With the UK Deposit Return Scheme (DRS) due to go live on 1 October 2027, drinks producers and importers should already be planning and preparing for the upcoming changes. One of the first readiness milestones will be producer registration, which is expected to open ahead of the scheme launch.
Producers and importers will have to register as scheme participants and provide product information for any in-scope drinks containers before they can be placed on the market under UK DRS. Registration will test whether producers understand their product portfolios, packaging formats, barcode structures, and product data well enough to support the scheme.
For many businesses, the challenge won’t be registration but the work required to answer the questions behind it. To help you prepare, this article will take a closer look at UK DRS registration to show why product, packaging, and data readiness are key to successful DRS implementation.
Treating DRS Registration as a Readiness Test
Producer registration is one of the first major milestones on the road to successful UK DRS implementation. While it is a regulatory requirement, it is also an opportunity for businesses to understand how prepared they really are.
Registration brings together product information, packaging, barcodes, and data in a way that many organisations have never needed before. As a result, it often highlights issues that have remained hidden across different parts of the business.
Registration reveals practical DRS readiness
Registration for DRS will bring product-level information into sharper focus. From this view, the real readiness test will be whether producers and importers can provide accurate information on in-scope drinks containers, packaging formats, barcodes, and product data.
For producers and importers, this means having a clear and accurate view of the products they place on the market, from scheme scope and market responsibility through to product identification, deposit return scheme packaging format, and the quality of the data held internally. This is where issues can start to emerge.
For example, a product may be recorded one way in commercial systems and another in supply chain or finance systems. For imported products, responsibility may also be unclear, particularly where information sits across an overseas brand owner, bottler, distributor and UK importer.
Although registration does not create these issues, it does a very good job of exposing them.
Understanding which drinks containers are in scope
UK DRS covers a defined range of drinks containers, meaning it only applies to in-scope containers. The scheme covers any single-use drinks container made wholly or mainly from PET plastic, steel, or aluminium, between 150 ml and 3 litres. This includes PET bottles and aluminium cans, but not glass containers for England, Scotland, and Northern Ireland.
Wales has taken a different position on scheme scope by including glass bottles. This article focuses on producer readiness for the DRS being implemented across England, Scotland and Northern Ireland through Exchange for Change. Producers placing products on the Welsh market should continue to monitor Welsh Government requirements and any interoperability arrangements as the Welsh scheme details develop.
For producers and importers with relatively simple portfolios, identifying in-scope products should be relatively straightforward. For others, this exercise can quickly become more complex, which is why understanding producer responsibilities early is an important part of DRS preparation. This is especially the case when identifying:
- Large product ranges
- Seasonal lines
- Limited edition runs
- Co-packed products
- Imported brands
- Multipacks
- International stock-keeping units (SKUs)
Producers need to review these drinks containers carefully to confirm whether they fall within the scope of UK DRS. Just as importantly, they need to understand what that decision means for packaging, barcodes, data, suppliers, and stock transition.
Where DRS Readiness Becomes More Complex
For many producers, understanding which products are in scope is only the beginning. The practical work of preparing those products for DRS can become much more complex depending on how portfolios are managed, how products are packaged, and where key information is held.
Imported products and international SKUs need early review
Imported drinks need early attention because they can create uncertainty around responsibility and information ownership. A UK importer may be responsible for placing a product on the market, while the registration data sits with an overseas brand owner, bottler, distributor, or co-packer. Without early clarity, producers can lose valuable preparation time before work on packaging, barcodes and product data begins.
International SKUs can add further complexity to this. Cross-market packaging may reduce costs and avoid UK-specific packs, but UK DRS regulations may challenge that approach. Packs designed for several markets may still need review against UK requirements for product identification, scheme labelling requirements, registration, and reporting. The key question is whether they can move through the DRS system without late changes, reporting issues, or operational disruption.
Packaging readiness is more than artwork
Packaging is usually the most visible aspect of DRS preparation, but it is much more than a late-stage artwork brief. Exchange for Change, the UK deposit management organisation, has already published material specifications to support industry readiness, giving producers a basis for reviewing packaging formats, product identification, and practical implementation requirements.
This is important, as packaging decisions are tied to other areas of the business, such as:
- Barcode strategy
- Registration
- Supplier lead times
- Internal approvals
- Production planning
- Customer communication
- Stock transition
If producers wait too long to identify these dependencies, then the risk of rework grows. This also rings true for seasonal and low-volume products. Even if these products do not represent a large share of sales, they can still create pressure if packaging, testing, barcodes, or data questions are left unanswered until close to launch.
Barcode strategy is important for drinks producers
Successful DRS implementation relies on correctly identifying in-scope products, making barcode strategy a core part of readiness. Barcodes allow empty containers to be recognised, registered and processed through the scheme, whether they are returned through a reverse vending machine or another approved return point.
