The question

With Deposit Return Schemes (DRS) moving from policy statements to real‑world implementation, retail leadership teams need to cut through the noise:

• What, exactly, will we be legally required to do?
• What is strongly expected but not strictly mandatory?
• What is purely optional, where we can differentiate or generate extra value?

This post focuses on UK‑style DRS implementation for single‑use plastic and metal drinks containers under the UK Deposit Management Organisation Ltd (UK DMO) (https://dmouk.com/), with lessons that are broadly relevant to other schemes.

The direct answer

For retailers, DRS obligations fall into a few clear buckets:

• Mandatory (“must do”)

  • Register with the DMO as an obligated business if you place in‑scope drinks on the market.
  • Apply deposits and scheme labelling to in‑scope containers when regulations take effect.
  • Act as a return point (“return‑to‑retail”) for empty containers at stores that meet the criteria, or secure formal exemptions.
  • Refund deposits to consumers and pass accurate data to the DMO on sales and returns.
  • Cooperate with counting, settlement and audit processes.

• Discretionary but strongly recommended (“should do if you are serious”)

  • Use automated return points (RVMs) rather than manual counter returns, for hygiene, fraud control, data integrity and labour reasons.
  • Install RVMs indoors where possible, close to store entrances.
  • Engage fully with the DMO’s technical specifications and approval processes so your machines can be recognised as official return points.

• Optional but strategically valuable (“could do to differentiate and create value”)

  • Integrate RVMs with your loyalty ecosystem to capture data and run targeted incentives.
  • Monetise RVM media screens as premium in‑store digital inventory.
  • Use RVM projects to build ESG leadership stories, both pre‑DRS and during rollout.
  • Deploy AI‑Mode / closed‑loop applications in non‑DRS or special environments (factories, campuses, stadia).

What DRS will require of retailers

1. Registration and categorisation

Once DRS regulations are in force:

• Retailers who sell in‑scope single‑use plastic and metal drinks containers must:

  • Register with the DMO, providing details about:
    • Their business.
    • The volumes and types of drinks they sell.
    • The locations and types of stores they operate.

• Some very small or highly specific operators may qualify for:

  • Different obligations or reduced requirements under “low volume” thresholds.

Ignoring registration is not an option; it is the entry ticket to operating legally in a DRS world.

2. Applying deposits and scheme labelling

Producers and retailers together must ensure that:

• Every in‑scope container carries:
  • The mandatory deposit (for example £0.20) added to the purchase price.
  • Required scheme labelling indicating that it is part of the DRS.

For retailers this means:

• Updating POS systems and price files to:

  • Reflect deposit amounts correctly.
  • Differentiate between in‑scope and out‑of‑scope products.

• Working with suppliers and own‑brand partners to ensure:

  • Packaging meets labelling rules.
  • Multipacks are configured in a way that supports scanning and returns (for example barcodes on individual units once DRS is live).

3. Acting as return points or securing exemptions

Under a “return‑to‑retail” model, the general rule is:

If you sell in‑scope drinks, you must also take back empty containers and refund deposits.

However, regulations recognise that not every site can host a return point. For example:

• In the UK, urban retailers under 100 m² of retail space will not be required to host a return point.

• Other exemptions may be available where:

  • The location, layout, size or construction of a store makes hosting a return point impractical.

To remain compliant, retailers must:

• Either:
  • Operate a return point at each eligible store (typically via an RVM), or
  • Apply for and receive an exemption from the DMO, following their guidance and providing evidence.

Even exempt stores may still have obligations, such as signposting customers to the nearest available return point.

4. Refunding deposits and reporting data

Retailers that operate return points must:

• Refund deposits reliably when eligible containers are returned:

  • Manually or, more realistically, via RVM vouchers and integrated POS flows.

• Collect and submit accurate data to the DMO, including:

  • Volumes of in‑scope containers sold (deposits collected).
  • Volumes of in‑scope containers returned (deposits refunded).
  • Store‑ and return‑point‑level detail as required.

