First return machines certified for the UK deposit return scheme 2027 as Scotland adds £0.7m of SEPA costs

How the UK deposit return scheme 2027 works at the return point

A deposit return scheme adds a refundable charge to a drink at the till and pays it back when the empty container is returned. Under the UK design, one not-for-profit operator, Exchange for Change, runs the scheme in England, Northern Ireland, Scotland and Wales from 1 October 2027, collects producer fees and pays retailers for each container they take back. SPI’s registration piece of 14 October set out the fee path and the phase 1 registration process; this article picks up from there.

The scope in England and Northern Ireland is single-use containers made wholly or mainly of PET, steel or aluminium, from 150 ml to 3 litres, according to Defra’s producer and retailer guidance. HDPE containers such as milk bottles are excluded, and so are liquid medicines and flavourings such as syrups. Scotland’s amended regulations use the same three materials and the same 150 ml floor, as SPI’s tracker record PR-GB-005 shows¹⁶.

Return points come in two kinds. A manual point takes containers over the counter and earns 3p per container in handling fees. An automated point uses a reverse vending machine and earns 5p per container up to 225,000 items a year, then 1.3p above that, under the support package of 10 June 2026¹³. The same package set aside £60 million of grants, at £6,000 a site in three annual payments of £2,000, for up to 10,000 small independent retailers.

Which shops must host a return point depends on size. Urban retailers with under 100 m2 of retail space are exempt automatically. Urban shops of 100 to 199 m2 and rural shops under 200 m2 may apply for exemption but must still register, and shops of 200 m2 or more face a presumption against exemption¹³. Every shop that will run an automated point now needs a machine that appears on the certified list.

Registration runs alongside. Phase 1, open since 29 September, asks only for company details, a primary contact, trading names and addresses. Phase 2 opens in January 2027 and asks for information relevant to each business’s role, and the operator has urged businesses to register as soon as possible without setting a deadline¹⁴.

What changed in the last week

26 October: Scotland publishes the amendment addendum. The Scottish Government’s Environment and Forestry Directorate published an addendum to the final business and regulatory impact assessment for the 2020 Scottish regulations. The overview page says it explores the impacts of the Deposit and Return Scheme for Scotland Amendment Regulations 2026 and of an amendment order for the designation of the scheme administrator, and should be read alongside the full assessment⁵. SPI has not yet confirmed the Scottish statutory instrument number or the date the regulations were laid before the Scottish Parliament; neither appears on the addendum’s pages.

The addendum lists four changes. The issue page says SEPA’s power to recover its costs from the scheme administrator, and to enforce those charges, will start from the day after the regulations come into force. Export shops lose both their exemption from deposit charging and their return point exemption. Hospitality retailers gain a choice over charging deposits, and the administrator may charge interest on late registration fees⁶.

29 October: certified machines and artwork rules. Exchange for Change published its first list of certified reverse vending machines, together with RVM artwork guidelines. The release says certification of the machines was undertaken by a specialist assessment provider tasked with independently running the full process, and that the list will be updated on an ongoing basis as new machines are certified¹. It names no suppliers in its text.

29 October: Newsletter #16 adds detail. The operator’s newsletter said each certified machine had been tested independently against 77 technical and operational requirements, covering container identification, fraud prevention, connectivity with scheme systems, accessibility and data security⁴. It reported that the operator’s permanent headquarters in Milton Keynes had opened, with small offices planned in Scotland, Northern Ireland and Wales. It also marked one year to go with an event in London attended by industry, government and stakeholders from all four nations, where a Defra minister spoke on the government’s support for launch.

29 October: transition guidance still pending. The same newsletter said transition arrangements are still being finalised with UK governments and regulators. That leaves the operator’s 30 September transition note, last modified on 16 October, as the working position. It says drinks filled before 1 October 2027 sit outside the scheme and can be sold after launch, and asks industry to sell that stock through by April 2028, which it says is not a regulatory requirement¹¹.

September survey results. The newsletter also reported the first wave of a monthly Retailer Readiness Survey. In September, 68% of respondents were aware of the scheme, 43% felt fairly or very prepared, and 47% of responses came from small businesses with one to five stores⁴. The newsletter gives no response count.

What certification and the Scottish amendments require

The two documents set different kinds of rules. Certification is the operator’s technical gate for machines; the Scottish amendments change legal duties for named groups of businesses. The table sets out each item and what it means in practice.

The certified list groups approved machines by supplier and machine family². SPI has not yet confirmed the supplier names or the count of machine families from Exchange for Change’s own text, so this article does not name them. The list carries a limit on what certification means: it confirms that a machine meets the operator’s requirements, not that it will perform, and retailers remain responsible for agreeing performance terms with their supplier.

The artwork guidelines are prescriptive³. Exchange for Change branding must take 50% to 75% of the front and side panels, placed at the top, with the retailer’s own branding in the lower 25% to 50%. Designs need a 15 mm black border and body copy at 24 to 30 point. On secondary screens, the central 60% of the front is kept for return messaging, and retailer or third-party content may appear only while the machine is idle or after a transaction.

The guidelines also fix the customer journey on the machine. Instruction panels show recycle, refund and redeem steps in a fixed order, with accepted and not accepted items, a call to action in a fluorescent bar and a QR code for more information. The logo must appear in black or white and may not be altered, and retailers with uncertified models or missing artwork are told to contact the operator’s helpdesk³.

Hospitality has two routes under the Scottish change. A venue that charges the deposit must tell customers a deposit has been charged and where the nearest return point is. A venue that runs a closed loop must tell customers that no deposit is required and that scheme packaging should not leave the premises, according to the impacts page⁸. In both cases the waste duty of care under section 34 of the Environmental Protection Act 1990 still applies.

