The real challenge is not just understanding the scheme. It is getting the business ready to operate within it.”
Experience in Execution Matters
Bridging the gap between policy and operational delivery is no easy feat. Although public guidance, trade bodies, and internal teams have their role in this process, it doesn’t outright close the execution gap for producers. That means many producers still have to do the hard work of translating a developing external framework into an internal operating model.
Guiding Successful Delivery With Expertise
Organisations looking to succeed in the scheme’s framework need to think practically about implementation. Understanding where the real impacts will land, what decisions need to happen first, which dependencies matter most, and how to move from awareness to readiness can make all the difference.
That is where DRS International comes in. The expertise on offer from DRS International extends beyond repeating regulations back to producers. Instead, it is about helping businesses understand the regulation and translate it into tangible operational change.
From Regulation to Workable Operations
Implementing this operational change is all about identifying where the real business impacts sit. DRS International offers consultancy and IT solutions to ensure: GK – these links will have to be updated to also capture DRS International producer service offer.
- Functions neatly align
- Priorities are clear
- Risks are identified early
- Support is implemented before problems become expensive to fix
The Strongest Producers Will Be the Ones That Move Early
The producers in the best position will not be the ones waiting for absolute clarity from Exchange For Change. Instead, they will be the ones who recognise, from an early stage, that the UK Deposit Return Scheme is not a policy issue to park with one team until the final detail arrives.
Instead, it must be seen as a new operational reality with consequences across finance, IT, supply chain, commercial, marketing, supply chain, customer functions, and governance. That does not mean acting on assumptions that are not yet settled. It means doing the work that is already justified, while remaining disciplined about what is still evolving.
As George says, “The moment producers usually realise they’re in trouble is when they stop talking about the regulation in theory and start planning for how the scheme will actually work across their business.”
The organisations that leave that planning too late are the ones most likely to face avoidable pressure.
Get Ready for the UK Deposit Return Scheme with Professional Guidance
The upcoming UK DRS should not be left to the last minute or ignored by producers. If your business is still treating this scheme as a compliance task, now is the time to rethink that approach.
DRS International helps businesses assess readiness, align functions, and prepare for implementation before delays turn into disruption.
Get in touch with the team at DRS International today to assess your readiness, identify operational risks early, and build a practical implementation plan.