All barcodes used for in-scope products must be compliant with GS1 General Specifications, or an equivalent standard, and unique to the individual product. However, complexity can build quickly where producers use shared barcodes that were not designed with DRS in mind. Barcode decisions for manufacturing efficiency may not automatically support DRS registration, identification and reporting.
Producers therefore need to understand whether existing product identification structures will be suitable for UK DRS, or whether UK-specific packaging changes may be required. Reviewing this early gives businesses more time to make decisions without adding pressure to artwork, production, and stock planning.
Product data can become a registration bottleneck
Packaging changes are visible; data issues, however, are much less obvious until they affect registration, reporting, or reconciliation in DRS.
DRS registration will rely on accurate product information, from material type, container size, and barcode through to pack format and market responsibility. In many organisations, this information exists across several systems or teams, including commercial records, technical specifications, packaging files, finance systems, and supply chain data.
When those records do not align, delays can quickly build. To avoid this and ensure operational readiness for DRS, data reviews are an important part of the process.
What Producers and Importers Should Review Now for DRS
Producers and importers do not need every final detail of DRS before they begin preparing. Waiting for complete certainty may only slow down readiness, especially when enough information is already available to identify where risks may be building. Areas to review now include:
- Product scope
- Packaging readiness
- Data quality
- Governance
- Delivery planning
This early review can help producers identify where action may be needed before registration brings these issues into sharper focus.
DRS Readiness Needs Clear Ownership
Identifying the work is only part of the challenge. Delivering it requires coordination across multiple teams, each with different responsibilities and timelines.
Late planning creates wider business risk
DRS readiness is often discussed as a packaging and compliance concern, but the operational impact is wider than that, as delays can quickly move between teams.
Packaging may depend on product data, data may depend on commercial decisions, and supply chain planning may depend on supplier confirmation. At the same time, finance teams need visibility of deposit values, producer fees, controls, and reconciliation processes before the wider business can prepare with confidence.
If these dependencies are not managed early, delays can quickly shift from one part of the business to another. The result is a compressed implementation window, where rework becomes harder to avoid, packaging changes arrive late, stock transition becomes more difficult, and customer communication is left under pressure.
Delays rarely remain confined to compliance teams. They can affect packaging availability, production scheduling, customer commitments, working capital, and launch plans. Businesses that identify these dependencies early will have greater flexibility to manage implementation without unnecessary disruption.
Clear ownership is needed before registration opens
DRS is a wide-reaching programme that cuts across many areas of the business, from technical and IT teams to supply chain, finance, and compliance departments. There is no single function that can resolve all of the questions DRS creates, so it needs to be viewed holistically.
Producers and importers need clear ownership of the entire readiness programme, as well as defined responsibilities for the individual workstreams that sit beneath it. Without this, businesses risk duplication, delay, and late decision-making.
Those best placed for UK DRS will be those taking action with the information currently available. By being proactive, producers can understand where practical risks lie and what needs to be addressed. Those that wait for every remaining detail may find themselves working within compressed timelines, with less room to resolve issues before launch.
Operational Lessons From Live DRS Programmes
Experience from Ireland’s live Deposit Return Scheme and Romania’s implementation points to a consistent lesson: product, packaging, and data decisions often take longer than expected.
The scale of live schemes shows why these decisions matter. Ireland’s scheme successfully improved recycling rates, recording more than 2.5 billion returned cans and bottles since launch, including more than 1.4 billion in 2025 alone. Romania’s scheme reached a nationwide collection rate of 83% in 2025, with more than 5.2 billion containers returned in that year alone.
Behind those figures are thousands of practical decisions around product identification, packaging, data, reporting, logistics, and stakeholder coordination. The work is detailed, involves multiple teams, depends on external partners, and can reveal assumptions that have never previously been tested.
That is why early preparation is important. Registration may be a formal milestone, but readiness has to start before that point. Producers and importers that review product scope, packaging, barcodes, data, and internal ownership now will be better placed to manage the transition to UK DRS with greater control and fewer avoidable surprises.
DRS Readiness Starts Before Registration
DRS registration will bring product, packaging, barcode, and data questions into sharper focus. The producers and importers best placed to manage that process will be those that have already tested their readiness before registration begins.
That means understanding which products are in scope, where responsibility lies, whether existing packaging and barcodes are suitable, and whether product data is complete enough to support registration and reporting. The more of this work that is done now, the easier it will be to identify issues early, manage decisions across the business, and reduce avoidable pressure as UK DRS implementation moves closer.
If your organisation has not yet tested its readiness across product scope, packaging, barcodes, data and internal ownership, now is the time to do so.
Contact DRS International to discuss a scheme readiness review and identify where action may be needed before UK DRS registration brings these issues into sharper focus.