Skip to content
Specialized Packaging Market Intelligence and Strategic AdvisoryPackaging Intelligence. Clearer Decisions. Stronger Growth.
SPI Regulation Tracker

Packaging rule · United Kingdom · Deposit return

Scotland deposit return scheme start moved to October 2027

Deposit return rule covering plastic, metal in Scotland, United Kingdom, set by Scottish Ministers. Adopted; applies from 1 October 2027.

By the SPI teamRule ID PR-GB-005Source consulted 13 October 2026Verified 13 October 2026
Sourced facts

The rule

Recorded from the official source named below. Rates and dates are as the source states them on the date it was consulted.

Jurisdiction
United Kingdom · Scotland
Authority
Scottish Ministers
Rule type
Deposit return
Materials
Plastic, Metal
Status
Adopted, not yet applying Enacted
Adopted or published
19 June 2025
Applies from
1 October 2027
From the source

“for “1 October 2025” substitute “1 October 2027”.”

Official source legislation.gov.uk: SSI 2025/188Official (government or regulator) · consulted 13 October 2026

Deadlines

Key dates

  1. Adopted or published 1 year and 3 months ago

  2. Source consulted by the SPI team 2 days ago

  3. Re-checked by a second SPI team member 2 days ago

  4. Today

  5. Applies from in 11 months

SPI analysis

What it means

SPI analysis Our reading of the official source above. Not legal advice; always rely on the official text.

SPI summary

The Deposit and Return Scheme for Scotland Amendment Regulations 2025 move the main start of Scotland's scheme from 1 October 2025 to 1 October 2027, aligning with England and Northern Ireland. Registration provisions for retailers and return point operators applied from 1 July 2025.

In practice

SSI 2025/188 resets Scotland's deposit and return scheme to start on 1 October 2027 and aligns its design with England and Northern Ireland: glass is removed, the minimum size moves from 100 ml to 150 ml, and the scheme is run by a designated scheme administrator. Drinks producers apply to the scheme administrator, not SEPA, for registration before 1 October 2027 and print the scheme logo and return code. Converters and brand owners can therefore plan one artwork and material approach for the UK schemes that start that day.

Where the record is unclear

  • The explanatory note does not mention the removal of glass, although regulation 5 removes it from scheme materials.
  • The deposit amount is not stated in the pages consulted; the deposit review provision was removed.
  • The Designation Order 2025 naming the scheme administrator was not reviewed.

Where it sits in the tracker

  • One of 7 packaging rules we track in the United Kingdom, of which 2 are deposit return rules.
  • In all, 7 deposit return rules are tracked across 6 jurisdictions. Compare them below

Company profiles that map to this rule

Companies whose SPI profile lists this rule in its regulatory exposure, based on where they report selling. Not company-reported.

SPI analysis

Overview

Scotland's scheme rests on the Deposit and Return Scheme for Scotland Regulations 2020 (SSI 2020/154), made by the Scottish Ministers on 19 May 2020 under sections 84, 89, 90 and 96(2) of the Climate Change (Scotland) Act 20093. As first made, the scheme covered PET, glass, steel and aluminium containers from 50 ml to 3 litres, carried a 20p deposit written into regulation 5(1) and was to start on 1 July 20223.

SSI 2025/188 is an amending instrument, not a new scheme. It was made on 19 June 2025, approved in draft by the Scottish Parliament and in force the next day; its 33 regulations rewrite large parts of the 2020 text1. Regulation 5 takes glass out of the scheme article definition and raises the size floor from 100 to 150, regulation 3 moves the general start to 1 October 2027, and regulations 9 to 14 move producer registration from SEPA to a single scheme administrator designated by order rather than approved on application1. The companion Designation Order, SSI 2025/189, names UK Deposit Management Organisation Limited (company 16278705) as that administrator from 20 June 20252.

The stated aim in section 84(6) of the 2009 Act is to increase recycling3. The amended Schedule 3 keeps that aim measurable through return targets of 70% for 2028, 80% for 2029 and 90% from 2030, and an 85% floor for each of PET and steel or aluminium1.

Duties

Who must do what

Producer of scheme articles supplied in Scotland

  • Apply to the scheme administrator for registration before 1 October 2027, or within 28 days of becoming a producer after that (2020 regulation 7, as substituted by SSI 2025/188 regulation 9).
  • Notify material changes within 28 days, keep records for seven years and send reports to the administrator (2020 regulation 10, amended by SSI 2025/188 regulation 11).
  • Pay registration fees and a sum equal to the deposit to the administrator (2020 regulation 11, amended by SSI 2025/188 regulation 12).
  • Show the scheme logo and return code on scheme articles and the multipack logo where required, but no logo or code on low volume drink products (2020 regulation 5, amended by SSI 2025/188 regulation 7).