The interest power has no rate yet. The addendum says the administrator will set the rate, which is expected to appear in its operational plan, and will issue guidance to producers⁸. It presents the power as a more proportionate step than SEPA enforcement for a producer that pays late.

The addendum ties all four changes to the scheme’s stated aims. Its overview describes the amendments as targeted and proportionate, and the intended outcomes include recycling at least 90% of single-use drinks containers, a scheme kept as simple as possible for consumers and businesses, and interoperability with arrangements in the rest of the UK⁵. The government says it will monitor deposits, returns and collection rates, and may consider intervening if the hospitality change affects collection targets⁸.

Who pays and who gains from the Scottish changes and the machine list

The new costs and benefits are small next to the scheme’s size, but they land on named groups. Public figures allow some of them to be measured.

Drinks producers. Producers pay the £0.7 million of added SEPA costs indirectly. The costs page says the scheme administrator pays SEPA and charges producers through registration fees, for the period December 2026 to October 2027⁹. Producers that pay registration fees late in Scotland can also be charged interest once the administrator sets a rate. Producer fees per container stay at 0p from October 2027 to December 2028, then an anticipated 0.6p for aluminium or steel and 2.3p for PET, under the stepped fee notice of 2 September¹².

SEPA and the public purse. The addendum records a £0.7 million saving to the public sector, the mirror of the business cost, because SEPA’s early work is paid for by the scheme rather than by public funds⁹. It states no change to the scheme’s estimated net present value of £366 million over ten years.

Exchange for Change. The operator gains a lever over late payers and a clearer basis for fees, but carries SEPA’s costs from December and a duty to collect hospitality empties free on request⁷. It also takes on the work of keeping the certified list current.

Export shops. Shops at Scottish airports and other export outlets lose their exemptions and face added administrative requirements and costs. The addendum gives no count of affected shops, and says airports are considering several return vending machines^7,8.

Hospitality. Scottish cafes, pubs, bars and hotels gain a choice: charge a deposit, or run a closed loop with no deposit and no duty to keep empties for the scheme. The trade-off is a duty to tell customers which model they use⁷.

Retailers and machine suppliers. Retailers that host automated points earn 5p per container up to 225,000 a year and can claim grants of £6,000 a site if they qualify¹³. Suppliers on the list gain a certified product to sell into that demand, though certification carries no performance guarantee.

Do not add these figures together. They cover different things (a ten-month cost, a ten-year present value, per-container fees, grants and handling income) and different areas, some Scotland only and some UK wide.

SPI calculation. The addendum says £0.7 million equals 0.04% of estimated scheme costs over ten years. Dividing one by the other gives £0.7m / 0.0004 = £1,750 million. Both inputs are rounded, so the implied total sits in a band of about £1.44 billion (£0.65m / 0.045%) to £2.14 billion (£0.75m / 0.035%). Spread over December 2026 to October 2027, the £0.7 million is about £64,000 to £70,000 a month, depending on whether ten or eleven months are counted.

The transition gap behind the machine list

The certified list settles what retailers can buy. It does not settle what producers can fill. The operator’s provisional note says unfilled packaging not tied to orders placed before 1 October 2027 cannot be filled and sold after launch unless it is updated to carry a deposit logo and a scheme-registered barcode¹¹. Flexibility for packaging tied to pre-launch orders depends on regulators agreeing, and Newsletter #16 said only that guidance would follow as soon as possible.

That matters most for can makers, PET preform and bottle suppliers and label printers. With 334 days to go, a producer that orders a long run of unmarked packaging now may not know whether it can use that stock after launch. The April 2028 sell-through request applies to drinks already filled, not to empty packaging.

A second gap concerns hospitality. Defra’s guidance page for England and Northern Ireland, which shows a last-updated date of 30 January 2025, says opt-out premises must collect and store empty containers for the operator¹⁵. Scotland’s amendment removes the duty to keep empties, while the addendum describes its change as aligning with England, Northern Ireland and Wales. SPI has not yet confirmed whether rules for England, Northern Ireland or Wales have changed in the same way, so operators running pubs on both sides of the border should check their duties nation by nation.

The calendar shows how little room is left. By SPI’s calculation, 273 days separate the start of phase 2 registration in January 2027 from launch, and 153 days separate the May 2027 fee reconfirmation from launch. Any packaging decision that waits for the transition guidance has to fit inside those windows, and the operator has given the guidance no date.

How Scotland's rules compare with England and Northern Ireland

Both schemes share one operator, one start date, a 20p deposit and the same collection path of 70% in 2028, 80% in 2029 and 90% from 2030. They differ in how they are enforced and, after the 2026 amendments, in some retail duties. The comparison below is built from SPI’s tracker records PR-GB-004 and PR-GB-005 and the new addendum.

Enforcement is the biggest structural difference. England and Northern Ireland use civil sanctions, with fixed penalties of £1,000 for breaches such as unregistered supply or missing labels and £500 for lesser display duties, under SI 2025/67. Scotland relies on criminal offences under regulation 31 of its 2020 regulations, prosecuted after SEPA investigation, with fines up to the statutory maximum on summary conviction¹⁶.

Late payment is handled differently across UK packaging rules too. Under packaging EPR, PackUK may charge interest on an unpaid disposal fee instalment 50 days after it falls due, according to the GOV.UK notice of liability guidance held in SPI’s UK fee data¹⁷. The Scottish deposit amendment gives Exchange for Change a similar lever on registration fees, with the rate still to be set. SPI’s Ledger on UK EPR year 2 explains how that EPR bill is built.

All money figures are pounds sterling. The late payment row compares the trigger for interest, not a rate, because neither rate is set out in the documents above. Wales starts on the same day and includes glass at a 0p deposit until 30 September 2031, as SPI’s Ledger on deposit return across Europe and the UK explains.