Exchange for Change: What UK DRS labelling means for drinks manufacturers in the UK

By Tom Smith, Managing Director, Advanced Dynamics

I’ve lost count of the number of times over the last few months I’ve been asked some version of the same question:

“Tom, what does Deposit Return Scheme labelling actually mean for us in real terms?”

It’s a fair question. Exchange for Change, as the scheme administrator for the UK’s Deposit Return Scheme (DRS), is doing a lot of work behind the scenes. Timelines are set. Requirements are emerging. Guidance is gradually becoming clearer. But from the perspective of a manufacturer trying to keep product moving out of the door, it can still feel abstract.

What I’ve noticed on site visits is that many producers understand that something is changing, but few have fully thought through what that change means for their labelling process, their packaging lines, and their operational flexibility once the scheme goes live.

DRS isn’t just a compliance exercise. For many manufacturers, it will reshape how labelling decisions are made for years to come.

From policy to production reality

On paper, the requirements are straightforward. Producers must ensure all in‑scope drinks containers carry a scheme logo and barcode. Each individual container — including those sold as part of a multipack — must be labelled correctly.

Producers must register, report volumes, and from October 2027, pay a deposit and producer fee on every in‑scope unit placed on the market, unless they qualify for the low‑volume exemption.

That all sounds manageable.

The complexity comes when those rules meet the realities of packaging operations.

Labelling isn’t just about artwork and compliance. It’s about accuracy at speed, repeatability across SKUs, and the ability to adapt without disrupting output. And DRS adds a new layer of permanence to labelling decisions that many manufacturers aren’t used to dealing with.

Why labelling suddenly matters much more than before

I was recently on a drinks production site where labelling had historically been treated as one of the most flexible parts of the line. Artwork changed regularly. Promotional labels were common. Short runs weren’t unusual. Operators were used to swapping reels, tweaking settings, and keeping things moving.

That flexibility has been invaluable — but DRS challenges some of those assumptions.

With Exchange for Change requiring specific scheme icons and barcodes on every in‑scope container, the tolerance for variation reduces. Barcode placement, print quality, scan reliability, and consistency suddenly become critical. A label that looks fine to the eye but doesn’t scan cleanly is no longer just a quality issue — it’s a compliance risk.

And unlike many other regulatory changes, this one doesn’t disappear after a period of adjustment. Once DRS labelling is live, it’s part of the packaging landscape permanently.

When labelling becomes a regulatory control point, ‘good enough’ no longer is.

The hidden pressure on existing labelling equipment

One of the quieter impacts of DRS is what it asks of labelling machinery.

Many existing labellers are perfectly capable of applying labels accurately — when conditions are ideal. But DRS raises the stakes. Barcodes must be readable. Placement must be consistent. Containers must be presented reliably, even at speed. Changeovers must be repeatable, not improvised.

On older or lightly‑built systems, that can be a challenge.

I’ve seen manufacturers assume they’ll “just update the label” without realising that their current setup relies heavily on operator intervention to maintain alignment or compensate for container variation. That approach often works right up until compliance becomes non‑negotiable.

What was once manageable through experience suddenly becomes a vulnerability.

Multipacks, variants and the SKU challenge

Another area that’s catching attention is multipacks.

Under the scheme rules, each individual in‑scope container within a multipack must carry its own scheme icon and barcode. That can complicate packaging formats that were previously simple — especially where outer packaging has historically carried most of the information.

Add SKU growth into the mix, and labelling strategy becomes even more critical. More variants mean more changeovers, more chances for error, and more reliance on systems behaving predictably.

This is where labelling stops being a standalone decision and becomes part of broader packaging line strategy.

Low‑volume exemptions still require planning

It’s also worth addressing the low‑volume producer exemption. Producers placing fewer than 5,000 units per SKU per year (or 6,250 units in the first 15 months) may not need to apply scheme labelling or pay the producer fee — but they do still need to register and report.

What I’ve noticed is that some small and growing producers assume this exemption means they can ignore DRS entirely.

That’s risky.

Volumes change. Products succeed. What qualifies today may not qualify next year. And retrofitting compliance onto a labelling process that wasn’t designed with DRS in mind can be costly and disruptive.

Forward‑thinking producers are already asking whether their labelling approach today gives them room to grow tomorrow.

Where to focus now — before the deadlines arrive

Registration opens in Q3 2026. Go‑live is October 2027. That sounds a long way off — until you’re deep into redesigning artwork, validating barcodes, testing labels at speed, and assessing whether your current labelling equipment can deliver consistently under the new demands.

The manufacturers making the smoothest transition are doing a few simple things now:

They’re reviewing their labelling capability honestly. They’re stress‑testing assumptions about accuracy and repeatability. They’re thinking about whether future compliance fits comfortably into their current processes — or whether it exposes weaknesses that were already there.

And importantly, they’re not treating DRS as “just a regulatory headache”, but as an opportunity to strengthen labelling reliability more broadly.

Regulation doesn’t just demand compliance — it exposes process maturity.

A practical way to look at Exchange for Change

Exchange for Change is not trying to catch manufacturers out. The scheme is evolving, and engagement with industry is ongoing. But once it’s live, expectations will be clear — and non‑compliance won’t be optional.

In that sense, DRS is a forcing function. It pushes labelling closer to the same level of discipline that filling, capping, and downstream packaging have been moving towards for years.

For manufacturers who already value consistency, it will be an adjustment — but not a shock. For those who’ve relied heavily on flexibility, experience and workarounds, it will require more careful preparation.

Exchange for Change isn’t really about labels. It’s about control.

Control over what goes onto the market. Control over traceability. Control over consistency. And ultimately, control over risk.

UK manufacturers who recognise that early — and treat labelling as an engineered process rather than an afterthought — will navigate DRS with far less disruption.

The regulation is coming either way. The question is whether it arrives as a scramble, or as a step you were already prepared to take.

That choice is still very much in manufacturers’ hands.