Deposit Return Schemes: What hospitality businesses need to know across England, Scotland and Wales
Deposit Return Schemes (DRS) are moving from policy debate to operational reality. From October 2027, aligned schemes in England, Scotland and Northern Ireland will introduce deposits on certain single use drinks containers, with Wales taking a different approach. For hospitality venues, the key question is not whether DRS applies, but how to work with it without disrupting service, margins or customer experience.
Usually, no. Where drinks are sold for consumption on the premises, for example in pubs, restaurants, hotels and bars, hospitality venues can operate what’s called a closed loop system. That means the venue manages empty containers internally and does not need to charge the customer a deposit at the till. This is a deliberate policy choice recognising that hospitality is not retail. Empty containers remain on site, so there is no consumer return to manage and no cash handling at the bar. However, where a venue sells takeaway or packaged drinks (for example bottled soft drinks from a café fridge), different rules may apply and operators should consider what’s best for their business in terms of whether to charge deposits or absorb them depending on the sales model.
No. Across England and Scotland, hospitality venues are not required to host public return points. They may choose to do so voluntarily, but there is no obligation to accept containers they did not sell. This removes one of the biggest practical and space‑related concerns for the sector.
In England and Scotland, the DRS applies to single use PET plastic bottles and aluminium or steel cans between 150ml and 3 litres. Glass is excluded from the aligned England–Scotland scheme but will be part of the Wales scheme. For hospitality operators, this means that beer cans, soft drink bottles and water bottles are typically in scope, while non glass wine and spirit bottles are not, at least outside Wales.
For most venues, DRS will be a back of house issue, not a front of house one. Practical steps include:
- Ensuring drinks are sourced from registered producers
- Segregating in scope containers behind the scenes
- Aligning waste contracts so containers are collected appropriately
Training staff to answer customer questions accurately and confidently.
Early planning is particularly important for multi site operators, where consistency across locations will reduce training and compliance risk.
- Re use complexity
Reusable glass systems require reverse logistics, storage space and cleaning infrastructure, features that many hospitality venues, especially smaller sites, simply do not have. - Cross border and national brand issues
Businesses operating across England, Wales and Scotland may face different labelling, storage and handling rules for the same product, increasing cost and operational risk. - Glass and fraud risk
Industry groups have warned that a Wales only glass deposit risks cross border fraud, with containers purchased in one nation returned in another, particularly if deposits or scope differ. Estimates of potential fraud run into hundreds of millions of pounds. - Customer confusion
Different rules on what can be returned and where risk undermining consumer confidence and increasing front of house friction, particularly in tourist areas and border regions.
The takeaway for hospitality operators
For England and Scotland, the message is broadly positive: hospitality has been heard and the schemes are designed to work around how venues actually operate. Wales remains more complex, particularly for national brands and glass heavy operators.
The smartest hospitality businesses are already mapping their drink formats, supply chains and waste flows, so that when DRS arrives, it feels like a controlled adjustment rather than a last minute scramble.
What should hospitality businesses be doing now?
- Map which drinks are sold on site vs takeaway
- Decide when deposits will (and won’t) be charged
- Align waste contracts and storage practices
- Train staff on how to explain DRS confidently to guests
- Monitor Welsh developments closely if you operate cross border
Please contact Kirstin Roberts if you have any questions or for further information.
The content of this page is a summary of the law in force at the date of publication and is not exhaustive, nor does it contain definitive advice. Specialist legal advice should be sought in relation to any queries that may arise.
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