What’s happening.
From 1 October 2027, a 20p refundable deposit will apply to single-use drinks containers made from PET plastic, aluminium or steel, from 150ml to 3 litres, across England, Scotland, Wales and Northern Ireland. In Wales, glass bottles are also in the scheme, with a 0p deposit until October 2031.
The deposit travels down the supply chain on business-to-business invoices. If you supply drinks to retailers or wholesalers, your EDI invoices will need to show it correctly.
Celtrino has handled deposit return invoicing in Ireland since the scheme went live in 2024, and we’re applying that experience to the UK.
What’s changing.
● The deposit is shown separately. The 20p sits on its own against each invoice line and in the invoice totals. It shouldn’t be added to the unit price of the drink.
● The deposit is treated differently from the drink for VAT. It needs to be shown separately on the invoice. HMRC’s detailed rules are still to come.
● Your invoice maps change, your orders don’t. Current draft industry guidance says only invoices need to change and purchase orders stay as they are.
● Both EANCOM and Tradacoms are covered. The draft guidance covers EANCOM (EDIFACT) invoices and Tradacoms INVFIL version 9.
● Each retailer will set its own specification. Some may ask for more than the guidance, so each trading relationship needs checking and testing.
Already live in Ireland.
DRS isn’t new to us. Our Retail Exchange and TradeHub platforms have supported deposit return invoicing in Ireland since 2024, for suppliers, retailers and wholesalers.
Our platforms already:
● calculate the deposit on each invoice line from the number of consumer units
● show the deposit separately from the goods value and VAT
● carry a separate deposit total in the invoice summary
● support deposits on web-entered invoices as well as EDI files
For the UK, we’ll change the deposit value, VAT coding and message mappings. We don’t need to build anything new into the platform.
Keeping up with the UK guidance.
DRS International, a specialist DRS consultancy, is working with GS1 UK and leading retailers and drinks suppliers on the UK EDI guidance. We’re in contact with them and reviewing the draft as it develops.
As UK retailers publish their updated specifications, we’ll review each one as it’s published and agree the changes with you.
What to do next.
1. Check you’re registered. Producers and importers register with Exchange for Change, the UK scheme administrator. Phase 1 registration opened in September 2026 and Phase 2 starts in January 2027.
2. Know your trading partners. Make a list of the retailers and wholesalers you invoice for in-scope drinks.
3. Talk to us. We’ll review your current invoice setup with you and plan the changes as retailer specifications are published.
We look after the EDI invoicing side of DRS. For wider advice on labelling, scheme registration and operating models, we can introduce you to DRS International. This page isn’t tax advice.