Groceries retailer

  • Operate a return point unless an exemption on proximity or premises grounds is granted (2020 regulations 19 and 22, amended by SSI 2025/188 regulations 16 and 21).
  • Register as a return point operator and display redemption information; registration provisions applied from 1 July 2025 (2020 regulation 1(4A)).
  • Where exempt, display the exemption and notify material changes within 28 days (2020 regulation 24, amended by SSI 2025/188 regulation 23).

Hospitality retailers and takeback service providers

  • A takeback service may only be offered after registration, with deposit payment and container retention duties (2020 regulation 21, amended by SSI 2025/188 regulation 20).
  • Where drinks will definitely be drunk on the premises, the operator says no deposit is charged and containers are stored for collection.

Scheme administrator

  • Act under an approved operational plan and submit annual reports within six weeks of each scheme year (2020 regulation 16, amended by SSI 2025/188 regulation 15).
  • Meet the Schedule 3 collection targets and make payments to return points, hospitality retailers and takeback providers (new regulations 16A and 16B).

SEPA

  • Enforce the regulations with entry, sampling, test purchase and test return powers (2020 regulation 30).
  • Recover its enforcement costs from the scheme administrator (new regulation 30A inserted by SSI 2025/188 regulation 27).
Scope

Are you in scope?

Work through each question. The answers are the SPI team's reading of the sources cited.

  1. Is the drink in a single-use container of PET plastic, steel or aluminium?

    If yes
    It can be a scheme article.
    If no
    Glass was removed from the definition by SSI 2025/188 regulation 5 and is outside the Scottish scheme.

  2. Does the container meet the minimum size of 150 ml set by the 2025 amendment?

    If yes
    In scope, up to the scheme maximum.
    If no
    Below the floor, outside the scheme; the 2025 text replaced the figure 100 with 150.

  3. Is the drink made available in Scotland on or after 1 October 2027?

    If yes
    Deposit, labelling and payment duties apply.
    If no
    Stock filled before launch stays outside; the operator asks for sell-through by April 2028.

  4. Are you a producer under amended regulation 6, for example the brand owner, importer or online seller of the line?

    If yes
    You must apply to the scheme administrator for registration.
    If no
    You carry only retailer or supplier duties.

  5. Do you sell groceries from premises in Scotland?

    If yes
    Return point duties apply unless an exemption is granted under amended regulation 22.
    If no
    Return point duties do not apply, though displayed redemption information may.
Checklist

Compliance checklist

  1. Register as a retailer or return point operator

    By Open since 1 July 2025 (registration provisions)

    SPI analysis of the official text. Not legal advice; confirm with the text or counsel. Scottish registration provisions for groceries retailers, return point operators and takeback providers were brought forward by new regulation 1(4A).

    Evidence to keep Registration confirmation from the scheme administrator.

  2. Apply for producer registration with the scheme administrator

    By Before 1 October 2027, or within 28 days of becoming a producer

    Applications go to the administrator, not SEPA, with the Schedule 1 information on scheme articles and low volume products.

    Evidence to keep Application copy and Schedule 1 data set.

  3. Remove glass from Scottish deposit planning

    By Now

    Glass lines sold in Scotland carry no Scottish deposit or label after the 2025 change.

    Evidence to keep SKU list by material and nation.

  4. Set up seven-year record keeping

    By 1 October 2027

    Amended regulation 10 requires records for seven years and reports to the administrator.

    Evidence to keep Retention policy covering scheme article sales.

  5. Model the fee path

    By Reconfirmation May 2027

    The administrator charges nothing per container until the end of 2028; from January 2029 it expects 2.3p per PET unit and 0.6p per metal unit.

    Evidence to keep Scottish unit forecasts split into PET and metal.

  6. Check due diligence controls for labelling and supply

    By 1 October 2027

    The regulation 31(14) defence requires all reasonable precautions and all due diligence.

    Evidence to keep Supplier declarations and label checks.

