Drinks producers lie at the heart of the Deposit Return Scheme (DRS). Their drinks containers are the subject of the legislation and are ultimately responsible for what happens to them.

The DRS has been designed to ensure they are legally fulfilling their environmental responsibilities and Circularity Scotland has been created to help them do that.

The Scottish Government’s Deposit Return Scheme(DRS) legislation defines a producer as “the Brand owner”, or, where the brand owner is outside the UK, “the importer”. So, if you make drinks in the UK, retail drinks under your own label or import drinks into the UK you are viewed as a producer and have certain legal obligations under the DRS Regulations. 

These include registration with the Scottish Environment Protection Agency and responsibilities to take back packaging, repay deposits and pay handling charges. These responsibilities can be more easily discharged by appointing the scheme administrator to perform them on your behalf.

In Scotland’s DRS, a producer is a drinks brand owner or importer into the market (or the website operator, for online sales).

What you need to know  

Producer agreement

Find out more about the agreement that will allow Circularity Scotland to meet your DRS obligations on your behalf.

Producer registration 

Producers need to register with Circularity Scotland in good time to enable us to fulfill your duties under the DRS regulations. 

Producer fee

The producer fee is the financial contribution that producers will make to ensure that the DRS scheme runs smoothly. The overall fee will be based on the number of containers you put on the market. The rate will vary for different materials but that rate will be the same, per container, for every producer whatever their size. 

Packaging requirements 

The Regulations don't require you to add new labelling to packaging sold in Scotland. However, creating a new label and barcode will improve the security of the scheme. It also enables you to add a consumer-facing logo to your label - highlighting that your product is in the scheme. For this reason, the producer fee will be higher for those products staying with the existing, UK-wide, label and barcode systems. 


A key part of Circularity Scotland’s role is ensuring that cash flows round the system as efficiently and safely as possible.

Key dates for producers

  • Autumn


    Sign up with Circularity Scotland

    Sign up with Circularity Scotland

    Sign up with Circularity Scotland to start getting ready for the formal registration process. 

  • December


    Clarity on labelling

    Clarity on labelling

    Plans for a scheme logo to label drinks containers were announced. Producers can access the information by signing up.

  • Spring


    Producer fee range announced

    Producer fee range announced

    Once running costs for the scheme are clearer, we will be able to give producers a defined range for fees.

  • January


    Register with SEPA

    Register with SEPA

    If you are not registering through Circularity Scotland, you must legally register directly with SEPA from 1 January 2023


Not necessarily. If you register with Circularity Scotland, we will register your business with SEPA and undertake reporting duties on your behalf. If, however, you don’t register with Circularity Scotland, you will have to register with SEPA and fulfil their reporting requirements yourself.

Yes. Everyone producing any amount of drinks for sale on the Scottish market in PET plastic, glass or metal containers between 50ml and 3 litres is legally required to take part in the scheme.

No. You can choose to administer the scheme yourself but the costs and complexity of doing this yourself are likely to prove onerous. This is why the drinks industry has come together to create a single scheme administrator in the form of Circularity Scotland.

Financial contributions will take the form of a producer fee, charged on each drinks container placed on the market. The level of the producer fee will be determined at a later date by Circularity Scotland. 

We aim to be able to advise producers with an initial view of the likely range of producer fees by Spring 2022 but a definitive figure will be set closer to the time when the  scheme goes live. This is due to the complexity of implementing the scheme and variability in the value of recycled materials. The fee will be reviewed annually.

Circularity Scotland operates as an independent, not-for-profit company. It will run a professional, fair and highly efficient scheme that meets the collection targets laid out in the DRS Regulations while keeping producers’ fees as low as possible. Circularity Scotland is currently determining the exact producer fee and will communicate this to registrants as soon as possible.

Circularity Scotland will set out more information for producers in due course. The sign up process is now open & you’ll be able to start the formal registration process during 2022. 

Under the DRS Regulations, producers who are not using us as their scheme administrator are required to register with SEPA from January 2023 onwards. If producers choose to appoint a scheme administrator, this will be carried out on their behalf and registrations with Circularity Scotland will start in 2022. Circularity Scotland advises producers wishing to appoint it as their scheme administrator to sign up with us now to help get your businesses ready for formal registration. 

No, The Scottish Government’s Deposit Return Scheme (DRS) legislation defines a producer as “The Brand owner”, or where the brand owner is outside the UK, “the importer”.

If you are unsure if your business is required to register as a producer, please check SEPA’s FAQ page. Circularity Scotland are unable to advice businesses on the Deposit Return Scheme regulations and how they apply to their business.

We recognise the regulations place additional operating requirements on producers, but there are important reasons for requiring this information.  It is the responsibility of each producer to report the number of containers placed onto the market in Scotland, accurately and regularly. 

If you choose to appoint Circularity Scotland as your scheme administrator we will lay out the details of what we need in the contract.  You may wish to engage with your trade association to see how other organisations in a similar situation are dealing with this new legal obligation

We are not aware of any funding being available to support the Deposit Return Scheme implementation.