Check whether the scheme covers your shop
This guide covers England and Northern Ireland, where the Deposit Scheme for Drinks Containers (England and Northern Ireland) Regulations 2025 apply. Wales and Scotland have their own laws. Read the Wales and Scotland sections near the end if you trade there.
The scheme starts on 1 October 2027. Its status is confirmed, because the regulations set it. Exchange for Change, the deposit management organisation (DMO), runs the scheme for England and Northern Ireland.
You must run a return point if you are a groceries retailer, unless you are exempt. That means a supermarket of any size, a grocery store, a convenience store or a newsagent, selling drinks in scope of the scheme. Pubs, restaurants, cafes and takeaways do not have to run a return point, but every seller must charge the deposit on takeaway and shop sales. Sellers of drinks for consumption on the premises may opt out, as explained below.
Check the transition rules before you stock up. Filled containers made before the start date fall outside the scheme. The DMO has not confirmed what happens to empty packaging ordered before launch, so ask your supplier.
Work out whether you must run a return point
A return point takes back empty in-scope containers from customers and refunds the deposit. It can be a manual counter or a reverse vending machine. It must be at your premises or on adjacent customer car park premises.
Check whether your shop is exempt
A groceries retailer in an urban area with a small enough shop floor is exempt automatically. You do not need the DMO to approve it, and you need to register only if you want to run a voluntary return point. The table shows the exemption in the regulations (in force from 1 October 2027) and the wider bands the DMO announced in June 2026.
Only the automatic exemption is in the regulations. The wider bands are announced DMO criteria, not law, and the application route is not yet published. Do not assume your shop qualifies for them. Shops in those bands must still register.
Even if you are exempt, you must still charge the deposit on in-scope drinks you sell and display the notice that tells customers where the nearest return point is. The DMO offers a postcode lookup for the urban test. It is general guidance only. If your shop is near a boundary, ask the Environment Agency in England or the Northern Ireland Environment Agency in Northern Ireland.
Environmental rules for shops sit across several regimes. See environmental obligations for retailers for packaging, waste electrical equipment and carrier bag duties alongside this scheme.
Register with Exchange for Change
Retailers who must run a return point need to register with the DMO. Registration has 2 phases and you must complete both. Work through these steps in order:
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1. Confirm you are a groceries retailer that sells in-scope drinks
Check the container types and sizes in the scope table above. If you are unsure whether your products are in scope, check the DMO FAQs.
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2. Check your postcode and measure your retail space
Use the DMO postcode lookup, then compare your retail space with the exemption table. Keep your measurements in case you need them for an exemption application.
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3. Complete Phase 1 registration now
Phase 1 is open. Register your business on the Exchange for Change registration portal. You receive a reference number when you submit.
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4. Complete Phase 2 when it opens
Phase 2 asks for further detail about your role. The DMO has announced January 2027 but has not given a day.
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5. Apply for an exemption if you want one
The DMO has not yet published the application process for exemptions beyond the automatic one. Check its website for the route and the evidence it asks for. An exemption can rest on proximity to another return point or on your premises.
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6. Choose manual take-back or a reverse vending machine
Plan where you will store returned containers for collection and how you will refund customers by voucher, card or cash.
Plan for fees and support
The DMO pays return point operators a handling fee for each container returned. The fee differs for manual and automatic return points. It has been announced but not finalised, because the DMO says it will review it before the scheme starts.
Pubs, cafes, restaurants and takeaways
You do not have to run a return point or register as a return point operator. You do have to charge the deposit on in-scope drinks you sell, unless you choose the on-premises opt-out. Takeaway sales always carry the deposit.
If you serve food and drink for eating in and also sell takeaway, you can charge the deposit on takeaway drinks only. If you opt out, the regulations require you to display opt-out information (regulation 29). GOV.UK and the DMO also say you should keep the empty containers on your premises for the DMO to collect. That storage advice is guidance, not a requirement in the regulations.
Online sellers must charge the deposit as well.
VAT on deposits
You do not charge VAT on the deposit at the till. HM Revenue and Customs (HMRC) has published a draft change for unreturned deposits, but it is not law.
Penalties for getting it wrong
The Environment Agency and Trading Standards enforce the rules in England. The Northern Ireland Environment Agency enforces them in Northern Ireland. Fixed penalties apply once the duties are in force.
England
Everything above applies in England. The Environment Agency and Trading Standards enforce the regulations. "Urban" has the meaning given by the Office for National Statistics 2011 rural urban classification of output areas.
Northern Ireland
The same regulations apply. The Northern Ireland Environment Agency enforces them, and "urban" follows the Northern Ireland Statistics and Research Agency Urban-Rural Classification 2015.
Wales
Wales has its own regulations, so the registration steps and exemptions above do not apply there as written. The Welsh rules are in the Deposit Scheme for Drinks Containers (Wales) Regulations 2026. Glass is in scope in Wales. The Welsh Government did not approve Exchange for Change as the Welsh administrator in April 2026, so the Welsh registration route may differ from the one in this guide.
This guide does not set out Welsh retailer duties in full. Check with the Welsh Government before you act.
Scotland
Scotland has its own scheme law, so the steps above do not apply there as written. This guide does not set out Scottish retailer duties. Check with the Scottish Government before you act.
If you also make, import or fill drinks
Producers have separate duties. Brand owners, importers and anyone who fills containers to order must register as producers, apply and pay deposits, label containers and report the containers they place on the market. Read packaging producer responsibility and packaging waste compliance for the wider packaging rules.
For other duties under the Environment Act 2021, see Environment Act 2021 compliance.
What to do next
Work through these steps in order.
- Decide whether you are a groceries retailer that sells in-scope drinks.
- Check your postcode and shop size against the exemption table.
- Register on the Exchange for Change portal, because Phase 1 is open now.
- Note when Phase 2 registration opens.
- Check the DMO website for the exemption application route and the handling fee review.
Who to ask
Start with Exchange for Change, the DMO, for registration, return points and exemptions. Ask the Environment Agency or your local Trading Standards team in England, or the Northern Ireland Environment Agency in Northern Ireland, about enforcement and boundary cases. Ask HMRC about VAT. Your trade association may also have guidance for your sector.
Legal basis
Primary legislation and key regulations
Official guidance
Exchange for Change: register your business (opens in a new tab)
Exchange for Change
Exchange for Change: frequently asked questions (opens in a new tab)
Exchange for Change
Exchange for Change: postcode lookup for exemptions (opens in a new tab)
Exchange for Change
Exchange for Change: registration opens (29 September 2026) (opens in a new tab)
Exchange for Change
GOV.UK: Deposit return scheme, drinks producer and retailer responsibilities (last updated 30 January 2025) (opens in a new tab)
GOV.UK
HMRC: VAT provisions for drink deposit return schemes (opens in a new tab)
GOV.UK
Deposit Scheme for Drinks Containers (England and Northern Ireland) Regulations 2025, Schedule 2 (registration) (opens in a new tab)
legislation.gov.uk
Deposit Scheme for Drinks Containers (England and Northern Ireland) Regulations 2025, regulation 35 (small urban shops) (opens in a new tab)
legislation.gov.uk
Welsh Government: written statement on the Deposit Scheme for Drinks Containers (Wales) Regulations 2026 (opens in a new tab)
Welsh Government
Scottish Government: deposit return scheme (opens in a new tab)
Scottish Government