Enforcement

Enforcement and penalties

Who enforces
Scottish Environment Protection Agency (SEPA), acting itself or through persons it authorises in writing (2020 regulation 30).
Powers
Entry to non-residential premises, examination, measurements, photographs, samples, document seizure, test purchases and test returns, and written information notices; a sheriff, summary sheriff or justice of the peace may grant a warrant (regulation 30(4) and (5)).
Enforcement so far
SPI found no SEPA action under the scheme when checking on 14 October 2026, and regulation 31 stays prospective until 1 October 2027.

Penalties

BreachPenaltyLegal basis
Offences under regulation 31, including breaches of labelling, registration, notification, administrator, retailer and takeback duties, on summary convictiona fine not exceeding the statutory maximumSSI 2020/154, regulation 31(15), as amended by SSI 2025/188 regulation 286
The same offences on conviction on indictmenta fine (no maximum stated)SSI 2020/154, regulation 31(15)6

Scotland uses criminal offences rather than the civil sanctions schedule found in SI 2025/676. Directors and partners can be liable where an offence was committed with their consent, connivance or neglect (regulation 31(16) and (17))6. SSI 2025/188 also moves the statutory review to 1 October 2032 and drops the duty to consider the deposit amount in it (regulation 29)1.

Connections

How it fits with other rules

  • Deposit return scheme for drinks containers (England and Northern Ireland) PR-GB-004
    England and Northern Ireland share the same start date, administrator body and collection percentages, but their instrument enforces through fixed and variable civil penalties while Scotland relies on criminal offences prosecuted after SEPA investigation. A producer selling across Britain faces one registration body but two enforcement regimes.
  • UK packaging EPR regulations (pEPR) 2024 PR-GB-002
    UK packaging EPR applies in Scotland alongside the deposit scheme. Drinks containers that enter the Scottish scheme need separate tracking in EPR data so the same container is not reported twice.
  • Ireland Deposit Return Scheme (Re-turn) PR-IE-001
    Ireland's Re-turn scheme has run since 2024 with its own deposit bands. Drinks brands supplying Ireland and Scotland need different labels and deposit flows, as the Scottish logo and return code rules come from amended regulation 5.
  • Austria deposit on single-use beverage containers PR-AT-001
    The tracker record for Austria's deposit, running since 2025, lists plastic and metal containers. Removing glass from the Scottish scheme article definition in 2025 left Scotland with the same two material groups, which simplifies label and container planning for brands active in both markets.
Timeline

History of the rule

  1. SSI 2020/154 made, with a 20p deposit, glass in scope and a planned start of 1 July 2022.

  2. SSI 2022/76 amends the commencement provisions in regulation 1(5).

  3. SSI 2025/188 and SSI 2025/189 made; glass removed and start moved to 1 October 2027.

  4. Both instruments in force; UK Deposit Management Organisation Limited designated as administrator.

  5. Registration provisions for groceries retailers, return point operators and takeback providers apply.

  6. Today

  7. Main scheme duties start in Scotland.

  8. First target year, 70% of scheme articles returned.

  9. Target rises to 90%, with 85% minimums for PET and for steel or aluminium.

  10. Statutory review date under amended regulation 32.

Questions

Questions

Is glass still in Scotland's deposit return scheme?

No. Regulation 5 of SSI 2025/188, in force from 20 June 2025, removed glass from the scheme article definition. The 2020 Regulations had included glass alongside PET, steel and aluminium.

Who runs the Scottish scheme and who enforces it?

SSI 2025/189 designated UK Deposit Management Organisation Limited, company 16278705, as scheme administrator from 20 June 2025. SEPA enforces the regulations under regulation 30 of the 2020 Regulations. SEPA can recover its enforcement costs from the administrator under new regulation 30A.

What are the penalties for breaking the Scottish deposit rules?

Regulation 31 creates criminal offences punishable by a fine up to the statutory maximum on summary conviction or an unlimited fine on indictment. The offence provisions start on 1 October 2027. A due diligence defence is available for some offences under regulation 31(14).

When must a new drinks producer register in Scotland?

Before 1 October 2027, or within 28 days of becoming a producer after that date. Applications go to the scheme administrator rather than SEPA. Registration details are listed in the replaced paragraphs of Schedule 1.

How many times has the Scottish start date moved?

The 2020 Regulations set 1 July 2022, and SSI 2025/188 replaced the then start of 1 October 2025 with 1 October 2027. SSI 2022/76 also amended the commencement provisions in February 2022. The current date matches England and Northern Ireland.

