Welsh Deposit Return Scheme in Jeopardy: British Glass Industry Deems 2027 Plans Unworkable

The British Glass industry has expressed urgent concerns regarding the Welsh Government’s plans to include glass in the Deposit Return Scheme (DRS) launching in October 2027. The industry representation warns that, in its current form, the policy is unworkable in practice, could impose unfair costs and regulatory confusion on domestic manufacturers, and may hinder the system’s operation for other materials. According to the organization, there is a threat of double charging, and the situation needs to be clarified through immediate consultations.

Double Charging and Looming Burdens

One of the most immediate and severe issues highlighted by British Glass is the risk of double charging. Under current proposals, manufacturers placing glass on the Welsh market would simultaneously have to cover extended producer responsibility (pEPR) fees and the initial setup costs of the DRS system, which is to be established by October 2027.

According to Jenni Richards, Policy Adviser at British Glass, it is clearly unsustainable for companies selling products in glass beverage containers on the Welsh market to pay twice for the collection of the same material. Although ministers have previously indicated that glass beverage producers might not have to contribute directly to the DRS setup costs, the exact mechanism for funding the system remains unclear until the Deposit Management Organisation (DMO) managing the scheme is appointed. Without explicit intervention from the Welsh Government, the industry believes double taxation is inevitable.

Legal Concerns and UK Internal Market Distortion

Serious legal and market obstacles have also emerged regarding the glass DRS. Suspicions have arisen within the industry that the Welsh Government may have inadvertently breached the conditions of the exemption granted under the UK Internal Market Act (UKIMA). Although Wales has, in principle, received an exemption to include glass alongside metal and plastic, British Glass states it is increasingly unlikely that a workable agreement will be reached in time.

Introducing new glass collection targets before the end of the previously agreed transition period could result in statutory compliance binding only Welsh manufacturers. Meanwhile, competitors operating in other parts of the UK could be exempt from these obligations. Jenni Richards warned that if this legislative error is not corrected, the entire cost of the system will be borne solely by Welsh businesses. This creates a clear market distortion and raises serious questions about compliance with internal market principles.

Traceability and Technical Barriers

Beyond financial and legal risks, there are fundamental practical concerns regarding the actual operation of the system. In the future, recyclers would need to differentiate between glass placed on the Welsh market and glass originating from other parts of the UK, as well as separate specific beverage bottles from other glass containers.

According to the professional stance of British Glass, this is technically extremely difficult to implement. Currently, there is no credible mechanism to track glass at the individual item level required by the proposal. Since glass is collected, sorted, and processed in mixed streams in reality, this level of retrospective identification of origin and product type is unfeasible. This expectation introduces massive costs, logistical complexity, and an extremely high risk of error into the system.

Circular Economy and Reuse at Risk

The most severe environmental reservation is that including glass in the deposit system could undermine existing, well-functioning circular economy mechanisms that currently support high-quality recycling. The current system of Packaging Recovery Notes (PRN) specifically incentivizes the energy-efficient remelting of glass into new containers. This so-called closed-loop recycling provides significantly greater environmental benefits than recycling glass for lower-value purposes, such as aggregate for construction. Removing these incentives without a clear alternative risks pushing materials down the waste hierarchy.

Although the DRS is theoretically aimed at greening, the industry points out that the draft might actually make glass reuse more difficult. By diverting feedstock and investment away from reuse infrastructure, and further eliminating existing incentives, the policy could easily delay the rollout of a Welsh reuse scheme.

Adding to the complication, the reusable packaging incentives linked to reduced packaging EPR fees would automatically cease from October 2027, contradicting the stated government ambition to implement a Welsh glass reuse scheme. Until the Reuse Regulations (presumably also laid down around October 2027) come into effect, businesses have no economic incentive to introduce reuse in Wales. The wording of the “reusable” packaging targets introduced in the Welsh Government’s 2026 regulations is also problematic. These targets have not yet received full UKIMA approval. The legislation currently focuses merely on making packaging physically suitable for reuse, but does not guarantee that reuse will actually happen. Without supporting infrastructure, simply increasing material usage will lead to a decline in system efficiency.

Crucial Negotiations with the Government

As the fate of the Welsh deposit return scheme reaches a turning point, industry representatives have begun “crunch talks” with the new Welsh Government. British Glass strongly urges decision-makers—and specifically the Plaid Cymru party—to recognize the growing risks and take the necessary corrective actions.

The industry organization calls on the Welsh leadership to reconsider the program’s ultimate goals. They urge discussions on whether the implementation of the current work plan truly serves the interests of Welsh businesses and citizens. At the same time, they ask policymakers to work closely with the industry to develop a system that is not only legally and technically functional but also represents truly world-leading quality in the field of sustainable recycling.

References and Sources Used:

• Original Industry Source: Glass industry warns Welsh recycling plans are “unworkable” and faces double charging – British Glass

• Welsh Government Official Information on DRS: Deposit Return Scheme for Wales – gov.wales

• UK Government Policy Update on Internal Market Exemption: UK Internal Market Act exclusion: policy update – gov.uk