Is the UK DRS really united across all four nations?

Now united? At last, the UK DRS will be managed by one organisation. On 24 August, the Welsh Government announced that Exchange for Change (EfC), the Deposit Management Organisation (DMO) formed to manage the DRS for England, Northern Ireland and Scotland, had been appointed to manage the Welsh DRS. This brings all four UK nations under one DRS operator and was essential to get the UK DRS over the line – albeit very late in the day. Having separate DMOs across the four nations was inconceivable. In many ways the selection of EfC for the Wales DRS was inevitable, though that perceived inevitability almost cost the DRS. The appointment follows the rejection of EfC's initial bid by the Welsh Government, reportedly on the basis that they did not adequately address the Welsh Government's ambitions on glass recycling and reuse. Many have expressed their view that EfC believed it was the only option open to the Welsh Government and that their initial proposal was dripping with complacency. Who knows? At any rate, the recent appointment of EfC for Wales is excellent news for those supporting a UK-wide DRS. Wales will include glass in its scheme unlike the other UK nations. Now that EfC has their hands on the reins, it is full speed ahead to try to launch the world's biggest DRS by October 1 2027. Even if this timing slips (to Q1 2028), it will still be a hugely challenging undertaking. So, we have a common DRS across the UK now? Well, not quite! The Welsh legislation includes glass in its own DRS, while glass was excluded from the schemes' scope in England, N. Ireland and Scotland. However, as a compromise to secure agreement with the UK Government (to agree not to use the Internal Markets Act to prevent Wales doing something different in their DRS to the rest of the UK, as they did to Scotland), glass bottles included within the scheme will not require labelling nor carry a deposit for the first four years of being 'live' i.e. not until October 2031 at the earliest. Many have asked: 'So this means then that glass is not really in the DRS for 4 years after launch of the DRS?' In many ways that is true. But the legislation does require retailers to 'take back' in-scope glass containers (bottles). As the retailers do not need to process deposit returns, most retailers are simply planning to offer bins or crates for consumers to bring back any bottles if they so wish. However, it is believed that EfC had to commit to a certain return infrastructure in order to have their application for the Welsh DMO approved. In reality, of course, without a deposit or reward for changing behaviour, the vast majority of consumers will not change what they do day to day. Products in glass consumed at home will continue to be returned via their kerbside bins, and those littered or dropped in waste bins will continue to be. Hospitality will also be able to largely ignore the glass DRS for the 4-year interim period. Much of the DRS discussion in industry continues to be centred around glass – even though materially nothing will happen until at least 2031. This is a real headache for EfC, whose mission is clearly to deliver a well-functioning DRS including cans and PET bottles for October 2027 – now a little over a year away! The glass bottle industry and those players who depend on its use (most notably the global brewers and selected soft drinks brands) are constantly putting the Welsh Government under pressure to drop their glass plans. In my view, they shouldn't do that. What they should be doing is using this four-year 'quiet period' to find the optimum solution for glass: single-use through a DRS, and reuse. Further, I believe, respectfully, that the glass bottle industry should focus on optimising the new process, such as Extended Producer Responsibility (EPR), and should turn to DRS somewhere around 2029. A huge concern for the glass industry is cost. In the run-up to the UK DRS in October 2027 (or maybe up to 6 months later), cans and PET bottles are not within the scope of the UK EPR system, which was launched in 2025. Glass, however, as it's not in scope of the forthcoming 'UK DRS', has already started to incur EPR fees. Many see this as glass being unfairly disadvantaged compared to its main soft drinks and alcoholic drinks packaging rivals: cans and PET. Add to this the fact that the EPR system has set charges based on the weight of packaging – not units. This further penalises glass as a format due to its much higher weight compared to cans and plastic (and cartons). As EPR is a UK system, and DRS is devolved, there seems little appetite to support the Welsh glass industry, which, as it stands, is facing the costs of a DRS on top of EPR fees. In my view, this must be addressed, and quickly. So, despite glass not being effectively active in the DRS until 2031 or later, the Welsh Government and EfC must address the current concerns around the direction for glass in a DRS and for reuse. Many organisations are genuinely concerned about the future of their businesses and, more widely, their business sector. Brushing them aside or ignoring them will serve only to intensify those concerns. An open statement outlining plans to test and develop the optimum solution for glass over the next four years would at least clarify the direction. A well-designed and well-run DRS across the UK will be transformational, Midwood believes DDRS Alliance is currently developing a plan to implement a kerbside-focused solution for consumers to return their glass bottles for a reward, and on which reuse trials and pilots can sit. The plan is for this to run alongside current DRS plans and not to interfere with them. The aim is to provide EfC with two viable DRS models come 2029 or thereabouts, and to generate valuable insights and data to inform the development of an optimum reuse model for glass. As if it needed any more evidence, even in this article, too much emphasis has been put on glass in a DRS – the tail continues to wag the dog! Glass only accounts for 16% of drink containers across the UK, according to the UK Government. As Wales represents only around 4.6% of the UK population, glass containers in Wales represent less than 0.9% of the in-scope containers for the UK-wide DRS. One would expect, therefore, that there is very little focus on glass in the DRS! With that in mind then, let's turn back to the main event: the UK-wide DRS for cans and PET bottles. Critical to its successful implementation is for all stakeholders to be supportive and pulling (or pushing) in the same direction. EfC has a mammoth task to implement across all four UK nations at the same time. Brands, producers, retailers, hospitality, wholesalers, packaging suppliers, trade bodies, environmental groups, waste companies, local authorities, national government and everyone else involved need to be focused on implementing a successful solution to encourage consumers to return their used cans and PET bottles, and then to ensure the maximum amount of that is recycled back into new drink cans and bottles. Only with clear plans and 100% commitment can consumers get behind such a plan. Certainty is the driving force here, and the UK Governments, with EfC, need to be aligned and act as one. The impression 'out in the market' is that we are not there right now. By most accounts, EfC are doing a good job in scaling their own organisation and engaging with the DRS stakeholders. However, those that will be impacted by DRS and are not central to its functioning have been somewhat sidelined – such as some waste management organisations and most local authorities. A well-designed and well-run DRS across the UK will be transformational, and all stakeholders should be looking at its impact over the next 10-20 years. The DRS impact will be far wider than short-term collection rates and litter. Done right, it should change consumer behaviour and how they treat packaging – not simply as a way of getting the product to them in a convenient way, but as a resource that should be cherished and used as many times as possible before being destroyed. I would encourage all impacted industries to find solutions to the inevitable challenges and changes that a DRS will bring, rather than fighting for their own corner. Let's get into solution mode! And, if I may, one last comment on glass! Let's use the next five years to develop the best way to get glass reuse and recycling optimised, while not impacting or risking the success of the mainstream DRS on cans and PET. Let retailers focus on cans and PET bottles, and support programmes working in parallel to develop the right solution for glass.