Glossary

Definitions

Scheme administrator
The person designated under the Designation Order 2025 to run the scheme, replacing the earlier model of administrators approved on application (2020 regulation 2 as amended by SSI 2025/188 regulation 4).1
Scheme article
A drink in single-use scheme packaging of PET plastic, steel or aluminium within the volume limits, after glass was removed (2020 regulation 3 as amended).1
Groceries retailer
A retailer of groceries, a term inserted by SSI 2025/188 regulation 4, which carries the return point duty under amended regulation 19.1
Sum equal to the deposit
The amount a producer pays the administrator for each scheme article, defined in amended regulation 2 and payable under amended regulation 11.1
Sources

Sources for this analysis

  1. legislation.gov.uk: SSI 2025/188 Deposit and Return Scheme for Scotland Amendment Regulations 2025, as made Official · Consulted 14 October 2026
  2. legislation.gov.uk: SSI 2025/189 Deposit and Return Scheme for Scotland (Designation of Scheme Administrator) Order 2025 Official · Consulted 14 October 2026
  3. legislation.gov.uk: SSI 2020/154 Deposit and Return Scheme for Scotland Regulations 2020, as made Official · Consulted 14 October 2026
  4. legislation.gov.uk: SSI 2020/154, regulation 1 (commencement), latest revised text Official · Consulted 14 October 2026
  5. legislation.gov.uk: SSI 2020/154, regulation 30 (enforcement authority) Official · Consulted 14 October 2026
  6. legislation.gov.uk: SSI 2020/154, regulation 31 (offences) Official · Consulted 14 October 2026
  7. Exchange for Change: FAQs Compliance scheme · Consulted 14 October 2026
  8. Exchange for Change: Newsletter 15, September 2026 Compliance scheme · Consulted 14 October 2026
  9. Exchange for Change: update on transition arrangements (30 September 2026) Compliance scheme · Consulted 14 October 2026
  10. legislation.gov.uk: SI 2025/67 Deposit Scheme for Drinks Containers (England and Northern Ireland) Regulations 2025 Official · Consulted 14 October 2026
  11. legislation.gov.uk: SSI 2025/188 Deposit and Return Scheme for Scotland Amendment Regulations 2025, regulation 3 Consulted 13 October 2026

Written by the SPI team on 14 October 2026. Sources checked as of 14 October 2026. SPI analysis, not legal advice; always rely on the official text.

Audit trail

Change history

Verified: a second SPI team member re-checked every fact above against the source on 13 October 2026. Any later change to the facts sends the rule back to Sourced and is logged here.

  1. Verified by a second SPI team member

  2. Added to the tracker

Spotted an error? Write to sales@strategicpackaginginsights.com quoting PR-GB-005 and the source. Corrections are logged in this history.

Other jurisdictions

Deposit return rules elsewhere

The same type of rule for the same materials in other jurisdictions, by the date it applies.

RuleWhereTypeMaterialsStatusApplies from
Ireland Deposit Return Scheme (Re-turn)PR-IE-001IrelandDeposit returnPlastic, MetalIn force1 February 2024
Austria deposit on single-use beverage containersPR-AT-001AustriaDeposit returnPlastic, MetalIn force1 January 2025
Poland deposit return systemPR-PL-001PolandDeposit returnPlastic, Metal, GlassIn force1 October 2025
Portugal deposit and refund system (Volta)PR-PT-001PortugalDeposit returnPlastic, MetalIn force10 April 2026
PPWR: 90% separate collection of beverage containers (deposit systems)PR-EU-007European UnionDeposit returnPlastic, MetalAdopted, not yet applying1 January 2029

Every deposit return rule in the tracker

ClosingAsk the SPI team

Ask the SPI team

Does this rule apply to your packs?

Tell us your products, materials and markets. An analyst maps the obligations, fees and deadlines that apply, with every source.

Request a briefing

Prefer email? Write to sales@strategicpackaginginsights.com.

Questions people bring
  1. Q1

    Which packaging rules apply to us in each market we sell in?

    We map each market's EPR, tax, ban, recycled-content, labelling and deposit rules against your materials and formats, and show which are in force, adopted or only proposed.

  2. Q2

    What could EPR fees and plastic taxes cost us next year?

    We apply published fee tables and tax rates to your tonnages and recycled content, and show the result as scenarios with every rate sourced.

  3. Q3

    Can you tell us when a rule changes?

    Yes. The free tracker alerts cover rule changes by country; a monitoring retainer adds monthly notes on what the changes mean for your portfolio.