Deposit Return Schemes (#DRS)- an area we are well familiar with at Fieldfisher, having advised a large number of drinks clients on this turbulent road!
Some points for all UK drinks businesses to note (hot off yesterday’s policy statement)…
💡There will be three DRSs in the UK (one in England and Northern Ireland, one in Wales and one in Scotland) with (potentially) separate deposit management organisations, but maximum alignment and interoperability between the three
💡What that looks like in practice is still not 💯 unclear, but we’re expecting:
💡All DRSs to include drinks containers made of PET, steel and aluminium cans. The position on glass will be set out separately.
💡All to include drinks containers of 150ml to 3 litres. Outside of this you’ll be caught by Extended Producer Responsibility for packaging (packaging EPR).
💡A single registration and reporting process across all DRSs
💡A single DRS logo across the UK and a single deposit level
You’ve still got time to prepare (it kicks in from Oct 2027) but you need a long lead time (we know this from our experience on the Scottish and Irish DRS!).
We’ve got lots more insights to share so get in touch if you’re looking for a steer.
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