The DMO will:

• Use this data, combined with RVM event logs and counting‑centre information, to:
  • Reconcile deposits and refunds.
  • Monitor return rates against staged targets (for example 70% to 90% by 2030 in the UK).
  • Detect anomalies and potential fraud.

For finance teams, this means building repeatable reporting processes and aligning accounting treatments (deposits as liabilities, handling fees as income) with scheme requirements.

What is not strictly mandatory – but is practically essential

DRS legislation will usually not say:

“You must install an RVM with these exact specifications.”

Instead, it will specify outcomes:

• Return rates.
• Data granularity.
• Fraud prevention and auditability.

In theory, manual returns at the counter might satisfy the letter of the law. In practice, for retailers:

• Manual take‑back is:

  • Dirty, labour‑heavy, and space‑hungry.
  • Operationally fragile under peak loads.
  • Far more vulnerable to fraud and error.

• RVMs, especially those approved by or meeting the technical specifications of the DMO, are the only realistic way to:

  • Combine high return rates with acceptable store operations.
  • Provide the quality of data that settlement and audit require.
  • Protect the business from reputational damage and disputes.

Similarly, installing RVMs indoors is not codified in law, but is de facto required if you want:

• Lower deployment and maintenance cost.
• Better customer experience.
• Higher uptime and machine life.

What is genuinely optional – and where you can create advantage

Once you are meeting your obligations via compliant RVMs, several layers of activity are optional from a legal standpoint but strategically powerful.

1. Loyalty integration

Not required by law, but:

• Scanning a loyalty card/app at the end of an RVM session lets you:

  • Attribute returns behaviour to individuals (in pseudonymous form).
  • Reward recycling with points or perks.
  • Build richer behavioural datasets.

• This supports:

  • More intelligent promotions.
  • Deeper customer engagement.
  • Supplier‑funded campaigns.

2. Media and promotions via RVM screens

DRS wants containers back. It does not care what you show on the screen while that happens.

A media‑equipped RVM can:

• Display:

  • Your own brand and ESG messages.
  • Supplier adverts and offers.
  • DRS education content.

• Become:

  • A high‑value digital asset sold to brands on a CPM or sponsorship basis.
  • A critical part of your in‑store media network.

Recyclever deliberately integrates a proper media screen so that:

• You are not just buying a compliance device.
• You are buying a revenue‑generating, engagement‑capable asset that helps justify the investment.

3. Pre‑DRS pilots and non‑DRS closed loops

You are not obliged to:

• Install RVMs before DRS goes live.
• Run voluntary programmes in factories, campuses or stadia.

But doing so can:

• De‑risk the eventual DRS rollout (learning operationally in advance).
• Support ESG commitments and local authority relationships.
• Open up closed‑loop or brand‑specific programmes.

A practical obligation matrix for retail teams

You can think of DRS in three columns:

1. Must do (law / regulation)

• Register with the DMO.
• Apply deposits and correct labelling to in‑scope drinks.
• Operate or formally apply for exemption from return points.
• Refund deposits and report accurate data.
• Cooperate with counting and settlement processes.

2. Should do (practical necessity)

• Use RVMs as official, DMO‑approved return points.
• Install indoors where feasible.
• Define and deploy robust SOPs for bag changes, cleaning, and alert handling.
• Ensure clean integration between RVM fleet portals (for example RecyHub), POS, ERP and reporting.

3. Could do (strategic choices)

• Integrate RVMs with loyalty to gather data and drive engagement.
• Monetise RVM media screens via supplier campaigns and own promotions.
• Pilot early and run non‑DRS closed‑loop or ESG projects where beneficial.

Conclusion

New DRS legislation will clearly define what you must do as a retailer: register, label, collect, refund and report. It will not tell you how to make that obligation pay for itself.

The “how” is where your choices matter:

• Choosing RVMs over manual returns.
• Installing them in the right locations.
• Selecting technology that is robust, DRS‑ready and commercially flexible (media, loyalty, AI‑Mode).
• Treating RVMs not just as a compliance cost but as an infrastructure platform for service, data and revenue.

Getting the basics right keeps you legal. Using the optional layers intelligently can make DRS an opportunity rather than just another regulation to endure.